Darren Draper, Epsten Group & Jim Magee, Facility Cx Group 21 st National Conference on Building Commissioning

Darren Draper, Epsten Group & Jim Magee, Facility Cx Group

21st National Conference on Building Commissioning

AIA Quality Assurance

The Building Commissioning Association is a Registered Provider with The American Institute of Architects Continuing Education Systems (AIA/CES). Credit(s) earned on completion of this program will be reported to AIA/CES for AIA members. Certificates of Completion for both AIA members and non-AIA members are available upon request.

This program is registered with AIA/CES for continuing professional education. As such, it does not include content that may be deemed or construed to be an approval or endorsement by the AIA of any material of construction or any method or manner of handling, using, distributing, or dealing in any material or product.

Questions related to specific materials, methods, and services will be addressed at the conclusion of this presentation.

21st NCBC Conference

Presentation Description

IgCC adoption into prevailing building codes creates Authority Having Jurisdiction (AHJ) enforcement and implementation requirements for commissioning services providers, including accreditation and liabilities not currently associated with typical commissioning services.


At the end of this session, participants will be able to:

1. Apply International Green Construction Code (IgCC) to Commissioning (Cx) and Cx contract considerations.

2. Understand International Code Council (ICC) and International Accreditation Services (IAS) participation in IgCC and other codes pertaining to Cx.

3. Read ACR476 open letter dated April 5, 2013 requesting review and response by May 22, 2013 concerning Presentation on Development of Accreditation Criteria for Organizations Training and/or Certifying Individuals Involved in Commissioning, Subject MISC3-0613- 0613-R1 (PB/CPR).

Learning Objectives



INTERNATIONAL ACCREDITATION SERVICE, INC. 5360 Workman Mill Road ⋅ Whittier, CA 90601 USA 562-364-8201 local ⋅ 866-427-4422 toll free ⋅ 562-699-8031 fax www.iasonline.org web site ⋅ April 5, 2013

TO: TRAINING AGENCIES, PERSONNEL CERTIFICATION BODIES, BUILDING DEPARTMENTS AND OTHER INTERESTED PARTIES SUBJECT: Presentation on Development of Accreditation Criteria for Organizations Training and/or Certifying Individuals Involved in Commissioning, Subject MISC3-0613- 0613-R1 (PB/CPR)

AGENDA


1. International Code Council (ICC)2. International Green Construction Code (IgCC)3. ICC Commissioning Guideline4. IAS and ACR4765. ASHRAE STANDARD 202/ASHRAE BPA6. ISO 170247. DCRA 1st Annual Green Symposium

• Member focused association

• Develop model codes and standards

• Minimum safeguards to protect people

• Safe, resilient, affordable structures

• One set of codes without regional limitations


ICC I-CODES• International Codes: I-Codes

• 50 State including the DC have adopted at state or jurisdictional level

• Fed agencies: Architect of the Capitol, GSA, NPS, Dept. of State, USFS, VA, DoD, Amtrak

• Puerto Rico and Virgin Islands


ICC CREATION• ICC founded in 1994

• Building Officials Code Administrators International (BOCA)

• International Conference of Building Officials (ICBO)

• Southern Building Code Congress International (SBCCI)

• Merger to a single set of codes


ICC – CODE DEVELOPMENT

• Any group or individual can submit a code change proposal

• Open debate/participation before a committee

• Representatives from across the construction industry, including code regulators

• Ensures a consensus process of construction community in decision-making


IgCC–INTERNATIONAL GREEN CONSTRUCTION CODE

• 1st model code to include sustainability measures• Design – Construction – C.O. – Post-Occupancy• More efficient, reduce waste, positive impact• Collaborated with

• American Institute of Architects (AIA)• ASTM International • ASHRAE• USGBC• Illuminating Engineering Society (IES)


IgCC • Model-Code Approach - communities tailor to meet local

needs• Note: 189.1 is jurisdictional compliance option, however Cx

is mandatory regardless of compliance route chosen• 611.1.1- Registered design professional OR approved

agency• Approved Agency – An established and recognized agency

regularly engaged in conducting tests or furnishing inspection services or commissioning services, where such agency has been approved (approved = acceptable to code official)


IgCC

• 902.1.1 Commissioning professional is required to be “competent and independent” from contractor performing the work

• Code states that IAS Accreditation ensures code official of the commissioning professional’s competence and independence


IgCC• 611.1.4 Preliminary Cx report shall be certified

(signed and sealed) and final inspection not allowed until building owner has received Preliminary Cx report and confirmed as such to the code official. Otherwise building will not get a Certificate of Occupancy

• Table 903.1 – Checklist of Cx requirements from Erosion Control to Air Balancing, and reads that all 60+ items in Cx Report


IgCC A Few Regulated Environment Cx Implications:

•Could be a much larger role and fee in the project depending on jurisdiction

•Brings commissioning authority much closer to the local AHJs

•Code enforcement can be expected of the commissioning authority


IgCC• Significant legal implications - exposure to poor

performance

• Cx Standard of Care - legal ramifications could follow if the Standard of Care is not met

• CxA will be either a registered design professional or a credentialed commissioning authority (more on this later)

• Code enforcement can be expected of the commissioning authority


SUMMARY OF IgCC Cx IMPLICATIONSGOOD BAD UGLY

More systems and services provided, higher fees

More risk, professionally and legally

Cx taking place of the AHJ and therefore assuming far more responsibility

More impact on design/construction decisions

Higher insurance coverage and premiums

Cx Provider could be accountable for collecting all documentation deemed a Cx item (i.e. field report for inspection of soils)

Actively involved after building turnover in recommissioning

More stringent requirements for certification and registration

Movement toward unified expectation of Cx professionals

Competitive advantage for large firms with all specialties in house

Only required to be independent of contractor, not independent of design team


IgCC• Per April 5, 2013 IAS Letter, “IgCC establishes

requirements for certain buildings to be commissioned.”


IgCC

• “As adoption of the IgCC and other green codes advances, the responsibility for enforcing commissioning shifts to the authority having jurisdiction.”

• “Regulators, therefore, need a process to ensure that commissioning agents/agencies comply as Approved Agencies as defined in Section 902.1 of the IgCC.”

April 18, 2013 ACG 9TH ANNUAL CONFERENCE ON TOTAL BUILDING COMMISSIONING 19

ICC G4-2012: GUIDELINE FOR COMMISSIONING


ICC G4-2012: GUIDELINE FOR COMMISSIONING


ICC COMMISSIONING GUIDELINE

• Compliance language• Enforcement at discretion of local code official• Evaluation criteria for Cx of each system type

located in Section 5.0• Guideline specifically for overview of skillsets

and process for code implementation/enforcement

• Can adopted in whole or in part by AHJ• Similar implications as outlined for IgCC (IeCC)


Per April 5, 2013 IAS Letter:

“To aid code officials in enforcing commissioning, the International Code Council (ICC) has published a Commissioning Guideline (ICC G4-2012). However, this guideline does not specify what is required when approving and accepting a commissioning agent/agency.”


ICC COMMISSIONING GUIDELINE

IAS – INTERNATIONAL ACCREDITATION SERVICES


• IAS is a nonprofit, public-benefit corporation that has been providing accreditation services since 1975. It is a subsidiary of the International Code Council (ICC).

• IAS accredits a wide range of companies and organizations including governmental entities, commercial businesses, and professional associations.

ACCREDITATION/CERTIFICATION

ICC tasks IAS with creating an accreditation for Cx certification companies.


IAS CREATES AC 476

• AC 476 - Establish criteria for obtaining and maintaining accreditation for commissioning training and certification organizations.

• Organizations must provide training in the following:

• Cx process• Codes, standards, guidelines• Systems, equipment, components and verification of

their performance


IAS AND AC476

• Personnel certification shall certify that:• Individual has thorough knowledge of Cx process• Knowledge of codes, standards, guidelines• Ability to verify system performance• Met their minimum requirements for education,

work skills and experience• And comply with ISO 17024


IAS AND AC476• Commissioning professional defined in two

ways:• Commissioning Provider of Record – Approved

by AHJ to be responsible for building commissioning process

• Commissioning Specialist (twelve categories from HVAC to Irrigation) – Certified party working under the Cx Provider of Record for specific technical area


IAS AND AC476• AC476 defines options for educations

requirements, work experience and examination (currently in Section 5.2 of the version available for public comment)

• Two tables to distinguish between certification criteria for Cx Provider of Record and Cx Specialists

• ISO 17024 – objective is achieving and promoting accepted benchmark for organizations operating certifications of persons

• Could be applied to organizations for anything from commissioning to IT and more


IAS AND AC476• Could be applied to organizations for anything

from commissioning to IT and more

• By AC476, certification bodies will be required to be ISO 17024 certified which involves an initial certification and then annual audit and renewal

• ISO 17024 certification requires:• Fairness among potential candidates• Policies for granting, maintaining, renewing and

expending the certification• Organization must be INDEPENDENT and

IMPARTIAL in relation to applicants


AGENT VERSUS AUTHORITY

• Important to know and understand the legal differences• Authority – Individual cited as or appealed to as an

expert (Webster’s)• Agent – One who is authorized for or in place of another

(Webster’s)• What this means is that an agent does not work for the

client but actually becomes the client. So the CxA would actually become the Owner in this instance contractually. This is not how commissioning contracts are typically written.


AGENT VERSUS AUTHORITY• Essentially all of the Cx bodies providing certification of

commissioning professionals have recognized the title of Authority or interchanges between Authority and other titles (i.e. Provider), but most do not call the professional a Commissioning Agent

• Finally, IgCC identifies Approved Agency in lieu of Authority or Agent

• Thanks to Jerry Kettler for his report on commissioning professional terms which was used to create this slide


REGULATORY STEPS TO THE PRESENT SITUATION:


INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO)

• World’s largest developer of voluntary International Standards [that] give state of the art specifications for products, services and good practice, helping to make industry more efficient and effective. Developed through global consensus, they help to break down barriers to international trade.

• ISO develops International Standards. We were founded in 1947, and since then have published more than 19,500 International Standards covering almost all aspects of technology and business. From food safety to computers, and agriculture to healthcare, ISO International Standards impact all our lives.


ISO 17024


ASHRAE STANDARD 202


ASHRAE STANDARD 202

•ASHRAE BUILDING PERFORMANCE ALLIANCE

(BPA)


DCRA 1ST ANNUAL GREEN SYMPOSIUM

Summary of Services

DCRA is responsible for regulating construction and business activity in the District of Columbia. The agency operates a consolidated permit intake center and reviews all construction documents to ensure compliance with building codes and zoning regulations.


DCRA 1ST ANNUAL GREEN SYMPOSIUM• District of Columbia

• Department of Consumer and Regulatory Affairs

• The mission of the Department of Consumer and Regulatory Affairs (DCRA) is to protect the health, safety, economic interests and quality of life of residents, businesses and visitors in the District of Columbia by ensuring code compliance and regulating business.








Sample IgCC Code Mandated Commissioning Test

606.1.2.2 Testing requirement. The building envelope air tightness shall be considered to be acceptable where the tested air leakage is less than 0.25 cfm/ft2 (4.57 m3/hr/m2) when tested at a pressure of .30 in w.c. (75 Pa). Testing shall occur after rough in and after installation of penetrations of the building envelope, including penetrations for utilities, HVAC, plumbing, and electrical equipment and appliances. Testing shall be done in accordance with ASTM E779.


IAS APRIL 5, 2013

• Commissioning, as defined by the IgCC:

“Commissioning verifies that building staff are prepared and able to operate and maintain the building’s systems.”


IAS APRIL 5, 2013• “You are cordially invited to submit written comments, or

to attend the committee hearing and present verbal comments.

• Written comments will be forwarded to the committee, prior to the hearing, if received by May 15, 2013.”

• Link to AC-476: http://www.iasonline.org/Accreditation_Criteria/1306-pre/MISC3-0613.pdf


THANK YOU

Darren Draper Jim Magee

Documents

Darren Draper, Epsten Group & Jim Magee, Facility Cx Group 21 st National Conference on Building Commissioning