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USE OF BUILDING CODES IN FEDERAL AGENCY CONSTRUCTION Committee on Assessing the Impact on Federal Agencies of the Use of Building Codes as Design Criteria Building Research Board Commission on Engineering and Technical Systems National Research Council NATIONAL ACADEMY PRESS Washington, D.C. 1989

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a mandate chat Hi ret: i t: NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competencies and with regard for appropriate balance. This report has been reviewed by a group other than the authors according to procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has ~ ~~ __ to advise the federal government on scientific and technical matters. Dr. Frank Press is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Robert M. White is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the of the public. The Institute Academy of Sciences by its congressional charter to be an adviser to the federal government and upon its own initiative, to identify issues of medical care, research, and education. Dr. Samuel O. Thier is president of the Institute of Medicine. The National Research Council was established by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and of advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Frank Press and Dr. Robert M. White are chairman and vice chairman, respectively, of the National Research Council. This report was prepared as part of the technical program of the Federal Construction Council (FCC). The FCC is a continuing activity of the Building Research the Commission on Engineering and Technical Systems of the National Research Council. The purpose of the FCC is to promote cooperation among federal construction agencies and between such agencies and other elements of the building community in addressing technical issues of mutual concern. The FCC program is supported by 14 federal agencies: the Department of the Air Force, the Department of the Army, the Department of Commerce, the Department of Energy, the Department of the Navy, the Department of State, the General Services Administration, the National Aeronautics and Space Administration, the National Endowment for the Arts, the National Science Foundation, the U.S. Postal Service, the U.S. Public Health Service, the Smithsonian Institution, and the Veterans Administration. Funding for the FCC program was provided through the following agreements between the indicated federal agency and the National Academy of Sciences: Department of State Contract No. 1030-621218; National Endowment for the Arts Grant No. 42-4253-0091; National Science Foundation Grant No. MSM-8600676, under master agreement 82-05615; and U.S. Postal Service grant, unnumbered. examination of policy matters pertaining to the health acts under the responsibility given to the National Board, which is a unit of Limited supplies of this document are available from the National Academy Press, 2101 Constitution Avenue NW, Washington, DC 20418. A charge of $3.00 for postage and handling must be prepaid. Printed in the United States of America

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Building Research Board 1988-89 CHAIRMAN RICHARD T. BAUM, Consultant, Jaros, Baum and Bolles, New York, New York MEMBERS . . LYNN S. BEEDLE, University Distinguished Professor of Civil Engineering and Director, Council on Tall Buildings and Urban Habitat, Lehigh University, Bethlehem, Pennsylvania GERALD L. CARLISLE, International Union of Bricklayers & Allied Craftsmen, Washington, D.C. RAY F. DeBRUHL, Executive Vice President, Davidson and Jones Corporation, Raleigh, North Carolina C. CHRISTOPHER DEGENHARDT, President, EDAW, Inc., San Francisco, California DAVID R. DIBNER, Senior Vice President, Bernard Johnson, Inc., Bethesda, Maryland EZRA D. EHRENKRANTZ, President, The Ehrenkrantz Group & Eckstut, New York, New York ELISHA C. FREEDMAN, Consultant, Associated Public Sector Consultants & University of Connecticut, West Hartford, Connecticut DENOS C. GAZIS, Assistant Director, Semiconductor Science and Technology, IBM Research Center, Yorktown Heights, New York GEORGE S. JENKINS, Consultation Networks Inc., Washington, D.C. RICHARD H. JUDY, Director, Dade County Aviation Department, Miami' Florida FREDERICK KRIMGOLD, Associate Dean for Research and Extension, Virginia Polytechnic Institute and State University, Alexandria MILTON PIKARSKY, Distinguished Professor and Director, Institute of Transportation Systems, The City College, New York, New York KENNETH F. REINSCHMIDT, Vice President, Stone and Webster Engineering Corporation, Boston, Massachusetts LESLIE E. ROBERTSON, Director, Design and Construction, Leslie E. Robertson Associates, New York, New York NANCY S. RUTLEDGE, Consultant, Woolwich, Maine RICHARD L. TUCKER, Director, Construction Industry Institute, The University of Texas, Austin JAMES E. WOODS, Senior Engineering Manager, Honeywell, Inc., Golden Valley, Minnesota APRIL L. YOUNG, Vice President, N.V.R. Development, McLean, Virginia ~

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STAFF ANDREW C. LEMER, Director HENRY A. BORGER, Executive Secretary, Federal Construction Council PETER H. SMEALLIE, Executive Secretary, Public Facilities Council PATRICIA M. WHOLEY, Administrative Coordinator JOANN V. CURRY, Senior Secretary LENA B. GRAYSON, Senior Secretary 157

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COMMITTEE ON ASSESSING THE IMPACT ON FEDERAL AGENCIES OF THE USE OF BUILDING CODES AS DESIGN CRITERIA Chairman DONALD G. ISELIN, Consultant, Santa Barbara, California WILLIAM A. BRENNER, Vice President, Codeworks, Inc., Washington, DC JEAN-PIERRE FARANT, School of Occupational Health, McGill University, Montreal, Quebec, Canada EARL L. FLANAGAN, Architect, U.S. Department of Housing & Urban Development, Washington, DC DAVID W. FOULER, Director of Architectural Engineering, Department of Civil Engineering, The University of Texas at Austin ROBERT W. GLOWINSKI, Technical Research Counsel, National Forest Products Association, Washington, DC JOHN C. HORNING, Schenectady, New York WILLIAM N. McCORMICK, Jr., Lockwood Greene Engineers, Inc., Atlanta, Georgia JOSEPH H. NEWMAN, Retired President and Chief Executive Officer, Tishman Research Corporation, Llewellyn Park, West Orange, New Jersey JAMES SCHEELER, The American Institute of Architects, Washington, DC Agency Liaison Representatives JAMES M. BAYNE, Director, Facilities Operations and Maintenance Division, National Aeronautics and Space Administration, Washington, DC KENNETH FAULSTICH, Chief, Fire Protection Division, Veterans Administration, Washington, DC EDWARD FEINER, Architect, General Services Administration, Washington, DC JAMES GROSS, Deputy Director, Center for Building Technology, National Institutes of Standards and Technology, Gaithersburg, Maryland DANIEL HIGHTOWER, Division of Health Facilities Planning, Rockville, Maryland DALE JACKSON, General Engineer, Balling Air Force Base, Washington, DC JACK METZLER, General Engineer, U.S. Department of Energy, Washington, DC RICHARD McCRONE, General Engineer, Veterans Administration, Washington, DC JACK MORTON, Mechanical Engineer, Veterans Administration, Washington, DC IVAR R. PAAVOLA, Chief, Structures Section, Corps of Engineers, Washington, DC THOMAS R. RUTHERFORD, Director, Criteria Division, Naval Facilities Engineering Command, Alexandria, Virginia MURRAY TUEL, Director, Office of Architectural Services, Montgomery County, Rockville, Maryland v

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Project Staff ANDREW C. LEMER, Director HENRY A. BORGER, Executive Secretary, FCC JOANN CURRY, Senior Secretary LENA GRAYSON, Senior Secretary vi

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ACKNOWLEDGEMENTS The committee wishes to thank the representatives of the organiza- tions who presented their views and participated in committee discus- sions. The committee expresses its appreciation as well of the active participation of the federal agency liaison representatives. This study was supported by the agencies of the Federal Construc- tion Council (FCC) under their contracts with the National Research Council. Mr. Henry gorger, P.E., Executive Secretary of the FCC served as project manager. Dr. Andrew C. Lemer, Director of the Building Research Board, participated in technical aspects of the study and preparation of the committee's report. Ms. Joann Curry especially is to be commended for her work in preparing the manuscript. V11

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PREFACE The diversity of requirements in building codes, zoning regula- tions, and building design criteria in the United States is truly remarkable, and is often lamented in the building professions. This diversity reflects geographic variations to which buildings must respond and is also understandable, in the case of codes and regulations, as an expression of local authority and freedom from higher levels of govern- ment control, and with building design criteria, as a reflection of the needs and preferences of individual building owners and users. While building professionals have long dreamed of the possible benefits of greater uniformity in building regulation throughout the United States, we recognize that some diversity is appropriate and desirable. Striking a balance between uniformity and diversity in policies that regulate building poses a broad range of economic, legal, social, and political as well as technological questions. In asking the Building Research Board (BRB) to evaluate suggestions that federal agencies should replace portions of their building design criteria with state, local, or model building codes, the agencies of the Federal Construction Council (FCC)1 inevitably raised many of these questions. The BRB established the Committee on Assessing the Impact on Federal Agencies of Use of Building Codes as Design Criteria to make the evaluation drawing on the committee's collective knowledge of the field, the reported experience of federal agency officials, and presentations by representatives of professional and trade associations. The committee has tried to avoid becoming ensnarled by matters of philosophy, while 1 Fourteen federal government agencies with broad interests in building and facilities research, design, construction, operations, and maintenance comprise the FCC. These agencies had a combined construction budget in 1987 of more than $7 billion, and influence over a much greater amount of the nation's built assets. at. 1X

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still acknowledging the broader issues, and has conducted its delibera- tions within the framework of the current status of building codes and design criteria, viewed at a national level. We believe the nation would indeed benefit from some shift in policy and federal agency practice toward uniformity. We hope that the work of this committee will contribute to the necessary groundwork for this shift. Rear Admiral Donald G. Iselin, CEC, USN (Ret) Chairman, Committee on Assessing the Impact on Federal Agencies on Use of Building Codes as Design Criteria Andrew C. Lemer' Ph.D. Director, Building Research Board x

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EXECUTIVE SUMMARY Construction of buildings and other facilities owned by the federal government is not subject to regulations established by local building codes. Concerns for public health and safety, which local building codes are intended to ensure, are addressed in the design criteria federal agencies have established for themselves and firms employed to design and construct their facilities. Three principal model building codes, published by private pro- fessional organizations, are currently used in the United States, although a range of other more limited documents are published by other organizations as model codes. Most of the thousands of different building codes encountered across the country are adapted from one or another of the three principal model codes and given force of law by local or state government. Responsible state and local government officials are sometimes concerned that a federal building is being constructed or renovated in ways that do not conform to the official building code and therefore may not meet local expectations for health or safety. Organizations that promulgate the model codes are concerned that federal agency design criteria and guidelines differ from model codes and thereby worsen the already complex regulatory situation of the nation's building industry. Federal officials, who are responsible for construction of facilities to serve sometimes specialized agency purposes in many parts of the country, are reluctant to expose themselves unnecessarily to this complex regula- tory situation. The "Public Buildings Amendments of 1988" (Public Law 100-678) require that all federal buildings be '~constructed or altered, to the maximum extent feasible" in compliance with one of the nationally recognized model building codes and other applicable recognized codes such as electrical codes, plumbing codes, and fire and life safety codes. The impact of this legislation -- which builds on existing government policy and current practice in some agencies -- will vary substantially among the approximately 30 federal agencies that have responsibilities for building construction and alteration. The new law enhances existing federal policy stated in the Office of Management and Budget's Circular Number A-119, "Federal Participation in the Development and Use of Voluntary Standards." This circular calls on all agencies to adopt available private sector standards that meet agency needs, to encourage development of such standards, and to participate actively in the professional and industry organizations that develop such standards. X1

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The Building Research Board formed the Committee on Assessing the Impact on Federal Agencies of the Use of Building Codes as Design Criteria in response to a request by the Federal Construction Council. This request was motivated by continuing agency desire to improve the efficiency and effectiveness of their building programs, as well as by concerns regarding their compliance with broader federal policy. The committee met over the course of approximately nine months to review available information, hear the testimony of representatives of federal agencies and private sector organizations involved in codes development and use, and discuss the issues of building codes and design criteria used in the United States. This report presents the committee's conclusions and recommendations: Codes and Design Criteria. Building owners, whether in the public or private sectors, have requirements for building performance that extend well beyond the scope of building codes or the minimum requirements set in such codes. Model building codes can often be used for a portion of agency design criteria, but are not a substitute for all agency design criteria. Compliance to the Maximum Extent Feasible. The scope of "feasible compliance" under the new law should be limited initially to the three principal model building codes in use in the United States. The diversity of the large number of regularly published documents con- taining proposed guidelines and standards for building construction and purporting to be model codes is a meager reflection of the morass of more than 10,000 state and local building codes that have force of law in local government jurisdictions across the nation. While some diversity is appropriate among building regulations intended to protect public safety, health and welfare in the varied geographic conditions found from one part of the United States to another, the committee endorses the sentiment of those who call for increased use of the model codes, and for increased uniformity among these model codes. Limits of Code Applicability. The committee observes that in their experience building codes typically cover no more than approximately 20 percent of the criteria used in design of typical buildings. When agencies' requirements as owners do not differ substantially from common practice reflected in the model codes, the committee recommends that agencies should refer to the model codes as their design criteria for those concerns covered by codes. Agencies Should Be More Involved in Model Code Development. The committee recognizes that many agencies have not in the past parti- cipated actively in development of model codes and have responded in only a limited way to the policy stated in OMB Circular A-ll9. Agency pro- fessionals act as both building owners and regulatory officials, and have the capability to make significant contributions to the quality of building regulation in the United States. These professionals should be encouraged to make this contribution through greater participation in the organizations that promulgate the principal model codes. Some funding ~ X11

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will be required to support meaningful participation. The model code organizations should take steps to foster the participation as well. Agencies Should Periodically Review their Justification for Design Criteria Above Minimum Standards. The committee observes that federal agencies, like any building owner, may have valid requirements for building performance that exceeds levels implied by the minimum acceptable levels set in building codes. However, the committee recommends that agencies periodically review whether these higher requirements are warranted, in view of their impact on building costs and performance. Model codes can provide a useful baseline for such reviews, conducted within a framework of benefit cost analysis. Agencies Should Use Model Building Codes Construction in compliance warn nac~ona'~y recognized moue' codes is achieved when agency design criteria are met and these criteria meet or exceed requirements stated in the codes. However, the committee recommends that agencies should go the step further and replace their explicit criteria with reference to model codes and the standards they encompass, for those areas covered by the codes and where agency requirements do not warrant performance above the minimums established in codes. Some agencies have already adopted this approach in their design criteria, but others may incur significant costs in revising their criteria documents. The committee feels that these costs will be balanced by long term savings from increased competition, greater efficiency in design, and contribution to An ;mnrov-d h''i l dins regulatory climate in the United States. Agencies Should Foster Uniformitv in Building Recut Phi on The committee ca' Is on genera' agencies co wore actively toward bringing greater order to the morass of building codes and design criteria that regulate building construction in the United States. While there are valid differences in owners' requirements and community concerns for public safety, health, and welfare from one location to another, greater uniformity is possible and can bring economic and performance benefits to the users and producers of buildings. Agencies should support efforts to develop computer databases and analyses of benefits and costs that will assist comparisons among codes and among agency criteria. The committee urges Congress to support such efforts as well. t . X111

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CONTENTS 1. Introduction Origin of the Suggestions Some Key Definitions 2. Underlying Issues Extensive Scope of Owner's Requirements Federal Agencies as Building Owners and Users Scope and Diversity in Federal Agency Requirements Local Government Concerns About Federal Exemption from Local Codes Local Building Codes and Building Inspection Diversity of Local Code Provisions Local Codes as Barriers to National Policy or Technological Innovation Potential Advantages of Increased Use of Model Building Codes 3. The Principal Model Codes How the Model Codes Are Developed Comparing the Model Codes Moves Toward Uniformity 4. Federal Actions Related to the Question Executive Guidelines on Federal Participation in the Development and Use of Voluntary Standards Legislation to Improve the Efficiency and Effectiveness of Management of Public Buildings Current Agency Activities 5. Committee Findings, Conclusions, and Recommendations Codes and Design Criteria Compliance to the Maximum Extent Feasible Limits of Model Code Applicability .xv 1 1 8 9 10 10 10 12 12 15 15 16 17 19 19 20 22 23 23 24 25

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Agencies Should be More Involved in Model Code Development Agencies Should Periodically Review Their Justification for Design Criteria Above Minimum Requirements Federal Agencies Should Use Model Building Codes Agencies Should Foster Uniformity in Building Regulation 26 26 27 27 Appendix A OMB Circular No. A-119 29 Appendix B Section 6, Public Building Amendments of 1988 45 Appendix C Survey of Agencies' Design Criteria 51 Appendix D Biographical Sketches of Committee Members 53 XYi