# CA Building Officials - What's the Deal.



## Noob (Mar 8, 2019)

I work with architects in various jurisdictions in Southern California - we've noticed a large difference over the past 10 years regarding the plan review process.  The plans went from being acceptable to all of a sudden we are being forced (literally forced) to add huge sections of written code verbatim to our drawings to get a permit.  We submit and it comes back with 14 pages of commentary.  First off, the applicable codes are listed on the cover page - so no matter what, that's the law, contractors are required to follow the applicable codes.  Secondly, producing an "abridged" version of the code in our drawings is risky without disclaimer.  Because now it looks as though we are saying follow this "abridged" version of the code, not that book.  When really, it's black and white, follow the applicable building codes, period (it's only 1,500 pages).  Thirdly, I can only imagine how confounding it must be to cost estimation and subcontracting to decipher something like "provide X pursuant to the requirements in X unless because of X per CFC 12030.22 in areas that contain X" that was put in there at the request of an official.  Also, I used to live in another state where the inspectors where extremely knowledgeable contractors who actually would help the contractor come to an acceptable solution (ie. they understood the difficulties and knew it was best to be an educator in almost every situation).  On the 3 or 4 projects I've managed thus far, the inspectors have been seemingly trained to never say what they would or wouldn't accept in the field, just bizarre.  And all of this is as if the city has liability in the process.  Maybe I'm wrong, but Architects are licensed by the State, and often end up in construction litigation for code issues (why errors and omission insurance exists), so I'm baffled.  And I can tell it's really thrown Architects for a loop in CA, they end up having to submit 3 months early to make sure they start the project on time (which is why the drawings aren't great).  On top of longer plan check processes, the planning dept. times are excruciatingly long.  Makes the whole AEC industry look terrible to our clients IMO.  Few things I've thought:

1.  Some new (mystery) policy was enacted at State Level requiring greater enforcement efforts than previously.
2.  Experienced Folks in the Building Departments are all leaving/retiring, and there's just less real experience, so the younger folks are relying more heavily on passive tactics.
3.  There's been some new event that has made State's and Jurisdictions more at risk of liability for building code issues than they were previously.

Very curious for answers from you CA Building Officials.


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## cda (Mar 8, 2019)

Not in calif, so cannot speak to that

But city or inspectors are not supposed to design. Yes on simple stuff in the field they should listen to alternatives and if meet code approve them.

Very few plans submitted, conform to base code, so yes they need to be questioned.

Very few times I request actual code language to be written on plans.

Rarely see a contractor with a code book in thier hands, so not sure how they follow it?
Most say, that is what the plans say to do.

Not sure what you mean by abridged


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## Nearly-Complete (Mar 8, 2019)

A part of what you are referring to may be that CALGreen and CA Energy code do require quite a bit of language and checklists to be directly on the plans. It is pretty annoying because nobody reads those sheets, but I can see the goal for the requirement. So many builders ignore those regs because they are seen as unimportant by so many in the industry that they are trying everything they can to increase statewide compliance. Unfortunately, their efforts lead to more frustration than actual compliance.


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## Noob (Mar 8, 2019)

I mean abridged, because we are not reprinting the entire code, just portions of it.  The plan reviewer's favorite sections maybe?.  It _is_ quite annoying, and I haven't found there to be many really "good" architects practicing in this area of the world, I think because it just takes so much more time and energy to deal with all of this garbage day-to-day, that making a set "for construction" has become literally an afterthought.  Additionally, supplements, emergency supplements, and errata to the building code are sent out every 4 months or so.  Basically chaos.

Yes, there's the CALGreen checklists.  The Energy Codes (which everyone agreed to call Title 24 Calcs, for some reason, by the Energy Commission which is a different bureaucracy than the Code Commission) are additional 8.5x11 compliance forms added into the set.  There's the Energy Standards (325 pages) and then there's the compliance manual (746 pages).   And it all gets updated every 3 years or less along with all the other codes.  Occasionally a jurisdiction is smart enough to create a cover sheet for you with what they want.  Even this to me seems like a violation of the architect's instruments of service, but I'd rather that than blindly guessing what every town wants to enforce.


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## mark handler (Mar 9, 2019)

Why
because there are so many so called contractors that do not know the code, do not have a code, and have never read the code.
They then ask the inspector to show them where it is in the code.
My inspectors do not have that time.
If it is on the plans, less arguments in the field.
In 38 years in the buisness, I have only seen three or four construction sites with the codes in the construction trailer.

You need to show me the plans meet the code
2016 CBC ( same in CRC) 107.2.1 Information on construction documents
*Construction documents *shall be of sufficient clarity to indicate the location, nature and extent of the work proposed and *show *in detail* that it will conform to the provisions of this code and relevant laws, ordinances, rules and regulations, as determined by the building official.*

The easiest way to show compliance is by notes.


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## jar546 (Mar 9, 2019)

mark handler said:


> Why
> because there are so many so called contractors that do not know the code, do not have a code, and have never read the code.
> They then ask the inspector to show them where it is in the code.
> My inspectors do not have that time.
> ...



I totally agree.  I will say, however, that most contractors don't read the notes either but I like the fact it is in print on the  drawings because it has saved an argument more than once.


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## Mark K (Mar 9, 2019)

The plan checkers are exceeding their authority and trying to define how the construction documents are produced.  Yes the construction documents must address the relevant code provisions.  No it is in appropriate to repeat significant sections of the code on the drawings.

Inclusion of these sections of the code will likely confuse the contractor thus resulting in the project not being constructed in conformance with the intent of the design professional.

When the plan checker and the building official step over a line in dictating how the construction documents are organized they should then become responsible for the  costs of the confusion they create.  They should then be required to take responsibility for the design.  

The fact that the inspectors find it inconvenient to specify code sections is irrelevant.


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## Mark K (Mar 9, 2019)

Will suggest that this is a Southern California thing since I have not heard of this in Northern California.


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## mark handler (Mar 11, 2019)

As an Architect I have done work all over California and the US.
I have never been asked to place "unreasonable" notes and code sections on the plans. Sometimes it is easier and more through to note it. Sometimes providing a detail does not show compliance. Providing notes is a CYA in many cases.

Many times a graphic representation does not show compliance with all the nuances of the code.

Many times, I find the biggest complainers are unlicensed individuals that got in deeper than they thought. A restaurant is not the same as a room addition.


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## tmurray (Mar 11, 2019)

We generally ask for a "code matrix". It is a document that tells us the assumptions used int he design, so we are not left to guessing what the architect/engineer is designing to.

I find this really helps with the code review process.


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## cda (Mar 11, 2019)

tmurray said:


> We generally ask for a "code matrix". It is a document that tells us the assumptions used int he design, so we are not left to guessing what the architect/engineer is designing to.
> 
> I find this really helps with the code review process.




do you have a short example you can post


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## mark handler (Mar 11, 2019)

LOS ANGELES REGION UNIFORM CODE PROGRAM
The Los Angeles Basin ICC Chapter has been very active throughout the years in leading an effort to create uniformity of building codes and regulations in the greater Los Angeles region as well as addressing policy issues of interest to building officials and the construction industry.
One such effort to promote uniformity of building regulations is through the Los Angeles Regional Uniform Code Program (LARUCP). The LARUCP program began in July 1999 with the purpose of developing uniform interpretations and handouts to serve as guidelines for Building Officials, Inspectors, Contractors, Engineers and Architects in the consistent application of the codes. The mission of this program was to minimize the number of and to develop uniformity in local code amendments to the California codes for adoption by jurisdictions in the greater Los Angeles region.

This is to make submittals easier to predict.


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## tmurray (Mar 11, 2019)

cda said:


> do you have a short example you can post


Here is a good one from Ontario: https://www.barrie.ca/Doing Business/Building-Services/Documents/OntarioBuildingCodeMatrix.pdf


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## cda (Mar 11, 2019)

tmurray said:


> Here is a good one from Ontario: https://www.barrie.ca/Doing Business/Building-Services/Documents/OntarioBuildingCodeMatrix.pdf




Thanks. 

Have seen similar, thought yours might be something else


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## Mark K (Mar 11, 2019)

The primary purpose of the construction documents is to instruct the contractor.  All other uses are secondary.  

The construction documents need to address all relevant code requirements but the manner that this is accomplished is up to the registered design professionals.  In general the design professional will present the information in fairly standard ways that should make it relatively easy for the contractor and plan checkers to find it.  "Requirements" by the plan checker that certain information be shown in a particular location appear to be because the plan checkers are not aware of these industry practices or are too lazy.

Code data matrix does not belong on the construction documents since it does not direct the contractor.  If such matrix is used it should be considered a submittal document not a construction document.  The matrix is a summary of data that is supposedly already in the construction documents and there is a potential that the plan checker will use it as a crutch and not verify what the construction documents actually show.


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## mtlogcabin (Mar 11, 2019)

Mark K said:


> The fact that the inspectors find it inconvenient to specify code sections is irrelevant.


My inspectors will not do a code search while in the field to provide a specific code section. They call me and I find it and e-mail it to them. If they are still on the job site by the time I get back to them great if not they forward the code section(verbiage) to their contact on the job and discuss it with them later . An inspectors schedule can be pretty full and not allow them the time to research codes in the field for a contractor and even for themselves.


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## JPohling (Mar 11, 2019)

Mark K said:


> The primary purpose of the construction documents is to instruct the contractor.  All other uses are secondary.
> 
> The construction documents need to address all relevant code requirements but the manner that this is accomplished is up to the registered design professionals.  In general the design professional will present the information in fairly standard ways that should make it relatively easy for the contractor and plan checkers to find it.  "Requirements" by the plan checker that certain information be shown in a particular location appear to be because the plan checkers are not aware of these industry practices or are too lazy.
> 
> Code data matrix does not belong on the construction documents since it does not direct the contractor.  If such matrix is used it should be considered a submittal document not a construction document.  The matrix is a summary of data that is supposedly already in the construction documents and there is a potential that the plan checker will use it as a crutch and not verify what the construction documents actually show.




I agree that some plan reviewers are lazy and will not look to hard to find the necessary code references that are placed on the plans to prove code compliance.  Some will spend the time, but would like to see the information on another location so that the GC does not miss it.  Point is if you do not satisfy the code reviewers you will not obtain a permit so your CD's are essentially worthless as the GC will never have an opportunity to build from them.


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## mark handler (Mar 11, 2019)

Mark K said:


> The primary purpose of the construction documents is to instruct the contractor.  All other uses are secondary.
> 
> The construction documents need to address all relevant code requirements but the manner that this is accomplished is up to the registered design professionals.  In general the design professional will present the information in fairly standard ways that should make it relatively easy for the contractor and plan checkers to find it.  "Requirements" by the plan checker that certain information be shown in a particular location appear to be because the plan checkers are not aware of these industry practices or are too lazy.
> 
> Code data matrix does not belong on the construction documents since it does not direct the contractor.  If such matrix is used it should be considered a submittal document not a construction document.  The matrix is a summary of data that is supposedly already in the construction documents and there is a potential that the plan checker will use it as a crutch and not verify what the construction documents actually show.


Read section 107 of the CBC, SUBMITTAL DOCUMENTS. 
Says nothing about the contractor. Show compliance with the code.
I don't care what the contractor is building from as long as it  complys the the submittal documents approved by the ccity agencies.
What plans you give them is irrelevant to the code.
What you submit to the city and what is built is all that I care about.


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## tmurray (Mar 12, 2019)

Mark K said:


> Code data matrix does not belong on the construction documents since it does not direct the contractor.  If such matrix is used it should be considered a submittal document not a construction document.  The matrix is a summary of data that is supposedly already in the construction documents and there is a potential that the plan checker will use it as a crutch and not verify what the construction documents actually show.



I should clarify, the matrix forms part of the building permit application. I do not care if the contractor gets a copy or not. In fact, I do not see how it would be helpful to a contractor at all.There are three different methods used to calculate the number of building occupants. There are 60 different building classifications. Each one having a different acceptable occupancy group, number of stories, area, number of streets, level of fire separation, and fire protection. It would be very helpful to us to know which the designer used so that we can quickly check to make sure they are in the right ball park. 

Without knowing this information, plan reviews will take a much longer time. We end up having to do our code reviews over and over until we find what the designer used for their design. 

However, I would also agree that it is not exactly reasonable to re-write major portions of the code on the plans. The whole "show me in writing" can be dealt with as mtlogcabin suggested. Establish a maximum turn around time for code section investigation requests of 24 hours. During this time, you can prohibit the covering of any suspect work that may be subject to re-inspection. This process reduces the number of frivolous code section requests.


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## JPohling (Mar 12, 2019)

tmurray said:


> I should clarify, the matrix forms part of the building permit application. I do not care if the contractor gets a copy or not. In fact, I do not see how it would be helpful to a contractor at all.There are three different methods used to calculate the number of building occupants. There are 60 different building classifications. Each one having a different acceptable occupancy group, number of stories, area, number of streets, level of fire separation, and fire protection. It would be very helpful to us to know which the designer used so that we can quickly check to make sure they are in the right ball park.
> 
> Without knowing this information, plan reviews will take a much longer time. We end up having to do our code reviews over and over until we find what the designer used for their design.
> 
> However, I would also agree that it is not exactly reasonable to re-write major portions of the code on the plans. The whole "show me in writing" can be dealt with as mtlogcabin suggested. Establish a maximum turn around time for code section investigation requests of 24 hours. During this time, you can prohibit the covering of any suspect work that may be subject to re-inspection. This process reduces the number of frivolous code section requests.



Do you not just ask for an area analysis or an occupancy analysis?  simple.  it validates the design for the plan reviewer.  GC could care less


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## tmurray (Mar 12, 2019)

JPohling said:


> Do you not just ask for an area analysis or an occupancy analysis?  simple.  it validates the design for the plan reviewer.  GC could care less


No idea what either of those analyses are.


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## ADAguy (Mar 12, 2019)

CYA is the name of the game today, consider them as potential courtroom exhibits ?


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## JPohling (Mar 12, 2019)

tmurray said:


> No idea what either of those analyses are.


What is your position in the building game?


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## tmurray (Mar 13, 2019)

JPohling said:


> What is your position in the building game?


Chief Building Official

I'm assuming that those are IBC/CBC based? I don't use ICC codes for the most part.


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## JPohling (Mar 13, 2019)

What codes do you use and they do not have "allowable building area analysis"? or a "mixed use occupancy analysis"?

Oh I see you are from our neighbors to the North.


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## Noob (Mar 23, 2019)

Great info from all!  Sorry for this long-winded rant;
So, CA Title 24 is over 4,548 pages, last I checked.  I agree, we need to meet code, no matter what.  But making that efficient on the plan review side is another matter.  *As an architect, I would love to fill out a 10 page matrix *for "commercial restaurants" or "assembly" or "Research Facilities".  But this _needs to come from the jurisdiction_ as their due-diligence.  I'm in SoCal, and every town is different in their enforcement, forms, bulletins, policies etc.  It's not uncommon for the first submittal being sent a boiler plate "corrections" list.  An obvious indicator, that they pretty much didn't even look at the drawings that were submitted.  The second submittal, you get 14 pages of comments.  The third submittal, after you thought you had addressed all 14 pages thoroughly, they "find" new corrections somehow (oh also, you're incurring thousands of $$ in printed drawing sets every time).  In the meantime, the contractor is twiddling his thumbs waiting for the permit, and the client is pointing at the architect saying "boy, this guy is incompetent", we should have a permit already!  If the thorough "check" needs to be done, bldg depts need to make it efficient for us and for yourselves!  Then the architects can focus on making better drawings that are easier to check.  Obviously, there are bad and good actors in all these roles, but I just feel like here in SoCal it's a mess.  We've got this bloated code, so how do we deal with that efficiently?  We need SoCal plan reviewers to step-up and guide that process, but that's not happening.  Even just the building application form is always one-size-fits-all.  Doesn't matter if you are building a Hospital or a house....fill this out, it's all the same to us....?  And God forbid we do ANYTHING digitally.  This is why we have plan review expediters setting up shop in the city - that ought to be a warning sign to any city building/planning dept. that things are so highly inefficient for us (architects/contractors) that we are willing to pay someone to deal with it.  Many cities in the US are already on a fully digital plan check system.  Hell, even New Orleans (as corrupt of a city as it is) is 100% digital plancheck now.

Tmurray - Thanks for that Matrix, I agree this should be furnished uniformly by each city as part of the building application.
Mark Handler - is the LARUCP helping anything?  Last person I spoke to that permitted in LA said it was a nightmare.


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## Noob (Mar 23, 2019)

Responding to my own post.  The added benefit of providing a complex code matrix is also that you can immediately throw the complexity in front of the applicant, without even looking at their drawings.  If they submit garbage, you can say, uh I think you need an architect to help you with this, you obviously don't know what you are doing.  This protects clients, helps architects, and keeps the bad contractors accountable.


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## tmurray (Mar 25, 2019)

Noob said:


> ...  Even just the building application form is always one-size-fits-all.  Doesn't matter if you are building a Hospital or a house....fill this out, it's all the same to us....?  ...



This is always a surprise to me that more people don't do this. We have different applications for houses, decks, fences, sheds...etc. I need different information to approve each one of those applications, so I explicitly tell people what information I need. I don't have time to keep asking people for more information.


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