Statements of special inspection -- again

[Yankee Chronicler]

We have a project for which we have approved the plans, but we can't issue the permit because the engineer (from another state) can't seem to figure out how to complete a statement of special inspections. Last Friday I had a long telephone discussion with the contractor, who is also the applicant, explaining what the issues are. About an hour later, I received a phone call from the owner of named testing laboratory asking why we had rejected them as the special inspections agency. I told him we hadn't rejected his company, we had rejected the SSI because it wasn't properly completed and didn't include information that is specifically required by IBC.

In the course of the phone call with the lab owner, he mentioned that his lab is not NVLAP accredited, and that none of his technicians hold certifications from groups such as the ACI, AWS, etc. He said he trains his employees and "certifies" them internally.

Problem: our state statutes (since 1990!) have required testing labs involved in construction testing to be NVLAP accredited, and that requirement is reproduced in the IBC as adopted by this state. Verifying that the named testing agency holds required certifications is supposed to be something the engineer-of-record does before he lists the agency on the SSI. Obviously, this engineer didn't bother to do that.

Has this been an issue for anyone else?

 

[jar546]

The engineer provides a special inspection form and digitally signs and seals it. The form is downloaded from our website. At that point, the engineer is taking responsibility for the special inspections that he/she declares.

 

[Yankee Chronicler]

Update: I have consulted the State Building Inspector's office, and they confirmed that I am reading the code and the statute correctly. Labs performing special inspections for soils and for concrete must hold NVLAP accreditation.

The NVLAP program is under NIST (National Institute for Standards and Technology). They publish an on-line roster of accredited testing laboratories, which can be searched by name, or by state. The lab I'm dealing with doesn't come up either way, so that means we can't approve them as a special inspections agency. The roster does list some other labs we've been seeing, so there are options available to the owner/applicant.

If anyone is curious about testing labs you deal with, here's the link to the roster search page:

Touchstone: Accreditation & Assessment Management System - Customer Portal

If you find a lab on the roster, their accreditation number (left-hand column) is a hotlink to their certification page. From there, you can click a link to get a PDF of their certificate, with date range, and another link to download a PDF showing exactly what areas of testing they are accredited to perform.

REMEMBER: The NVLAP program is voluntary. Labs do not have to participate. However, in my case we have a statute (dating to 1990) that requires NVLAP accreditation for labs doing soils testing and concrete testing. So for my purposes, it's not so voluntary -- if the lab wants to do special inspections in this state.

 

[steveray]

Update: I have consulted the State Building Inspector's office, and they confirmed that I am reading the code and the statute correctly. Labs performing special inspections for soils and for concrete must hold NVLAP accreditation.

The NVLAP program is under NIST (National Institute for Standards and Technology). They publish an on-line roster of accredited testing laboratories, which can be searched by name, or by state. The lab I'm dealing with doesn't come up either way, so that means we can't approve them as a special inspections agency. The roster does list some other labs we've been seeing, so there are options available to the owner/applicant.

If anyone is curious about testing labs you deal with, here's the link to the roster search page:

Touchstone: Accreditation & Assessment Management System - Customer Portal

If you find a lab on the roster, their accreditation number (left-hand column) is a hotlink to their certification page. From there, you can click a link to get a PDF of their certificate, with date range, and another link to download a PDF showing exactly what areas of testing they are accredited to perform.

REMEMBER: The NVLAP program is voluntary. Labs do not have to participate. However, in my case we have a statute (dating to 1990) that requires NVLAP accreditation for labs doing soils testing and concrete testing. So for my purposes, it's not so voluntary -- if the lab wants to do special inspections in this state.

Glad they agree with me…

 

[Yankee Chronicler]

Update: The engineer-of-record has now made four attempts at filling out the SSI, and he still can't manage to get a single page correct. On the last try he enlisted the help of the engineer from the local (next town) testing lab they intend to use, and together they still managed to mess it up.

Just went through the SSI for another project, by another out-of-state design team, and they messed up every page, as well.

And I just opened up a new application for a new commercial building -- and there's no SSI.

I'm baffled. This has been a requirement in the codes since 1990. How can a licensed professional engineer NOT know how to complete a statement of special inspections? How can they NOT know it's a required submittal?

 

[steveray]

#becausenoonecaresaboutdoingagoodjobanymore

 

[Mr. Inspector]

I have architects that still use pencils that don't know the first thing about when special inspectors are required.

 

[tmurray]

Update: The engineer-of-record has now made four attempts at filling out the SSI, and he still can't manage to get a single page correct. On the last try he enlisted the help of the engineer from the local (next town) testing lab they intend to use, and together they still managed to mess it up.

Just went through the SSI for another project, by another out-of-state design team, and they messed up every page, as well.

And I just opened up a new application for a new commercial building -- and there's no SSI.

I'm baffled. This has been a requirement in the codes since 1990. How can a licensed professional engineer NOT know how to complete a statement of special inspections? How can they NOT know it's a required submittal?

Because people see something being done by an engineer/architect and simply move on. The reality is that others accept the paperwork you are finding issues with, but you know this.

We have a similar thing here and one time I had an architect cross off Part 5 of the National Building Code of Canada under their responsibilities. Part 5 is environmental separation. It deals with insulation, vapour barrier, air barrier, rain penetration, etc. So, I called the owner and told them that they needed to hire another architect to do this since their architect said that they aren't doing it. Later I got a revised form and a phone call from the architect where he said "well, obviously I designed the building to be outside!" My response "Oh, well why did you cross out Part 5 then?" He gave me some BS answer about other jurisdictions not really enforcing Part 5.

 

[Yankee Chronicler]

Later I got a revised form and a phone call from the architect where he said "well, obviously I designed the building to be outside!" My response "Oh, well why did you cross out Part 5 then?" He gave me some BS answer about other jurisdictions not really enforcing Part 5.

We hear that a lot -- and I heard it a lot at my former position (in another town), too. "They don't make me do this is [_____]!"

Not my problem. I gave you the code section. We (me, my boss, and his boss -- the Director of Planning) recently sat down with a designer (an unlicensed individual practicing architecture illegally and getting a friend to stamp his drawings) who was complaining because I keep rejecting his plans. He sat across the table from us and said, "There's nothing you wrote in this plan review that's incorrect, but I've been doing this for 20 years and nobody has ever questioned me before. I demand that you issue us a permit. You just wrote that letter to make me look like an a...hole."

It was all I could do to not respond, "No, you're doing a good job of that by yourself."

 

[Inspector Gadget]

We have a project for which we have approved the plans, but we can't issue the permit because the engineer (from another state) can't seem to figure out how to complete a statement of special inspections. Last Friday I had a long telephone discussion with the contractor, who is also the applicant, explaining what the issues are. About an hour later, I received a phone call from the owner of named testing laboratory asking why we had rejected them as the special inspections agency. I told him we hadn't rejected his company, we had rejected the SSI because it wasn't properly completed and didn't include information that is specifically required by IBC.

So ... I only had a vague clue what a "statement of special inspections" was 10 minutes ago. Then I did some google-based research. I think I know what they are now. This ain't rocket surgery: seems roughly analagous to our "letters of commitment."

Because people see something being done by an engineer/architect and simply move on. The reality is that others accept the paperwork you are finding issues with, but you know this.

There is that. But I am also increasingly saddened by the lack of competence expressed by some professionals. Let me put it like this: I just received a set of plans for a fairly notable capital project. On the initial review I noticed among other things, a list of what kinds of fire stops will be used, for what penetrations, and the designer had actually included the ULC listing number for each and every single one. This is one of the first times this has been presented as part of the original submittal package.

"Yeah, we'll handle that later" ain't good design.

He gave me some BS answer about other jurisdictions not really enforcing Part 5.

?? Like what, Sussex doesn't need insulation? Grand Bay don't need no stinking shingles?

We hear that a lot -- and I heard it a lot at my former position (in another town), too. "They don't make me do this is [_____]!"

Ah, my favourite. "Nobody should 'make' you do this, you have to by Code. If you haven't, that's your fault, not the inspector's."

 

[redeyedfly]

"Yeah, we'll handle that later" ain't good design.

When it comes to firestopping that is good design. Architects and engineers are not experts in firestopping, they delegate that design to specialists. Should they also submit all the testing for the elevators, or do we trust Otis to design them?


Firestopping should be a deferred submittal, AHJs who require the listed penetration firestopping on the permit drawings don't understand how it works.

 

[Beniah Naylor]

they delegate that design to specialists.

I wish... around here they just leave it for the general contractor to figure it out. That has worked out well before, but not often enough to inspire confidence.

 

[tmurray]

?? Like what, Sussex doesn't need insulation? Grand Bay don't need no stinking shingles?

To be fair, there were a couple of municipalities who didn't adopt Part 5 back in the dark ages before the BCAA.

 

[tmurray]

When it comes to firestopping that is good design. Architects and engineers are not experts in firestopping, they delegate that design to specialists. Should they also submit all the testing for the elevators, or do we trust Otis to design them?


Firestopping should be a deferred submittal, AHJs who require the listed penetration firestopping on the permit drawings don't understand how it works.

Why do you feel that?

The only issues I can think of would be the orifice size and annular space, but orifice size could be controlled through specs.

 

[Inspector Gadget]

When it comes to firestopping that is good design. Architects and engineers are not experts in firestopping, they delegate that design to specialists. Should they also submit all the testing for the elevators, or do we trust Otis to design them?


Firestopping should be a deferred submittal, AHJs who require the listed penetration firestopping on the permit drawings don't understand how it works.

Professionals design elevators. Professionals design firestops. I don't accept plans for elevators that have "we'll figure that out in the field." Why would I do the same for fire stops?

Moreover, who installs elevators? Usually, it's trained professionals. Who installs firestops? Usually, it's Chuck with a truck who went to the hardware store to get some "hell, this says it's fire-rated spray foam, I'll use this."

I've taken fire stop installation training. I know how it works. Every time I have had a foulup on a firestop, it's been because I didn't press for a system prior to application.

To be fair, there were a couple of municipalities who didn't adopt Part 5 back in the dark ages before the BCAA.

Were they even allowed to do that?

 

[redeyedfly]

Professionals design elevators. Professionals design firestops. I don't accept plans for elevators that have "we'll figure that out in the field." Why would I do the same for fire stops?

Moreover, who installs elevators? Usually, it's trained professionals. Who installs firestops? Usually, it's Chuck with a truck who went to the hardware store to get some "hell, this says it's fire-rated spray foam, I'll use this."

I've taken fire stop installation training. I know how it works. Every time I have had a foulup on a firestop, it's been because I didn't press for a system prior to application.

Deferred submittal. You're not "figuring it out in the field". It's a submittal prior to installing them in the field. Note that elevators are also a deferred submittal typically.

You may be in a small town and not accustomed to large scale projects. Hilti, 3M or some other manufacturer usually prepares the submittal, not the hardware store.

 

[tmurray]

Were they even allowed to do that?

It's arguable. The code was supposed to be adopted by reference, so the common legal view is that you have to adopt it all. They could develop their own codes at the time, but they would have had to actually read the code out loud word for word 4 times during council to enact it (LGA later allowed municipalities to read summaries, but I'm not even sure how you summarize a document like the building code).

Even if they had the legal authority, there was no due diligence done to investigate the interactions between this part of the code and others to evaluate negative impacts, so lots of liability there. Also, in speaking with the department mangers on why they didn't adopt Part 5, they both said "I don't know, it's just something we do." Whole process screamed liability exposure.

 

[tmurray]

Deferred submittal. You're not "figuring it out in the field". It's a submittal prior to installing them in the field. Note that elevators are also a deferred submittal typically.

You may be in a small town and not accustomed to large scale projects. Hilti, 3M or some other manufacturer usually prepares the submittal, not the hardware store.

The recommendation from the Fire Stopping Council is to have fire stopping submittals at permit review.

The issues related to selecting an approved fire stopping system are the same for any other product or system. If something in the design changes or trades do a poor job of installation, some of the fire stopping will need to change. Just like anything else that needs to change during construction.

 

[Inspector Gadget]

Deferred submittal. You're not "figuring it out in the field". It's a submittal prior to installing them in the field. Note that elevators are also a deferred submittal typically.

You may be in a small town and not accustomed to large scale projects. Hilti, 3M or some other manufacturer usually prepares the submittal, not the hardware store.

Want to make sure we're using the same language here. You're using "submittal" in the way I'm using system, but a submittal is merely a brand-created, product specific system.

As I see it, manufacturers don't prepare the submittal: they create, test and curate a library of them. It's still up to some bloke to tell me what system/submittal they will be using.

The size of the region I work in is irrelevant to appropriate practice. The designer of a project shouldn't be at all caught off guard when the plumber puts a 4" combustible pipe through a one-hour separation. The designer should know this and create a breakout that specifies a system/submittal.

Most designers don't. And frankly, I have found more than a few engineers are utterly dumbfounded at the idea of dealing with firestops/dampers at the design phase.

I'm presuming that you verify fire separation construction at the plans review stage. I say that as a bit of a rhetorical exercise because fire separations are also systems, that must be treated as such....

 

[Yankee Chronicler]

The size of the region I work in is irrelevant to appropriate practice. The designer of a project shouldn't be at all caught off guard when the plumber puts a 4" combustible pipe through a one-hour separation. The designer should know this and create a breakout that specifies a system/submittal.

Agreed. 110%.

Most designers don't. And frankly, I have found more than a few engineers are utterly dumbfounded at the idea of dealing with firestops/dampers at the design phase.

It's arguable that the firestopping isn't the engineer's responsibility, but the architect's. Then there's the debate over whether each trade (M/E/P) should be allowed to do their own firestopping -- which may result in one firestopping system for a copper or plastic water pipe going through a rated wall, and a metal or plastic electrical conduit of the same diameter a foot away using a different firestopping system, installed by a different Chuck with a Truck -- or if the G.C. should hire one firestopping subcontractor to do everything, so there's single source responsibility.

 

[Yikes]

We do hundreds of Type V-1 hour wood framed multifamily dwellings every year, and occasionally the buildings also have 2 hour shaft walls.
All the necessary firestopping, fire blocking, and draft stopping details can fit on one sheet of standard details, with firestopping usually taken from the UL directory. This is not rocket science and does not need to be deferred.

Elevators can be deferred, but we typically get the reaction forces from the manufacturer to use at initial submittal of the structural framing plans, and we also have a standard detail for maintaining the shaft rating at the guiderail attachment points in the shaft framing.

 

[Yikes]

We do hundreds of Type V-1 hour wood framed multifamily dwellings every year, and occasionally the buildings also have 2 hour shaft walls.
All the necessary firestopping, fire blocking, and draft stopping details can fit on one sheet of standard details, with firestopping usually taken from the UL directory. This is not rocket science and does not need to be deferred.

Elevators can be deferred, but we typically get the reaction forces from the manufacturer to use at initial submittal of the structural framing plans, and we also have a standard detail for maintaining the shaft rating at the guiderail attachment points in the shaft framing.

In the LA County area, we have a "Structural observation" form for periodic / milestone inspections by the EOR, but that is different from special/continuous inspection".

 

[redeyedfly]

The recommendation from the Fire Stopping Council is to have fire stopping submittals at permit review.

The issues related to selecting an approved fire stopping system are the same for any other product or system. If something in the design changes or trades do a poor job of installation, some of the fire stopping will need to change. Just like anything else that needs to change during construction.

No. For example, go look at plumbing sheets, tell me what type of pipe goes where. You won't find it because the documents allow the plumber to choose. So how can the architect specify the listed firestopping systems if they don't even know if it's plastic or cast pipe penetrating the assembly?

 

[redeyedfly]

Want to make sure we're using the same language here. You're using "submittal" in the way I'm using system, but a submittal is merely a brand-created, product specific system.

As I see it, manufacturers don't prepare the submittal: they create, test and curate a library of them. It's still up to some bloke to tell me what system/submittal they will be using.

The size of the region I work in is irrelevant to appropriate practice. The designer of a project shouldn't be at all caught off guard when the plumber puts a 4" combustible pipe through a one-hour separation. The designer should know this and create a breakout that specifies a system/submittal.

Most designers don't. And frankly, I have found more than a few engineers are utterly dumbfounded at the idea of dealing with firestops/dampers at the design phase.

I'm presuming that you verify fire separation construction at the plans review stage. I say that as a bit of a rhetorical exercise because fire separations are also systems, that must be treated as such....

We're not using the same language. A firestopping submittal is often the size of a phonebook and includes all systems used in the project. Often they are one brand per trade, sometimes they are for the entire project if a separate firestopping sub is used. Almost always, a firestopping submittal is prepared by the manufacturer for each specific project.
Again, it's not the AOR's scope to design the firestopping systems. The design is delegated to the installer. Does the structural engineer design the wood trusses? The AOR specifies the requirements of the firestopping per the code but does not design each penetration with a listed system.

Fire separations are different, they are definitely in the AOR's scope.

It's almost like the inspectors have no idea how buildings actually get built.