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OCR for page 23
5
COMMITTEE FINDINGS' CONCLUSIONS AND RECOMMENDATIONS
The Committee on Assessing the Impact on Federal Agencies of the Use
of Building Codes as Design Criteria find that the primary issue faced
here is not whether agencies should use the codes, but rather which codes
and how quickly. Current federal law requires agencies' construction to
conform to the provisions of model codes, and policy encourages adoption
of the standards contained in these model codes. The committee believes
that federal agencies have an opportunity and responsibility to take a
leadership role in reducing the unproductive plethora of building code
regulations in the United States. Nevertheless, the committee antici-
pates that federal agencies undertaking to assume this leadership will
have valid concerns.
Codes and Design Criteria
Participants in the discussion of federal agency use of building
codes must keep in mind that codes cover only a portion of the many
design criteria that any owner will impose to assure that a building's
performance meets requirements. Federal agencies will always have
extensive design criteria, and some of these criteria may represent
agency requirements for performance that exceeds the minimum requirements
set in applicable building codes.
Both local building codes and the nationally recognized model codes
have a limited scope compared to owner's design criteria. While any
inspection of agency plans and construction that occurs under the
provisions of the Public Building Amendments Act of 1988 may be helpful
to the agency in pointing out local conditions that have been poorly
accommodated in a building's design, the agency's costs of assuring
compliance with its own design criteria may not be significantly reduced.
(However, local inspection may serve to document compliance with model
codes, in those jurisdictions that have adopted a current model code as
local regulation.) The committee anticipates that the absence of funding
for local inspections may reduce the frequency with which such
inspections occur.
23
OCR for page 24
Compliance to the Maximum Extent Feasible
The committee discussed the issues of determining in an administra-
tively efficient way -- under the Public Building Amendments of 1988 --
whether federal agency projects are "to the maximum extent feasible" in
compliance with a nationally recognized model building code. The
committee is concerned that agencies have not been given funding for
activities called for under the new law or older OMB Circular No. A-ll9.
"Feasible" in one sense means simply capable of being done. There
is no question that each of the federal agencies could review its design
criteria and the several national model codes to determine that their
provisions are compatible, and either make changes to reach compliance or
justify differences.16
In the broader sense, however, "feasible" means reasonable, and the
committee questions whether the costs of requiring such a review by all
agencies are warranted by the benefits that might be gained. First,
there must be a determination of which of the many documents purporting
to be model codes should be recognized by the federal agencies. The
committee proposes the three principal model codes -- Basic or National
Building Code, Standard Building Code, and Uniform Building Code -- are
an adequate set for the purposes of the law. It would be the responsi-
bility of the model codes organizations to incorporate directly or by
reference those plumbing, electrical, fire safety, or other codes that
are not now part of these three principal model codes.
Then, based upon discussions with agency and codes organization
representatives, the committee proposes that either of two principal
courses of action might be taken, at an agency's discretion, to determine
compliance:
1. An agency could choose one of the three principal model codes
and make a complete review of its agency's criteria in comparison to that
code document. Differences would be noted and justified or eliminated by
changing the criteria. The committee anticipates that requirements
included in owner's criteria that exceed those contained in the selected
model code would generally be justifiable in terms of the agency's
mission requirements.
2. An agency could make a project-by-project selection of the one
model code prevalent in the area or that best suits the conditions of the
particular project. The agency would instruct the agency's project
architect/engineer (A&E) firm to use the model code and to note and
report to the agency all points of difference between the agency's design
criteria and the selected model code. The agency could then justify any
differences between its design criteria and the model code for the
project under concern or simply instruct the A&E firm to design to meet
i6Such a review might be accomplished without revision of an
agency's criteria to purge repetition of items covered adequately in the
model codes.
24
OCR for page 25
the model code requirements.17 In those jurisdictions where local
is based upon a current model code, the compliance review could be
carried out by local building code officials.
Under both options, the agency or its A&E will be faced with the
task of documenting all points of overlap between the model codes and
agency design criteria. The committee observes that for some projects
and some agencies this overlap may be substantial. The committee
believes that agency costs will in the long term be lower if agencies
simply follow the course of DOE: eliminate from their design criteria
those requirements that are adequately covered by model cadets) and cite
the model coders) as requirements.
Limits of Model Code Applicability
The major model codes incorporate standards that generally are
supported by substantial background research and have received thorough
review by highly competent professionals. The committee recognizes that
these model codes are therefore valuable examples that may be modified to
reflect local conditions and adopted by local jurisdictions, which may
lack the professional and financial resources to develop their own
building codes without such assistance. The committee recognizes as well
that the public interest is served when increased use of model codes
fosters reduction of unnecessary variation in building code requirements
in communities throughout the United States.
However, the committee notes that the performance required of many
government buildings is particular to the federal agency's mission and
very different from what is expected of typical buildings covered by
local codes.l8 It would be certainly inefficient for model codes to be
prepared to address the requirements of unusual building types and
environmental situations. There are then limits to how much of the
federal construction program can be covered by model codes.
On the other hand, facilities such as warehouses, office buildings,
dormitories, and hospitals do frequently have many similar character-
istics -- regardless of the government agency or private owner for which
they are built -- and the committee feels federal agencies could more
effectively coordinate their development of design and construction
criteria. Use of model codes is one means for achieving greater
uniformity in design criteria.
17An important justification might be, for example, the desire of an
agency to adopt an innovative material or process for which the code has
no appropriate guidance.
18Specialized defense and scientific research facilities, for
example, while not necessarily unique to government owners, are
infrequently encountered by local building code officials.
25
OCR for page 26
Agencies Should Be More Involved
in Model Code Development
The committee observes that the agencies have had limited involve-
ment in the activities of the model code bodies, in part because of lack
of funding for such involvement. Government agency personnel often have
experience in large and unusual projects that push the limits of
technical knowledge. These personnel also may have experience in many
areas of the United States. In both cases, their experience can be a
valuable addition to the process of building professional consensus that
underlies code development. Regardless of whether individual agencies in
the short run increase their use of model codes, long term benefits for
the nation's buildings may be realized by encouraging federal agencies to
take a more active role in model code development. The committee calls
on the agencies to encourage their professional staff to comply with the
spirit as well as the letter of the Public Buildings Amendments of 1988
and OMB Circular No. A-ll9.
The committee recommends that all federal agencies with construc-
tion programs should report periodically on their progress in participa-
tion in model codes development and their adoption of model codes as a
part of their design criteria. Agencies should be called upon to report
also their recommendations for changes needed to help the model codes to
serve better the public interest. These topics could appropriately be
included in annual reports agencies make to the Secretary of Commerce
under OMB Circular No. A-ll9 and in the triennial report to the Director
of the OMB of the Interagency Committee on Standards Policy.
The committee recognizes that some agencies will incur significant
costs in complying fully with the spirit of current law and policy, and
that all agencies will have to make a commitment of professional staff
time for participation in codes organizations. These commitments will
enhance agency staff opportunities for professional growth bringing
agency leadership into the codes development process. The committee
urges administration and Congress to look favorably upon ant hi
allocations in support of such activity.
_, , ~ _ _, _ _ ~ _ _
Agencies Should Periodically Review Their Justification
for Design Criteria Above Minimum Requirements
The committee observes that Federal agencies' design criteria
frequently exceed the minimum requirements adopted in building codes.
These criteria assure higher building performance, and, in turn, that
federal buildings would meet local code requirements if they became
subject to local code. One may argue that the resulting federal
buildings may be at least as safe and healthful as others in a given
community.
The committee notes that the higher criteria are generally
justified by specific performance requirements. However, sometimes
higher criteria may be a result of transferring criteria appropriate to
one region or application to another where a different standard would be
appropriate. Higher performance in federal buildings may be warranted by
the agency's mission, by the desire to minimize overall life cycle costs,
26
OCR for page 27
or by the government's general responsibility to maintain high standards
in public buildings. The committee nevertheless recommends that agencies
should regularly re-examine their design criteria to assure that the
requirements they contain are yielding benefits commensurate with any
increases in building costs they may bring about. Higher criteria should
not be imposed in all regions or all building situations simply for the
sake of maintaining uniformity. The model codes, intended to be
applicable in all regions, are designed to avoid requirements that are
unnecessarily high. The committee suggests that the model codes may be
useful baselines against which agencies can measure the benefits and
costs of their higher owner's criteria.
Federal Agencies Should Use Model Building Codes
The committee appreciates the concerns expressed by local
communities regarding federal exemption from local building codes and
from zoning or other regulations intended to give a local community some
control over their built environment. The committee notes with dismay
those cases in which federal agencies have failed to consult with local
authorities and to exercise sensitivity to local design practices and
preferences. However, the committee judges that these cases are
exceptional, and that there would be little or no national benefit to by
making federal agencies subject to local codes.
The committee applauds the efforts of model code organizations to
reduce the unproductive diversity of standards and procedures found in
local building codes. (Indeed, some of the committee's members expressed
the wish that there were only one national model code.) Nevertheless,
with the exception of the points made in the preceding paragraphs, the
committee judges that imposition of any particular one of the model codes
on all federal agencies would be inappropriate and unproductive. This
judgment in no way diminishes the committee's opinion that agencies
should adopt by reference the appropriate portions of model codes that
duplicate provisions in their current agency design criteria. In this
sense, federal agencies should not just construct their facilities to
comply with model codes: They should actually use the model codes as
design criteria in those areas within the purview of the model codes and
where agency needs do not warrant higher performance.
Agencies Should Foster Uniformity
in Building Regulation
The committee urges the federal government to take an active role in
fostering greater uniformity in building regulation in the United States.
The committee proposes that the model codes organizations and all
agencies with responsibility for construction and alteration of buildings
should actively participate in the development of a unified computerized
data base (such as the NIBS COB described in Chapter 2) that will make
accessible the various standards and procedures contained in the model
codes and agency design criteria, and again urges Congress to be
supportive of such activities.
27
OCR for page 28
Once a complete and unified database is developed, the procedures of
expert consensus that have served the industry in the past can be applied
to review of the model codes and widely used design criteria. The review
would seek first to establish a parallel presentation of requirements and
the measures or procedures used to determine if requirements have been
met. Direct comparison of the requirements themselves will then be
possible within a context of long term building life cycle performance.
Substantive differences among requirements or measures of compliance can
be discussed and evaluated in an open forum that will make a long term
contribution to improved efficiency and appropriate uniformity in
building design in the United States.
28
Representative terms from entire chapter:
design criteria
