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APPENDIX C SURVEY OF AGENCIES' DESIGN CRITERIA The Committee on Assessing the Impact on Federal Agencies of the Use of Building Codes as Design Criteria conducted an informal survey among construction agency members of the Federal Construction Council to gather information on the extent of overlap between current agency design criteria and the provisions of the principal model codes. Four questions were asked of the agencies: 1. Approximately what percent of the total information covered in the agency's design criteria documents addresses matters covered by the national model building codes, and what percent addresses owner's requirements beyond those covered in national codes? 2. Approximately what effort would be involved in comparing the agency's documents to one of the national codes to determine points of significant difference in requirements for those matters covered in both the code and agency criteria? 3. Approximately what effort would be required to a) create a cross reference guide to the selected national model code label by labeling all appropriate parts of the agency's criteria, and b) segregate and reorganize all material in the agency's design criteria to match the organization of the model code? 4. Approximately what effort would be required to identify and remove from the agency's design criteria documents all criteria that are met or exceeded by criteria presented in one of the national model codes, and to replace the criteria removed with references to national model codes? Question 4 differs from question 3 in that administrative review and approval procedures that agencies must follow to make changes in their official criteria documents would be activated. Responses varied substantially among agencies. At one extreme was the Department of Energy (DoE). This agency has already undertaken to follow the course suggested in question 4, and reports that less than one percent of its criteria address directly matters covered in the national model codes. DoE criteria documents refer users to standards promulgated by industry consensus organizations and to the national model codes. The balance of the agency's criteria documents deal with owner's requirements outside the scope of the model codes. DoE staff estimate 51
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that the effort required to make the changes in the agency's design criteria documents exceeded 3,000 person-days of staff effort and $1.25 million of consultant assistance. The Public Health Service reported that it has in the past made substantial reference to national consensus standards and model codes, and estimates that approximately 98 percent of its criteria address matters outside the scope of model codes. The agency estimated that verification -- by review of a selected sample of their criteria documents -- that their documents contain no material that could be replaced by reference to model codes would require approximately 160 person-days. The General Services Administration (GSA), Air Force (AF), Army Corps of Engineers (CoE), and Naval Facilities Engineering Command (NAVFAC) all estimated that approximately 20 percent of the material in their criteria documents that deal with military facilities deals with matters covered in national model codes.18 These agencies all have a relatively wide range of facilities types and projects located throughout the United States. The National Aeronautics and Space Administration (NASA), which has facilities located in comparatively few geographic areas, estimated that as much as 30 percent of its criteria documents overlap with model codes, and another 30 percent cover matters similar to those covered in model codes. Approximately 40 to 80 percent of these agencies' criteria documents deal with requirements outside the scope of model codes. The CoE, NAVFAC, and GSA have by far the most extensive sets of criteria documents, and estimated the costs to each agency of following a course of action similar to that undertaken by the DoE will exceed $1.3 million for consultant assistance in the first year, and that several years of effort may be required. NASA estimated their costs would be between approximately $500,000 and $750,000. 18The Corps has an extensive program of construction of dams and other public works facilities that are not typically covered by model codes, and estimates that only ten percent of their criteria documents for such facilities overlap with codes. 52