# Pennsylvania Continues to Blindly Make Rules without Context



## jar546 (Nov 8, 2021)

First I read this:



> *Electronic Signatures and Seals During Covid-19 Pandemic*
> Due to the current coronavirus pandemic, social distancing guidance from the Federal and State government and remote work is making it difficult for Architects to issue final or complete documents to clients, where Architects might interpret existing regulations to require a physical stamp and signature. The Department of State is providing this notice to clarify that all licensees of the State Architects Licensure Board may utilize electronic/digital signatures and seals until such time that Governor Wolf determines that the statewide emergency proclamation may be lifted. Electronic/digital signatures and seals affixed during this statewide emergency shall be recognized as originals notwithstanding the end of the current statewide emergency.


Let's first address this issue that PA does not define what an electronic or digital signature actually is and the rest falls apart from there.  Yes, something had to be done but rather than fix the problem, they create more with this bandaid.  Another example of rules being made without actually knowing the business.

A digital signature from Adobe helps no one and does not confirm who actually signed the plans.  Unless this comes from a third party digital verifier that imprints the PDF, a digital signature is useless but not as useless as an electronic signature.


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## Inspector Gift (Nov 10, 2021)

That sounds somewhat similar to Oregon's Administrative Rules for Engineers, which requires either wet-signed stamp or DIGITAL SIGNATURE. 

- "The Digital Signature must be unique to the registrant using it,

- "The Digital Signature must be independently verifiable by a Certificate Authority (3rd Party),

- "The Digital Signature must be under the sole control of

- "The Digital Signature must be attached to the document is such a manner that the digital signature is invalidated if any data in the document is changed.  And

- "For final electronic files, the registrant affixes a computer-generated image of a stamp that bears the phrase "digitally signed" in lieu of and in the location designated for a hand-written signature on that page.  The computer-generated image of the stamp must be of a stamp as described in OAR 820-025-0001(1) and (2), including the size prescribe in OAR 820-025-0001 when the page is printed to full size.

It is frustrating because *more than 90% of the "Digitally Signed" stamps we receive in our department do NOT comply *with all of Oregon's requirements for Digital Signatures. (See OAR 820-025-0005, OAR 820-025-0010, OAR 820-025-0020 and OAR 820-025-0025 for additional information). I am told that we are the only department in Oregon that insists on the digital signature.  (LOL, where have I heard that before?!!)


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## jar546 (Nov 10, 2021)

Inspector Gift said:


> That sounds somewhat similar to Oregon's Administrative Rules for Engineers, which requires either wet-signed stamp or DIGITAL SIGNATURE.
> 
> - "The Digital Signature must be unique to the registrant using it,
> 
> ...


In Florida we have almost the exact same language but enforcement has been a bear.  Our non-compliance rate is much worse with architects than it is with engineers.  We have about a 70% compliance rate with engineers and about a 20% compliance rate with architects.  Some still think they can use Adobe to place an electronic signature which is not correct.  We require a digital 3rd party verified signature and Adobe does not cut it.


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## redeyedfly (Nov 11, 2021)

Why does it matter?  Is there really a problem with forged DP signatures on permit documents?


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## bill1952 (Nov 11, 2021)

redeyedfly said:


> Why does it matter?  Is there really a problem with forged DP signatures on permit documents?


Thanks. I wondered same thing.


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## Rick18071 (Nov 11, 2021)

PA screwed up the 2018 IRC that will start next year. Many changes. They took some things out of the 2018 and added sections from the 2009, 2015 and the 2021 and changed other sections without making a Pennsylvania Residential Code book. Just took a webinar on it. I guess I need to cut the changes out and paste them into the 2018 IRC. I hope the designers do the same but they probably won't know about it.

Some funny things too. They changed the requirement for window U factors only in climate zone 3. There is no climate zone 3 in PA! This shows that no research (or any actual thinking) was made for the changes and they only made thinks up.


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## Paul Sweet (Nov 12, 2021)

Forged DP signatures are rare but they do happen sometimes, and it's easy to do with a pdf.  I know an architect in Virginia who had a disagreement with a client. The client took the preliminary drawings and had a drafting service draw the working drawings from them.  They scanned the signed seal from another project and pasted it into the pdfs they submitted for a permit.


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## bill1952 (Nov 12, 2021)

Paul Sweet said:


> Forged DP signatures are rare but they do happen sometimes, and it's easy to do with a pdf.  I know an architect in Virginia who had a disagreement with a client. The client took the preliminary drawings and had a drafting service draw the working drawings from them.  They scanned the signed seal from another project and pasted it into the pdfs they submitted for a permit.


Was the building permitted and constructed?


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## Msradell (Nov 12, 2021)

Paul Sweet said:


> Forged DP signatures are rare but they do happen sometimes, and it's easy to do with a pdf.  I know an architect in Virginia who had a disagreement with a client. The client took the preliminary drawings and had a drafting service draw the working drawings from them.  They scanned the signed seal from another project and pasted it into the pdfs they submitted for a permit.


If he or anyone else ever gets caught doing this or anything similar. Being a whole lot of explaining to the authorities required!


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## Mark K (Nov 13, 2021)

A scan of a signed seal is not a digital signature.  With a digital signature you cannot alter the file without corrupting the file.

The scanned seal and signature may be an electronic signature but its validity is dependant on there being supplementary information indicating an intent to sign the documents.


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## mtlogcabin (Nov 13, 2021)

It does not matter if the drawings are stamped, signed and sealed or a digital signature. We (the building department) are not the ones who police the validity of a stamp, seal or signature on a set of drawings. A set of plans can have any number of Architects and/or Engineers who have designed and  signed/sealed various portions of the buildings design.


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## jar546 (Nov 13, 2021)

Mark K said:


> A scan of a signed seal is not a digital signature.  With a digital signature you cannot alter the file without corrupting the file.
> 
> The scanned seal and signature may be an electronic signature but its validity is dependant on there being supplementary information indicating an intent to sign the documents.


You are correct.  The plans are not electronically signed, they are digitally signed and if altered, the signature is voided.


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## jar546 (Nov 13, 2021)

mtlogcabin said:


> It does not matter if the drawings are stamped, signed and sealed or a digital signature. We (the building department) are not the ones who police the validity of a stamp, seal or signature on a set of drawings. A set of plans can have any number of Architects and/or Engineers who have designed and  signed/sealed various portions of the buildings design.


In Florida, we are required to verify the digital signatures.  I just got back from a 2-day conference on this very subject.


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## mtlogcabin (Nov 15, 2021)

Did you check out BlueBeam for creating and verifying signatures?









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## jar546 (Nov 15, 2021)

mtlogcabin said:


> Did you check out BlueBeam for creating and verifying signatures?
> 
> 
> 
> ...


We do all plan review in blubeam


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## mtlogcabin (Nov 15, 2021)

I know you do I was just curious if you new about that feature from bluebeam?


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## Pcinspector1 (Nov 15, 2021)

mtlogcabin said:


> It does not matter if the drawings are stamped, signed and sealed or a digital signature. We (the building department) are not the ones who police the validity of a stamp, seal or signature on a set of drawings. A set of plans can have any number of Architects and/or Engineers who have designed and signed/sealed various portions of the buildings design.


Our state requires a person that practices architecture to be licensed and I check and verify that they are current through a website. I have not seen any violation except an architect that let his license lapse. Other than that I don't chase them down, I let the project applicant do the investigation.


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## jar546 (Nov 15, 2021)

mtlogcabin said:


> I know you do I was just curious if you new about that feature from bluebeam?


Oh absolutely.  It is the method we use for verifying digital signatures.


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## rktect 1 (Nov 15, 2021)

Man, I am not plan checking digital signatures or stamps.  That will cost you extra.


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## steveray (Nov 15, 2021)

We make a small effort but have no responsibility/ liability to....


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## jar546 (Nov 15, 2021)

rktect 1 said:


> Man, I am not plan checking digital signatures or stamps.  That will cost you extra.


Do you accept paper drawings without a wet-stamp?


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## rktect 1 (Nov 15, 2021)

jar546 said:


> Do you accept paper drawings without a wet-stamp?


We pretty much accept anything.


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## jar546 (Nov 15, 2021)

rktect 1 said:


> We pretty much accept anything.


So if it comes from an architect or engineer on paper and is missing the wet-seal, even for commercial work, you just accept it?


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## Rick18071 (Nov 16, 2021)

We accept embossed, copied, faxed, and emailed seals. I don't know of anything in our code that describes what a seal should be or look like.


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## tmurray (Nov 16, 2021)

Our provincial architects and engineer's associations requires a digital 3rd party signature for digital plans. Their membership dues entitle them to the service with a specific 3rd party company located here in Canada. This company provided our provincial building official's association a free webinar on how to check the legitimacy of their digital stamps and offered free technical support to any building officials. 

All in all, it was rolled out quite well.


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## rktect 1 (Nov 16, 2021)

steveray said:


> So if it comes from an architect or engineer on paper and is missing the wet-seal, even for commercial work, you just accept it?


If It is signed and sealed (wet or dry) then yes.


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## rktect 1 (Nov 16, 2021)

I just read the Illinois Architects requirements and don't see anything that states this seal must be wet, just reproducible.


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## steveray (Nov 16, 2021)

tmurray said:


> Our provincial architects and engineer's associations requires a digital 3rd party signature for digital plans. Their membership dues entitle them to the service with a specific 3rd party company located here in Canada. This company provided our provincial building official's association a free webinar on how to check the legitimacy of their digital stamps and offered free technical support to any building officials.
> 
> All in all, it was rolled out quite well.


As soon as global warming ramps up I am soooo moving to Canada.....They just seem to make sense...


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## steveray (Nov 16, 2021)

Post 26 misquoted me...That was JAR...weird.


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## Sifu (Nov 16, 2021)

redeyedfly said:


> Why does it matter?  Is there really a problem with forged DP signatures on permit documents?


Got one yesterday.  Not the first time.


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## bill1952 (Nov 16, 2021)

Sifu said:


> Got one yesterday.  Not the first time.


And you immediately recognized it was forged? If so, seems like you're doing a good job and that the system works


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## jar546 (Nov 16, 2021)

steveray said:


> Post 26 misquoted me...That was JAR...weird.


I think you can edit a quote


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## Sifu (Nov 16, 2021)

There is background.  I have been dealing with this situation for a while and suspected the DP would not have done what I saw on the plans.  When I see something like this suspect I usually call the DP to have a discussion, this time the CBO did it and confirmed the plans were not prepared by the DP.  The previous seals had been altered, and the most recent had been removed.  It looks like the plans were altered and the seal removed.  Both are problems between the DP and the person who did it.  I do not take extraordinary measure to confirm seals and signatures unless I have a compelling reason.  Our AES rules are vague, at best.  It is not my intention or desire to enforce or cite any of those rules, only to verify the documents are prepared by a registered design professional.  It is under that umbrella that I will try to verify they have been prepared by a duly registered design professional.  I start with the state database to make sure the licensee is valid.  I don't feel the need to check that very often (only when suspect).  In this case the format of the signature/date was different than every other time they submitted, and the plans were also suspect.

I have been patiently waiting for some consistent and verifiable methods for electronic/digital seals and signatures.  I stopped holding my breath.  Received one today with no signature or date as required by the AES rules, but there was a blank digital signature line that *I could apply my own digital signature to*.  I also see the majority of digitally applied seals that I can freely copy, delete, paste and alter if I so desired.  This is a problem that needs to be addressed by the DP's and their licensure board.  They are releasing documents that anyone can pirate or alter.  VERY rarely do I encounter a sealed document that has security of any kind.  When I am done with a plan I secure it as best I can (I protect my stamps and comments, and theirs as well), but the opportunity for misuse is real, and I suspect it happens more often than we think.  Come to think of it, I encountered a revision on one about a week ago.  Same deal, the proposal was suspect.  I called the DP, who I work with all the time.  He had no idea about it.  They (contractor) had generated a new detail on a plan page that had extra space, and submitted it as if the DP had done it.


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## jar546 (Nov 16, 2021)

*61G15-23.005 Procedures for Electronically Signing and Sealing Electronically Transmitted Plans, Specifications, Reports or Other Documents.*

(1) Engineering plans, specifications, reports or other documents which must be signed, dated and sealed in accordance with the provisions of Section 471.025, F.S., and Rule 61G15-23.001, F.A.C. may be signed electronically as provided herein by the professional engineer in responsible charge. As used herein, the term “electronic signature” shall have the meanings ascribed to them in Sections 668.003(2), (3) and (4), F.S.

(2) A professional engineer utilizing an electronic signature to electronically sign and seal engineering plans, specifications, reports or other documents using the Florida Department of Transportation (FDOT) Professionals’ Electronic Data Delivery System (PEDDS) software shall:

(a) Create a “signature” file that contains the licensee’s given name, the licensee’s license number, a brief overall description of the engineering documents to be signed and sealed, a list of the electronic files to be signed and sealed, and the SHA-1 authentication code or Secure Hash Standard for each electronic file to be signed and sealed. The SHA-1 authentication code is described in Federal Information Processing Standard Publication 180-4 “Secure Hash Standard,” August 2015, which is hereby adopted and incorporated by reference by the Board and can be obtained from the Internet Website: http://www.flrules.org/Gateway/reference.asp?No=Ref-05976.

(b) Create a “signature” report that contains the licensee’s given name, the licensee’s license number, a brief overall description of the engineering documents to be signed and sealed and the SHA-1 authentication code of the signature file;

(c) Print and manually sign, date and seal the signature report in compliance with Rule 61G15-23.003, F.A.C.;

(d) Transmit the signed, dated and sealed signature report to the receiving party along with the signed, dated and sealed signature file, either by hardcopy or electronic scan, if scanned and sent electronically. The hardcopy signed and sealed report shall be retained by the licensee in accordance with Rule 61G15-30.009; and,

(e) The signature file is considered to be signed and sealed if the signature file’s authentication code matches the authentication code on the manually signed, dated and sealed signature report. Each electronic file listed within the signed and sealed signature file is considered to be signed and sealed if the listed SHA-1 authentication code in the signature file matches the electronic file’s SHA-1 authentication code.

(3) A professional engineer utilizing an electronic signature to electronically sign and seal engineering plans, specifications, reports or other documents other than through the FDOT PEDDS system shall:

(a) Create a static electronic version, such as PDF, of the engineering document(s) that is to be signed and sealed;

(b) Compute an SHA-1 authentication code for each electronic engineering document;

(c) Create a printable “signature report” that contains the licensee’s given name, the licensee’s license number, and a list of the electronic files to be signed and sealed that includes a brief description of each engineering document and the SHA-1 authentication code of each engineering document;

(d) Print and manually sign, date and seal the “signature report” in compliance with Rule 61G15-23.003, F.A.C.; and,

(e) Transmit the signed, dated and sealed “signature report” to the receiving party along with each electronically signed, dated and sealed engineering document either by hardcopy or electronic scan, if scanned and sent electronically. The hardcopy signed and sealed report shall be retained by the licensee in accordance with Rule 61G15-30.009, F.A.C. Each engineering document is considered to be electronically signed and sealed if the document’s SHA-1 authentication code matches the SHA-1 authentication code on the physically signed, dated and sealed “signature report.”

(4) The affixing of an electronic signature to engineering plans, specifications, reports or other documents as provided herein shall constitute the signing and sealing of such items.

(a) A digitally created seal as set forth in Rule 61G15-23.002, F.A.C. may be placed where it would appear if the item were being physically signed, dated and sealed.

(b) The date that the electronic signature is to be placed into the document must appear on the document in accordance with subsection 61G15-23.001(5), F.A.C. and where it would appear if the item were being physically signed, dated and sealed.

(c) A scanned, facsimile, digitally created or copied image of the licensee’s signature shall not be used on electronically signed and sealed engineering plans, specifications, reports or other documents.

(d) The engineering plans, specifications, reports or other documents being electronically signed and sealed shall include text to indicate the following and place it where an original signature would appear if the item were being physically signed, dated and sealed:

1. The same information required by subsection 61G15-23.002(2), F.A.C. if a digitally created seal is not used,

2. The item has been electronically signed and sealed using a SHA-1 authentication codes; and,

3. Printed copies of the document are not considered signed and sealed and all SHA-1 authentication code must be verified on any electronic copies.

(e) Formatting of seals and text similar to that depicted below may be used.

1. When a digitally created seal is used:




seal hereThis item has been electronically signed and sealed by C. S. Hammatt, PE. On [DATE] using a _SHA-1 _authentication code.

Printed copies of this document are not considered signed and sealed and the _SHA-1 _authentication code must be verified on any electronic copies.


2. When a digitally created seal is not used:





C. S. Hammatt, State of Florida, Professional Engineer, License No. X

This item has been electronically signed and sealed by C. S. Hammatt, PE. On [DATE] using a _SHA-1 _authentication code.

Printed copies of this document are not considered signed and sealed and the _SHA-1 _authentication code must be verified on any electronic copies.

_Rulemaking Authority 471.025(1), 471.033(2), 471.008 FS. Law Implemented 471.025, 668.006 FS. History–New 11-3-15, Amended 2-3-16, 10-26-16._


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## my250r11 (Nov 16, 2021)

As long as it is a DP licensed in the the State & the correct Number of stamps/DP as required by the State Rules we accept them. Hard enough to get that sometimes and my time is better spent on plan review and compliance.


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## mtlogcabin (Nov 16, 2021)

It is electronic so who submitted it? If it is from the DP's email account or file transfer site then I would not be to worried that someone else is falsifying drawings/corrections and submitting them to us.


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## jar546 (Nov 16, 2021)

mtlogcabin said:


> It is electronic so who submitted it? If it is from the DP's email account or file transfer site then I would not be to worried that someone else is falsifying drawings/corrections and submitting them to us.


In our case whoever applies for the permit online uploads the documents.  95% of the time it is the contractor.


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## mtlogcabin (Nov 16, 2021)

98% of the time ours are submitted by the Architect since they are the ones who take a project through architectural and site review. The only file transfer site our IT department will allow us to use is the one operated by the state so all the DP's are already using it and most contractors do not want to be bothered with it. Win Win for us

Email can be used but it is very limited in size..


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## Mark K (Nov 16, 2021)

I suspect that there is confusion in the use of the term digital signature.  A digital file that contains a scanned signature is not necessarily a digitally signed file.

A digitally signed file will tell you if it has been modified.  In order to digitally sign a file the engineer needs to enter a password.

An electronic signature may consist of a scanned signature but for it to have legal validity you need more information that establishes that the engineer intended to sign the document.


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## jar546 (Nov 17, 2021)

Mark K said:


> I suspect that there is confusion in the use of the term digital signature.  A digital file that contains a scanned signature is not necessarily a digitally signed file.
> 
> A digitally signed file will tell you if it has been modified.  In order to digitally sign a file the engineer needs to enter a password.
> 
> An electronic signature may consist of a scanned signature but for it to have legal validity you need more information that establishes that the engineer intended to sign the document.


Absolutely correct.  Electronic and Digital are two different things.  Florida requires a digital signature that is verifiable and is voided if the document is altered.  We see scanned copies of drawings with an electronic signature shown in print but the inner workings of the PDF lack any digital signature, therefore we cannot accept them by law.


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## Mark K (Nov 17, 2021)

In California both electronic and digital signatures are legal.  Establishing that the electronic signature is valid is more difficult.

We have some agencies that will not accept a digitally signed file because they want to  ad their stamp to the approved document which I understand they then seal


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## jar546 (Nov 17, 2021)

Mark K said:


> In California both electronic and digital signatures are legal.  Establishing that the electronic signature is valid is more difficult.
> 
> We have some agencies that will not accept a digitally signed file because they want to  ad their stamp to the approved document which I understand they then seal



In our case the uploaded file must be digitally signed and sealed, flattened with security settings that allow the building department to place their reviewed stamp on it.  Once that is done, the file is flattened and brought back to the permit software as a separate file to be downloaded by the contractor.

The original file that was uploaded and digitally signed and sealed is left intact as proof of what was received.
A copy with the department seal "marked up" file is added for the contractor.
Yes when the BD stamp is added, it voids the RDP's digital signature but it is not relevant as the original intact file submitted to the BD is still present.
The system works as designed and protects the RDP because the BD stamped plan voids the signature.


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## mickleborn (Nov 25, 2021)

Thanks for these tips! Really useful!


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