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An engineer friend brought this to my attention yesterday.  Senator George Runner, 17th District of California, has proposed  Senate Bill 1227.  Taken from the bill:

This bill would transfer the duties of the Department of General Services with regard to design and construction of school buildings, as defined to include buildings used for elementary, secondary, and community college purposes, to the building department of the appropriate local jurisdiction.

The original text of the bill can be found here and a summary is here at the American Construction Inspectors Association website.

Background

The DSA is the Division of the State Architect.  The DSA is a department within the DGS, Department of General Services.  The DGS provides services to other state agencies, manages real estate for state owned properties and oversees the construction of schools.  The DSA provides design and construction oversight for K–12 schools and community colleges, and develops and maintains accessibility standards and codes utilized in public and private buildings throughout the State of California.  (taken from the DSA website)  Approximately 90 of the Division of the State Architect’s technical staff members are licensed Senior Structural Engineers. DSA also contracts out plan review to 100 private structural engineering companies. DSA also contracts with over 200 certified and inspected testing and inspection facilities and about 1,600 certified Project and Assistant Project Inspectors.

On a related note, hospitals get their own oversight through OSHPD, the Office of Statewide Health and Planning and Development. I worked somewhat with OSHPD during my my graduate research at the University of Nevada, Reno (Report CCEER-05-05).  Although I did not work with them extensively, from the short time I spent with them, I have the highest regard for the OSHPD engineers.  I would would have to say that the same caliber of engineer works at the DSA.

The bill that Senator Runner is proposing would modify the Field Act of 1933 (a good summary is here in pdf form).  The Field Act was conceived after the 1933 Long Beach Earthquake leveled 70 schools and damaged another 120.  The schools were unoccupied at the time.

The Field Act goes beyond the normal building code provisions by:

• Requiring better design engineer qualifications
• Ensuring better plan checker qualifications.
• Providing more thorough and consistent plan checks.
• Requiring continuous construction inspection.
• Specifying higher earthquake resistant requirements (about 15 percent higher than those called for by local building codes).
• Providing oversight by a District Engineer.
• Serving as an independent reviewer.

DSA Review Process

I have never worked with the DSA.  My only experience is second hand from fellow engineers that have worked with the DSA in permitting a school or other facility that falls under the DSA’s jurisdiction.  Designing DSA and OSHPD projects are somewhat of specialized field in California.  A licensed structural engineer must oversee the design of the project.  The engineering firms that design these facilities are industry leaders.  The review process is intense, with a DSA engineer reviewing just about every aspect of the project.  I have heard stories (the horror variety depending on whom you talk to) of the reviewer looking down to the nut and screw level.  Multiple reviews, multiple changes are normal for a DSA review project.  DSA is authorized by the Field Act to adopt and interpret rules and regulations governing public school design and construction.

In 2006, the California Seismic Safety Commission commissioned a review of the Field Act. It found the following items:

• Delays due to the length of time required by the Division of the State Architect (DSA) review processes.
• Inconsistency of interpretations of codes/regulations by the different DSA offices statewide.
• Increased costs due to the requirements of the Field Act.
• Increased costs due to delays in plan approvals and to the consistently skyrocketing costs of construction and materials.
• Discrepancies between technical accuracy of plan reviews and the interpretations of design professionals.
• No Field Act building has either partially or completely collapsed, no school children have been killed or injured in Field Act-compliant buildings

According the this op-ed in the San Diego Union Tribune, the longer review times, and increased costs, appear to be the impetus for the bill.

Local Building Department Review

I have permitted dozens of buildings and tenant improvements in California and Nevada.  Not more than 2 stories; ranging anywhere from a 20,000 sf office to a 500,000 sf warehouse, to car dealerships.

The most thorough reviews I ever had was when the local jurisdiction sent the plans out for a third party review.  I did grumble a bit as a new engineer when I would receive comments from a third party.  I thought some of the comments were just fluff; purely thrown in so that the jurisdiction could be reassured that they were getting their money’s worth.  However, many of the comments had merit.  Did the comments drastically change the building in any way?  No.  I was supervised by great engineers, asked questions throughout the design, so consequently, there were no surprises during the plan review.  But the comments did focus me in on issues I could have analyzed in more depth.

With a few exceptions, I have never received the same volume of comments, nor quality of comments, from a local jurisdiction when the jurisdiction performs the review themselves.  The exception is when the local jurisdiction had a licensed structural engineer on staff reviewing my project.

Final Word

The Union Tribune op-ed asserts the following:

1. Today’s building codes are much better
2. Municipalities do that work all the time (referring to code checking)
3. A bottleneck could be eliminated by eliminating the review process
4. Work could be done much better at the local level
5. Local control would improve the flow and might result in designs reflecting the community

First point. Undoubtedly, our building codes are getting much better.  They are also getting more complicated.  As we learn more about how buildings behave in earthquakes, we update the codes to reflect that new found knowledge.  The increasing levels of complication require continuing education, savvy engineers, contractors and inspectors whose job it is to review and implement the changes.

Second point. Municipalities are plan checking all the time, but not complicated schools or hospitals.  I would imagine anything over a couple of stories is handed off to a third-party review agency.  I would assert that the level of plan review required for an essential facility is not currently being done at the local level.

Third point. Bottle necks will be removed but at what cost? By costs, I mean intangible costs like life-safety and construction quality and not tangible costs like dollars and cents.  Continuous inspections will not be required and detailed reviews by licensed structural engineers familiar with school construction will not be performed.

Fourth point. If a local jurisdiction does not have a licensed structural engineer on staff (which I would imagine few do), the work would be farmed out to a third party reviewer.  These reviewers range from consulting firms to specialty review shops.  The work will not be done at the local level, just subbed out.

Fifth point. I have no idea what this even means.

I have only spoken to the structural engineering side of the DSA.   The DSA also looks at accessibility among a number of other functions.  I do not agree with the intent of the bill.  Removing a “bottleneck” (which I don’t think the bill would do anyway) at the expense of safety is not the way to jumpstart school construction or the economy.

The next step is a hearing set for April 14, 2010.

Tags: architect, California, California Seismic Safety Commission, Construction, Department of General Services, division of the state architect, DSA, Engineering, George Runner, law, legistlature, Office of Statewide Health and Planning, San Diego Union Tribune, sb1227, Structural engineering