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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
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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.
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Representative terms from entire chapter:
criteria documents