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Exception to IBC106.1 -Submittal documents

Code Neophyte

Silver Member
Joined
Oct 17, 2009
Messages
271
Location
Central Missouri
I know this will elicit a wide range of responses, based on location and size of jurisdiction, political support, etc.

The exception to 106.1 allows the building official to waive the submission of construction documents "if it is found that the nature of the work applied for is such that review of the construction documents is not necessary to obtain compliance with this code"

Under what circumstances would you be inclined to waive the submission of documents requirements?

In a shell space build-out with an OL < 30 and no changes to egress doors - only a few partition walls (no corridors, etc.)?

My understanding of our state's licensing statute is that if drawings are prepared, they must be prepared by a RDP. But if no drawings are required by the AHJ under the exception to 106.1, then it is not required that an RDP prepare plans?

Any input from the Land of Lincoln would be especially appreciated!

Happy New Year, fellow code wonks!!!
 
Just had one where a 1200 sq ft strip store tenant space changed tenants. Cell phone sale to vitamins. Exiting, restrooms, emergency illumination, storage rooms all remained the same, Slat wall and some counters where installed. He had a floor plan showing his merchandising pad layout, Issued permit did a final CO inspection. Pretty simple.
 
I can’t understand why you would even want to put yourself in a position not to require construction documents to “circumvent” registration statutes. Who will be “designing” the space to comply with the codes, you will by virtue of the additional questions that will be asked of you. Will you be designing all the accessibility elements of the building and taking responsibility for any design work. How is your successor or the attorneys going to know what was built if there are no prepared/reviewed documents in your files? What will be your answer as to why you did not require submittals......oh, I just wanted to “circumvent” registration statutes. I would think REQUIRING construction documents would save your office time and liability. Check with your legal council for further direction.
 
I can’t understand why you would even want to put yourself in a position not to require construction documents to “circumvent” registration statutes. Who will be “designing” the space to comply with the codes, you will by virtue of the additional questions that will be asked of you. Will you be designing all the accessibility elements of the building and taking responsibility for any design work. How is your successor or the attorneys going to know what was built if there are no prepared/reviewed documents in your files? What will be your answer as to why you did not require submittals......oh, I just wanted to “circumvent” registration statutes. I would think REQUIRING construction documents would save your office time and liability. Check with your legal council for further direction.
 
Khsmith,

I appreciate your position on this, and by and large, don't disagree. To play devil's advocate (sort of):

1. I am not "circumventing" registration statutes, I am operating within my latitude as an AHJ under the exceptions to the statute, which identify only "structural" and "life safety" changes in renovation as being requirements for design by an RDP.

2. Accessibility is not included in the statute's definition of "non-exempt".

3. If the permit application contains a statement that the applicant assumes responsibility for compliance with the applicable codes, then they are "taking responsibility for any design work" - not me.

4. I explain that, absent plans, there is the very real possibility - or even probability - that in the course of our inspections we will identify work that is not in compliance, and those elements will have to be removed or modified in such a way as to be compliant. In other words, "the hard way".

But under the exceptions in the IBC, as well as in the statute, in these smaller projects, I would tend to give the applicant the option of paying now (for design) or paying later (correction orders, delays, etc.).

In my example above, the tenant remodel (around 2,700 s.f.) is a change of occupancy without a change of use (B to B). No changes to exits, no corridors, OL<30, no modification to fire-resistive separation, no structural changes, etc. They are adding one, accessible restroom, and of course there will be other accessibility concerns (door widths, approaches, maneuvering, counter, etc.). So am I way beyond the intent of the "exception" in not requiring plans?
 
The accessibility concerns are why I require plans for just the kind of job you are talking about, especially when adding toilet rooms.

I also do what mtlogcabin said when they are "doing nothing."
 
khsmith55 said:
I can’t understand why you would even want to put yourself in a position not to require construction documents to “circumvent” registration statutes. Who will be “designing” the space to comply with the codes, you will by virtue of the additional questions that will be asked of you. Will you be designing all the accessibility elements of the building and taking responsibility for any design work. How is your successor or the attorneys going to know what was built if there are no prepared/reviewed documents in your files? What will be your answer as to why you did not require submittals......oh, I just wanted to “circumvent” registration statutes. I would think REQUIRING construction documents would save your office time and liability. Check with your legal council for further direction.
"if it is found that the nature of the work applied for is such that review of the construction documents is not necessary to obtain compliance with this code"

To avoid unneccesary bureaucracy, and to allow a competent individual to design their own project to save time and money. And yes, this generally requires us to answer building code questions (serve the public).

We do not require anything pertaining to the structure beyond a floorplan for one and two-family. Any commercial project exceeding $75,000 requires a stamp.
 
Code Neophyte said:
I am not "circumventing" registration statutes, I am operating within my latitude as an AHJ under the exceptions to the statute, which identify only "structural" and "life safety" changes in renovation as being requirements for design by an RDP.
Partition changes affect egress and therefore life safety.
 
Exactly Brudgers.....and once they have those plans and code data...it makes the next (and maybe more complicated project) that much easier! Unless you get a RDP that will stamp a ****tail napkin and a BO who will approve it...then everyones time just got wasted...
 
I would not require stamps on the project described. I tend to look for any means possible to NOT require stamps.
 
It would depend on the exact plan you are looking at. Partition walls might effect fire supression elements, egress elements as noted, interior finish elements, accessible elements etc etc.

I HAVE used that section and approve very minor projects, very carefully.
 
cabinet and countertop replacement, adding 2 receptacles (to come up to code).. moving one non bearing wall... relocating shelving, etc.. can all be handled effectively (more effectively) by the field inspector. IMHO
 
Peach (and others)

Do you require a permit for cabinet and countertop replacement and relocating shelving as mentioned in your reply?

If so, why?

Joe
 
mn joe said:
Peach (and others)Do you require a permit for cabinet and countertop replacement and relocating shelving as mentioned in your reply?

If so, why?

Joe
I have had one bookstore relocate shelving and void the travel distance to an exit. Moving one non-bearing partition wall can have the same effect. My state requires changes in egress to be submitted by a licensed professional.
 
Min&Max said:
I would not require stamps on the project described. I tend to look for any means possible to NOT require stamps.
State laws vary. So long as you are in compliance with yours when issuing permits, that's fine.
 
I have found myself gravitating towards Min&Max approach. Like brudgers commented you have to stay within your state guidelines but minimizing the contractors need to get stamps is resulting in a much better working relationship with them. If a plan needs corrections it is much easier and faster to get the contractor to fix it than argue with some DA design professional who's main interest is adding cost to the project in order to bump his salary.
 
Shelving is furnishings.. that's why the field inspector should make the call.. for countertops, cabinets, etc.. its generally exempted from permits.
 
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