How do you handle resubmittals?

[Yankee Chronicler]

I'm looking for some feedback on how other departments handle resubmittals to correct issues in the initial set of construction documents.

For commercial projects, over the past several years we have found that it's almost unheard of for any permit to be approved upon the initial submittal. The quality of work currently produced by architects these days is shockingly deficient, but that's another rant. This is about how you process their efforts to address the initial deficiencies.

Building department records are, by law, public records (at least here, and I assume this is the case everywhere). As public records, "the public" has a right under FOI laws to look at these records at any time. We are using the Municity on-line system, with a public portal that allows any person who creates a City Squared log-in to look at the entire file for any permit or permit application. However, because our department and the Fire Marshal's office aren't fully set up to perform plan reviews on-line, we also require applicants to submit three sets of full-size prints (two for Building, and one for the Fire Marshal).

We have had projects that had construction documents (plans) sets running into the hundreds of pages. A few years ago, on one such project, the architects sent us stacks of revised drawings, followed by revisions to the revised drawings and/or revisions to other drawings, followed by revisions to the revised (or other) drawings. By the time we finally approved the permit, I had probably spent at least a full 40-hour work week just disassembling plan sets, putting black marker X's through superseded sheets, inserting the newest sheets into the proper places in the sets, and then stapling the sets back together.

Following that debacle, we established a policy that any resubmittal that revises more than three sheets or pages must be resubmitted as complete, new sets. This is clearly stated in every plan review letter. Apparently architects can't read, because we're still receiving resubmittals consisting of replacement sheets only, or what initially appears to be complete, stapled and bound sets but which examination subsequently reveals aren't complete. I'm getting increasingly frustrated by trying to deal with this. How do y'all handle this problem?

 

[Inspector Gadget]

II refuse to deal with paper. Everybody can create .pdfs these days. I require significant changes in plans to be complete re-submittals of the entire document package.

If it's a major project and the plans are approved, I will digitally stamp the plans and send them along with the permit.

In your case, if they aren't delivering what you want, roll the plans up, park them on the front desk, and tell the client that you are not accepting the plans as they didn't meet your requirements, please send complete set of new drawings thank you so much have a nice day.

 

[jj1289]

We review the revised sheets and if approved, require the submitted of an updated conformed set of documents.

 

[steveray]

I don't collate...If it is only a few sheets and we don't "need" a set, I will staple them to an existing set.....This is partly our fault for not keeping up with the times on digital crap (which is part of my struggle)....Not that the digital submissions are any better....

 

[tmurray]

When I was on the municipal side,

Usually complete re-submission. The only exception is when pages are added.

Whole drawing sets are retained for version control (who knew what when).

 

[Sifu]

I look at this on two levels: (disclaimer...I have created my own system, and used it through several AHJ's, because nobody else has ever bothered to.)

1) resubmittal=plans that are resubmitted to answer review comments PRIOR to being approved, stamped and returned. They must 100% complete, because that is what will ultimately (theoretically) be stamped and returned. I do no collate, extract, insert or delete pages from prepared sets.
There could be and often are multiple resubmittals (I number them), for example, a plan that ultimately gets stamped will have "Approved" at the beginning of the file name, follow a naming convention and have the resubmittal number in parenthesis at the end. So "(Approved) xxxxxxxxxxx plans (4)".

2) revision=plans submitted to change an already reviewed, approved and stamped page. Revisions must only include the pages being changed. They will be reviewed and stamped separately, with their own file name and will supersede the page(s) in the field.
A revised set of pages gets a "Revision" stamp, with the revision number and would follow the same naming such as "(Approved) xxxxxxxxxxx REV 1"
There could be resubmittals to revisions which would be "(Approved) xxxxxxxxxx REV 1(2)"

Document management, naming conventions, security, retention.....all stink just about everywhere I have been. I have found only the larger AHJ's have any type of system, policy or protocol. And even if a smaller one has some semblance of a system, nobody follows it, instead they do it differently every time and from person to person.

 

[Inspector Gadget]

Document management, naming conventions, security, retention.....all stink just about everywhere I have been. I have found only the larger AHJ's have any type of system, policy or protocol. And even if a smaller one has some semblance of a system, nobody follows it, instead they do it differently every time and from person to person.

I think I'm really good at this. My former life was as a reporter/desk editor/editor/managing editor in newsrooms, often dealing with content from a dozen sources for multiple editions, special projects, etc.

I guess that zealotry has transferred into the current position. One of the things I strive to do is appropriate dating on files, including letters, plans reviews, whatever. Dates are always in the filename. Always.

Our inspection documents are now standardized across four inspectors. Inspection (permit-number)(inspectiontype)(address or building owner)

 

[jar546]

How do y'all handle this problem?

Software. Good permitting software. Next month will be 4 full years that I converted our department to 100% paperless and online.

 

[Yankee Chronicler]

I look at this on two levels: (disclaimer...I have created my own system, and used it through several AHJ's, because nobody else has ever bothered to.)

1) resubmittal=plans that are resubmitted to answer review comments PRIOR to being approved, stamped and returned. They must 100% complete, because that is what will ultimately (theoretically) be stamped and returned. I do no collate, extract, insert or delete pages from prepared sets.
There could be and often are multiple resubmittals (I number them), for example, a plan that ultimately gets stamped will have "Approved" at the beginning of the file name, follow a naming convention and have the resubmittal number in parenthesis at the end. So "(Approved) xxxxxxxxxxx plans (4)".

2) revision=plans submitted to change an already reviewed, approved and stamped page. Revisions must only include the pages being changed. They will be reviewed and stamped separately, with their own file name and will supersede the page(s) in the field.
A revised set of pages gets a "Revision" stamp, with the revision number and would follow the same naming such as "(Approved) xxxxxxxxxxx REV 1"
There could be resubmittals to revisions which would be "(Approved) xxxxxxxxxx REV 1(2)"

Point taken. My question was limited to revised plans submitted during the initial permitting review stage; I was not addressing what the code refers to as "amended" construction documents post-permit.

 

[Mark K]

The designers perspective.

It is good practice for the title block of each drawing to list each time changes were made to that sheet. Specific changes are identified by clouding the change and associating changes with a Delta containing a revision number.

When the construction documents are returned from the plan checker it is assumed that a thorough plan check was performed. It is not appreciated when a partial plan check is done resulting in new comments due to an incomplete original plan check. A complete plan check allows the designer to respond to all of the issues at one time.

The focus of the back check should be on resolving plan check comments, not on competing the plan check or expanding on the original plan check comments.

Plan checking by the inspector should be discouraged and when it happens the inspector should review his comments with the plan checker.

It is appreciated that there may be exceptions, but those exceptions should be rare and should be reviewed by the building official. When exceptions occur the building official should ask himself whether the building department's process needs improving or individuals need further training.

 

[Yankee Chronicler]

The designers perspective.

It is good practice for the title block of each drawing to list each time changes were made to that sheet. Specific changes are identified by clouding the change and associating changes with a Delta containing a revision number.

When the construction documents are returned from the plan checker it is assumed that a thorough plan check was performed. It is not appreciated when a partial plan check is done resulting in new comments due to an incomplete original plan check. A complete plan check allows the designer to respond to all of the issues at one time.

Our plan reviews always attempt to be complete, but often the drawings are so horrendous that it's not possible. Aside from that, the construction documents are supposed to be correct and complete the first time the building department receives them. When I was on the architect side of the counter, I regarded it as a personal lapse if a plan reviewer found anything wrong with my work. One jurisdiction I submitted to -- Baltimore County, Maryland -- had a hard and fast rule -- if a plan review reached 20 comments, they stopped. Their position -- which was entirely correct -- was that it's the design professionals' job to produce construction documents that comply with the codes. The role of the plan reviewer is supposed to be simply to verify this -- it is NOT to act as the design professionals' quality control department.

The focus of the back check should be on resolving plan check comments, not on competing the plan check or expanding on the original plan check comments.

More often than not, making the corrections needed to respond to the first plan review comments results in other non-conformities. If I ignore them, I'm not doing my job. We end our plan review letters with a boilerplate statement:

"While this department makes every effort to review construction documents diligently for conformity to code requirements, we do not represent that the foregoing comments constitute a complete or exhaustive tabulation of all deviations or non-conforming conditions. It is the responsibility of the owner and applicant to provide finished construction that is fully in conformance with code requirements; failure on our part to note any deficiencies does not absolve you of that responsibility. Due to the number of revisions which will need to be made to these construction documents to demonstrate conformity to code requirements, we respectfully suggest that your design professional undertake a thorough review of the design for code compliance before resubmitting."

Of course, they never do. They make a half-hearted attempt at doing something that might make the comments go away, but the average for commercial projects in our office is running about 3 to 4 submittals before we can feel comfortable issuing a permit -- and, even then, it's sometimes only with red marks on the approved sets. This isn't because we didn't do a complete plan review the first time, if that's what you were implying. It's because the design professionals working in the area I'm in suck.

Plan checking by the inspector should be discouraged and when it happens the inspector should review his comments with the plan checker.

They do check back.

 

[Inspector Gadget]

Plan checking by the inspector should be discouraged and when it happens the inspector should review his comments with the plan checker.

Question: I want to clarify what you mean by "plan checker," here. Are you talking about a person on the designer's side of the equation, or the planning/building part of the equation?

Reason I ask is that our shop is small, and with but one exception (a trainee who has strong field skills but isn't quite ready to review plans on his own), each inspector reviews plans and then is responsible for the build from permit issuance to final inspection. In other words, I *am* the plans reviewer, and field inspector.

More often than not, making the corrections needed to respond to the first plan review comments results in other non-conformities. If I ignore them, I'm not doing my job. We end our plan review letters with a boilerplate statement:

Exactly. I wish folks would grasp this reality.... the changes made to correct one error may often accidentally create another issue. Off the top of my head

- point load transfer
- duct penetration of fire separations
- exit pathways, exit widths, exit distance
- Fire separation requirements might change (Had a room required to be separated by 1 hour moved so that part of a wall was also part of a public corridor. Now that 45-minute wall has to be one-hour in that location.

In short, there are times when a "minor change in the plans" causes the requirement for a complete top-down review of the whole thing.

 

[Mark K]

Question: I want to clarify what you mean by "plan checker," here. Are you talking about a person on the designer's side of the equation, or the planning/building part of the equation?

Reason I ask is that our shop is small, and with but one exception (a trainee who has strong field skills but isn't quite ready to review plans on his own), each inspector reviews plans and then is responsible for the build from permit issuance to final inspection. In other words, I *am* the plans reviewer, and field inspector.


Exactly. I wish folks would grasp this reality.... the changes made to correct one error may often accidentally create another issue. Off the top of my head

- point load transfer
- duct penetration of fire separations
- exit pathways, exit widths, exit distance
- Fire separation requirements might change (Had a room required to be separated by 1 hour moved so that part of a wall was also part of a public corridor. Now that 45-minute wall has to be one-hour in that location.

In short, there are times when a "minor change in the plans" causes the requirement for a complete top-down review of the whole thing.

It is easy to blame it all on the design professional but the reality is that there are also some plan checkers who do not make an effort to do a thorough plan check. This may be because they have to respond within x days and they have too much work. I suspect that the policy of stopping after 20 comments actually results in a longer plan check process since the issues still must be addressed resulting in more resubmittals.

General statements that the design professional should perform a complete review are not helpful. If there are major problems with the submission an in person meeting is likely to be productive.

3 to 4 re-submittals is excessive which suggests either that you have poor design professionals in your neck of the woods or your system or plan checkers have issues.

In California OSHPD and DSA, two state agencies dealing with schools and hospitals, are known to do thorough plan checks but even so I do not remember any projects that required 3 to 4 re-submittals.

 

[Yankee Chronicler]

I'm the primary plan reviewer for commercial projects in the town where I work. It's not unusual for me to write up 20 to 30 comments on a plan review. I cite the code section(s) with all of my comments. I often get a set of revised drawings (with or without a narrative summary of the revisions, often with the drawing changes not even "clouded") in which 10 or 15 of the comments simply weren't addressed -- at all.

Then there are the ones who cloud the revisions -- with a single cloud that follows the border outline of the drawing sheet, thereby encompassing the ENTIRE drawing. And don't assign a revision number tag to the cloud.

Yes -- we have poor design professionals in my neck of the woods.

 

[jar546]

It is good practice for the title block of each drawing to list each time changes were made to that sheet. Specific changes are identified by clouding the change and associating changes with a Delta containing a revision number.

Believe it or not, this frequently does not happen. No clouds or delta, just a new revision date that forces us to look at the whole thing all over again. I often just reject the revisions when they are not clouded. Less than 1/3 of the time do we even get a response letter.

The focus of the back check should be on resolving plan check comments, not on competing the plan check or expanding on the original plan check comments.

I agree to a point. Sometimes the changes themselves create other issues that were not part of the original comments. Also, see my comment above.

It is easy to blame it all on the design professional but the reality is that there are also some plan checkers who do not make an effort to do a thorough plan check. This may be because they have to respond within x days and they have too much work. I suspect that the policy of stopping after 20 comments actually results in a longer plan check process since the issues still must be addressed resulting in more resubmittals.

I would not argue that. I don't allow that in my jurisdictions.

3 to 4 re-submittals is excessive which suggests either that you have poor design professionals in your neck of the woods or your system or plan checkers have issues.

Our record is 9. We start charging per page on resubmission #2.

 

[jar546]

Right from the Florida State Statutes:

(b) With respect to evaluation of design professionals’ documents, if a local government finds it necessary, in order to enforce compliance with the Florida Building Code and issue a permit, to reject design documents required by the code three or more times for failure to correct a code violation specifically and continuously noted in each rejection, including, but not limited to, egress, fire protection, structural stability, energy, accessibility, lighting, ventilation, electrical, mechanical, plumbing, and gas systems, or other requirements identified by rule of the Florida Building Commission adopted pursuant to chapter 120, the local government shall impose, each time after the third such review the plans are rejected for that code violation, a fee of four times the amount of the proportion of the permit fee attributed to plans review.

 

[Mark K]

Observations over multiple years and multiple jurisdictions

Engineers typically deal with multiple jurisdictions but it is not uncommon for a significant portions of the projects to be in a few jurisdictions.

Multiple resubmittals are an additional cost. The engineering firms are motivated to make a profit. In addition clients and Architects apply pressure to obtain a permit as soon as possible.

As a result engineers quickly come to an understanding of what they must do to minimize the number of resubmittals and speed up approval. In this context and in my experience the need for there to typically be 3 to 4 resubmittals is not a reality.

With regards to the monetary penalties in Florida those penalties would create additional incentives. In California building departments must limit their fees averaged over several years so as not to exceed their costs.

 

[Yankee Chronicler]

Here's an example. The A/E firm for this project is a good-size firm in another state. The project is a new building for a client company with locations in states all across the country, and this A/E firm does all their design work. Here's one page from the second plan review. Note that they simply ignored several of the comments. There was a narrative letter accompanying the revised plans that referred to revised civil drawings.



On the next page of this [second] plan review there were six more specific comments all with code section cited. Four of the six were not addressed by the revisions. This is from a purported major A/E firm that works in multiple states. If they're this bad, then consider how bad the local architects and unlicensed building designers must be.

I don't think my plan review notes are especially cryptic. I make a conscious effort to be as clear and proactive as possible, with the goal of helping the applicants get approval as expeditiously as possible. But I can't (and won't) do it for them. As has been discussed in other threads, I am a licensed architect. I have to be very careful NOT to suggest ways to correct problems, because in this litigious society the odds are the designer will follow a suggested correction, implement it wrong, and then blame me for "telling him" to do something that doesn't meet code. I'm not playing that game. The town pays me to be a building official, not to be every applicant's architect.

There's an old saying that "Man proposes; God disposes." In our world, the designer proposes and the building official disposes. Their job is to submit construction documents that clearly and in detail [code language] show how the proposed construction will conform to code requirements. The plan reviewer's job is to verify that the proposed work will conform to code requirements -- nothing more, nothing less. It's a system of checks and balances.

 

[tmurray]

Right from the Florida State Statutes:

(b) With respect to evaluation of design professionals’ documents, if a local government finds it necessary, in order to enforce compliance with the Florida Building Code and issue a permit, to reject design documents required by the code three or more times for failure to correct a code violation specifically and continuously noted in each rejection, including, but not limited to, egress, fire protection, structural stability, energy, accessibility, lighting, ventilation, electrical, mechanical, plumbing, and gas systems, or other requirements identified by rule of the Florida Building Commission adopted pursuant to chapter 120, the local government shall impose, each time after the third such review the plans are rejected for that code violation, a fee of four times the amount of the proportion of the permit fee attributed to plans review.

I...I might steal this for our province...

 

[Inspector Gadget]

It is easy to blame it all on the design professional but the reality is that there are also some plan checkers who do not make an effort to do a thorough plan check.

I've seen the archaeological evidence. In fact, I was just talking to a co-worker about the fact that I'm perceived as a big-bad meanie for enforcing (for the first time, in many cases) Codes that have been in existence since at least 1990, if ot earlier.

Our record is 9. We start charging per page on resubmission #2.

We had one project where a ... let's just call the plan creator a "pretty picture drawer" who simply did not have the competency to deal with light commercial work. He was OK (meh) on houses, but was totally over his head dealing with a two-storey E occupancy with fire separation and exit issues.

I would have to go back through my files, but I'm pretty sure we issued five-six rejections. In many cases, the guy simply failed to correct things that had been pointed out several times before. I remember the stair details took at least four revisions to solve. Buddy simply could NOT fathom that when he submitted treads that said "seven-inch rise" that when I took the distance between the floors and divided by the number of specified stairs, the end result was not, in fact, seven inches, and that no matter HOW many times he submitted stairs with 13 treads to span the distance in question, I was going to reject it, because he needed 14 treads to meet Code.

Which leads nicely to ...

I...I might steal this for our province...

Might I subtly suggest the added phrase, "with 10 per cent of all such fees to be deposited in an interest-bearing account of the senior building inspector for the jurisdiction." I could retire by the end of the year.

I say that because it has been an exceptionally long time since I have issued a permit right out of the gate.

Some of the rejections are really, really basic things like "you can't have a laundry room accessible from an exit shaft."

Others are things you'd think were common sense. "The slab detail on page (X) shows the floor slab directly contacting the frost wall. This creates a zone that has a thermal resistance of diddly/squat; please resubmit a design that meets the requirements of the NECB/9.36/something better than granny's house with the buckwheat hulls in the stud cavities."

I just rejected a plan that had a 245m2 D occupancy with one exit.

We desperately need to follow Ontario and have requirements for non-residential Part 9 buildings to be created by people with some skill and training.

 

[tmurray]

We desperately need to follow Ontario and have requirements for non-residential Part 9 buildings to be created by people with some skill and training.

It's on the list.

 

[steveray]

I suspect that the policy of stopping after 20 comments actually results in a longer plan check process since the issues still must be addressed resulting in more resubmittals.

General statements that the design professional should perform a complete review are not helpful. If there are major problems with the submission an in person meeting is likely to be productive.

If it is that bad we do encourage a meeting...We encourage a page flip at 60 or 80% con docs...Rarely taken advantage of and saves so much time...

 

[Sifu]

I'm with Yankee.

An example of what I found on the first page of a current project. Not all of these are code issues, but they do lend themselves to the approach taken by the designer, and what I can expect to find on page 2...and beyond.

First page: (code analysis and life safety plan)

• References the wrong code
• Multiple spelling errors (everything these days has some sort of spell check!)
• Lists the non-sprinklered CPET provisions for a sprinklered building
• Provides separation of occupancies in a non-separated building (their choice, but they don't even get this right)
• Provides frontage calculations for a building that is only 10% the size of allowable area (not even close to needing frontage)
• Runs the EATD through solid walls, and across diagonals in open offices
• Notes incidental separations where none exist
• Provides 1-hr fire partitions for occupancy separations in a separated building instead of fire barriers, even though neither would be required if non-sep.
• Provides a legend with exit separation line and diagonal measurement, but doesn't provide them on the plan itself.
• Labels a garage as a sallyport.
• Provides 2 exits specifying OL as the reason, when it is CPET that drives it.
• Square footage of the project is not provided

There was a review meeting prior to formal submittal, but apparently my mic was off (sarcasm)
New very small, VB, single story, single occupant building
There are 25 code comments with citations. 20 of them are on the A pages.
This is a government building, the local government is the applicant.
It was requested that I do the review. (by whom I do not know)

One last funny....On another current project, there are also spelling errors. On this one, in the title block, they spell the name of the facility/project wrong. I would love that if I were the client!

 

[rktect 1]

You should not be disassembling a licensed design professionals set of drawings. Period. That can probably lead to legal issues.

If you are still doing paper, make them either resubmit the entire set or the design professional or their representative can come into the office and disassemble and reassemble and resubmit.