Construction Code Professionals & Compliance for Illinois Pre K-12 Schools

Prior to 2006, the process of school construction was solely dependent on the architect of record certifying the accuracy and completeness of the construction documents submitted, and certification that the construction substantially conformed with the approved documents. However, the architect was “…not required to make exhaustive or continuous on-site inspections (AIA form A-201)”. This is NOT to say architects do not or did not perform due diligence. However, plan reviews and inspections are specialized in their required skill sets and knowledge base.

In September 2005, the state required inspections for all school construction projects by ISBE qualified inspectors. In 2006, the state amended the statutes requiring plan reviews and inspections for all school construction projects by ISBE qualified plan examiners and inspectors. Today, it is not an uncommon practice for some architectural firms to perform their own plan reviews when applying for school construction permits, and in some cases, perform their own inspections. Due to a severe shortage of qualified inspectors and plan examiners, Illinois state law does provide for this practice.
However, according to the ISBE inventory, over 80% of the public PK-12 schools in Illinois were built before 1993. Where in new construction, design professionals are generally in their comfort zone for achieving compliance based on their training and experience, working in existing construction, requirements are sometimes blurred.

An existing building may be subject to as many as 6 different editions of the various codes:
Here is a PARTIAL list:
Title 23 IL ADM CODE PART 175 (Built before 7/1965)
Title 23 IL ADM CODE PART 185 (Built after 7/1965)
BOCA 1996
Title 23 IL ADM CODE PART 180
IBC 2003, 2006, 2009, (2015 eff. 1/2016)
IEBC 2003, 2006, 2009, (2015 eff. 1/2016)
IMC/IFGC 2003, 2006, 2009, (2015 eff. 1/2016)
IECC 2006, 2009, 2012, (2015 eff. 1/2016)
NFPA 101
NFPA 10
NFPA 25
NFPA 70
NFPA 72
IL ADM CODE PART 890
IL ADM CODE PART 820.

The obvious question is “Why not just follow the latest code and call it a day?” The answer is that over the years, construction materials and practices have changed and the codes were changed in an effort to keep up with the various combinations of changes. For example, 2x lumber hasn’t been 2” for decades. Codes changed to compensate for changes in structural and fire resistance values. Who remembers the first EPDM roofing systems? What about the introduction of computer LAN and WAN systems? These systems were typically installed piece-meal based on the immediate need. I can’t count the number of penetrations I have found during inspection in fire resistance rated walls that were never properly sealed.

How many people are aware that school occupant loading calculations changed over the years? Or how maximum permitted exit travel distances have changed? Or that the way we calculate required minimum exit capacity has changed several times over the years? Under Part 185 exit capacity at doors is calculated at 18”/100 persons, which would be 200 persons for a 3’-0” door and stairs were calculated at 18”/80 persons, while under Part 175, the required width changed to 22”/100 persons for doors. Then under 2006 codes, the width requirement could be as low as .15”/person if fully sprinklered and today exit capacity is based on .2” clear width/person for locations other than stairs and certain assembly configurations. Without applying the correct occupant loading values, egress capacity can be inflated. This becomes problematic, especially where so many of these facilities are not equipped with automatic fire sprinklers.

How many people realize that under Parts 185 and 175 ‘Mechanical Rooms’, which include electrical rooms, and Storage Rooms are required to be a minimum 1-hr fire resistance rated? Depending where you are standing in an existing building and the level of alteration being performed, the values to be applied and any new requirements, particularly in terms of fire detection and suppression can vary significantly. When it comes to additions and renovations, all codes require maintaining at least the original levels of protection. Without a solid working knowledge of the earlier codes, as well as how and when they are applied, this can result in hazardous conditions and expensive corrections.

ISBE qualification includes evidence of successful completion of the ICC examination for a Plans Examiner discipline or current ICC certification as a Master Code Professional, evidence of successful completion the ICC examination for an Inspector discipline or ICC certification as a Master Code Professional, written certification of at least 4,000 hours of training or experience involving plan reviews, inspection, design, construction, or maintenance of commercial buildings for compliance with applicable commercial building codes, or evidence of licensure as a design professional or structural engineer.

The plan examination and inspection processes are not just Pass/Fail. The plan examination goal is assurance that the proposed design meets or exceeds the minimum Health/Life/Safety standards for schools. Your Code Compliance professional should be ready to assist the design team to select cost effective code compliance alternatives. In the field, your Code Compliance professional should be ready to work with design and construction members to expedite resolution of field modifications and substitution issues, as well as unknown/unforeseen conditions. Speaking of unknown/unforeseen conditions, how is it adequately addressed? Your Code Compliance professional should provide you with a Life/Safety Advisory report properly identifying and categorizing deficiencies, and be ready to assist in working with the District and design team to develop a compliance plan as necessary and appropriate, including extended deferment if necessary and appropriate.

During the Construction Phase, your Code Compliance professional should be maintaining a positive, pro-active dialogue with all the stakeholders; coordinating inspections with the dynamic of a changing project schedule, working to resolve issues in the field, so when the inspector leaves the site, a failed inspection is the rare exception. The plan examiner and inspector must be a part of the team. Doing the job in a proper and professional manner, they are as much facilitators as regulators. When the construction phase is complete, your Code Compliance professional should furnish electronic and hardcopy volume of all plan examinations, inspections, observations, and Life/Safety Advisories from the project, including Building (construction safeguards, general construction, fire separation, egress capacities, travel distances, areas of refuge), Special Inspection Documentation (Geo-technical reporting, concrete and masonry testing, welded and bolted connections, fabricator shop inspections ) Accessibility, Mechanical, Electrical, Fire (detection, notification, and suppression), Plumbing, Energy, Health, OSFM (boilers, elevators) inspections.