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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

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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

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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

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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

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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

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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