NBSIR 73-186 /

Criteria and Methodology for

Examination of Analysis Agencies

for Manufactured Building

One and Two Family Dwelling Systems and Components

J. 0. Bryson, J. L. Heldenbrand, B. M. Vogei

'

Project LEAP

(Laboratory Evaluation and Accreditation Program)

Center for Building Technology

Institute for Applied Technology

National Bureau of Standards

Washington, D. C. 20234

April 1973

Preliminary Report

Prepared for National Conference of States on Building Codes and Standards

NBSIR 73-186

CRITERIA AND METHODOLOGY FOR

EXAMINATION OF ANALYSIS AGENCIES

FOR MANUFACTURED BUILDING

One and Two Family Dwelling Systems and Components

J. 0. Bryson, J. L. Heldenbrand, B. M. Vogel

Project LEAP

(Laboratory Evaluation and Accreditation Program)

Center for Building Technology

Institute for Applied Technology

National Bureau of Standards

Washington, D. C. 20234

April 1973

Preliminary Report

This report is to be superseded by a future publication which will receive general distribution and should be cited as a reference.

Please consult the NBS Office of Technical Information and

Publications to obtain the paper citation.

Prepared for National Conference of States on Building Codes and Standards

U. S. DEPARTMENT OF COMMERCE, Frederick B, Dent, Secretary

NATIONAL BUREAU OF STANDARDS. Richard W. Roberts. Director

TABLE OF CONTENTS

PAGE

PART 1 INTRODUCTION 1

Icl GENERAL 2

1.2 DESCRIPTION OF STUDY APPROACH 7

1.2 J STUDY OF CURRENT ANALYSIS FUNCTION ACTIVITIES 7

K2.2 ESTABLISHMENT OF MODEL PROCEDURE 9

1.2.3 DEVELOPMENT OF REQUIREMENTS, CRITERIA, AND

METHODOLOGY 12

1.3 STUDY LIMITATIONS 13

PART 2 ANALYSIS FUNCTION 15

2.1 DEFINITION OF ANALYSIS FUNCTION RELATIVE TO

OTHER FUNCTIONS 16

2.2 OBJECTIVES FOR THE DESIGN OF THE ANALYSIS

FUNCTION 19

2.3 DOCUMENTS OF THE ANALYSIS FUNCTION 26

2.3.1 CONTROL DOCUMENT 27

2.3.1.1 THE CONTROL MATRIX 28

2.3.1.2 THE MANAGEMENT PLAN 30

2.3.2 PERFORMANCE SPECIFICATIONS 31

2.3.3 PRODUCT DESCRIPTION DOCUMENT 32

2.3.4 COMPLIANCE ASSURANCE MANUAL 35

2.3.5 INSTALLATION DOCUMENT 36

2.4 STEPS OF THE ANALYSIS FUNCTION 38

2.4.1 PRELIMINARY MEETING '39

2.4.2 SUBMISSION OF DOCUMENTS ' 40

2.4.3 STAFFING 41

2.4.4 EVALUATION OF PRESCRIBED SYSTEMS 43

2.4.5 EVALUATION OF PERFORMANCE SPECIFICATIONS 44

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PAGE

2.4.6 EVALUATION OF INNOVATIVE SYSTEM ' 45

2.4.7 EVALUATION OF COMPLIANCE ASSURANCE MANUAL 46

2.4.8 EVALUATION OF INSTALLATION DOCUMENT . 47

2.5 APPROVAL 49

PART 3 REQUIREMENTS, CRITERIA AND METHODOLOGY FOR

EXAMINING THE ANALYSIS FUNCTION 51

3.1 GENERAL DISCUSSION 53

3.2 EXAMINING THE ANALYSIS FUNCTION 54

3.3 CRITERIA AND METHODOLOGY FOR EXAMINING THE

ANALYSIS ORGANIZATION 59

3.4 CRITERIA AND METHODOLOGY FOR EXAMINING THE

MANAGEMENT STAFF 62

3.5 CRITERIA AND METHODOLOGY FOR EXAMINING TECHNICAL

STAFF EVALUATING PRESCRIBED PRODUCT DESCRIPTION

DOCUMENTS 66

^ 3.5.1 STRUCTURAL 66

- 3.5.2 MECHANICAL (HVAC) ' 69

3.5.3 ELECTRICAL 72

3.5.4 PLUMBING 75

3.5.5 ARCHITECTURAL - HEALTH AND SAFETY 78

3.5.6 FIRE SAFETY 81

3.5.7 ACOUSTICS 84

3.6 CRITERIA AND METHODOLOGY FOR EXAMINING TECHNICAL

STAFF EVALUATING INNOVATIC PRODUCT DESCRIPTION

DOCUMENTS 87

'3.6.1 STRUCTURAL 87

3.6.2 MECHANICAL (HVAC) ' 91

3.6.3 ELECTRICAL 95

3.6.4 PLUMBING 99

3.6.5 ARCHITECTURAL - HEALTH AND SAFETY 102

3.6.6 FIRE SAFETY 106
PAGE

3.6.7 ACOUSTICS 111

3.7. CRITERIA AND METHODOLOGY FOR EXAMINING

TECHNICAL STAFF EVALUATING COMPLIANCE

ASSURANCE MANUALS 115

3*8 CRITERIA AND METHODOLOGY FOR EXAMINING

TECHNICAL STAFF EVALUATING INSTALLATION

DOCUMENTS 120

PART 4 IDENTIFICATION OF CONCERNS AND ISSUES 123

4.1 EDUCATIONAL PROGRAM 125

4.2 MANPOWER EVALUATION 126

4.2.1 EDUCATION vs. EXPERIENCE 126

4.2.2 THE ROLE OF PROFESSIONAL REGISTRATION IN

ESTABLISHING QUALIFICATIONS OF TECHNICAL

PERSONNEL 126

4.3 THE ROLE OF THE STATE 129

4.3.1 ACCREDITING BUILDING EVALUATION AGENCIES 129

4.3.2 ASSIGNMENT OF EVALUATION JOBS 129

4.3.3 ALTERNATIVE APPROVAL METHODS FOR BUILDING

SYSTEMS 130

4.4 COST AND FEES 131

4.5 LIABILITY 132

4.6 RESPONSIBILITY FOR INSPECTION IN-PLANT.

IN-TRANSIT AND ON-SITE 133

APPENDICES

A MONITORING AND AUDITING 135

B THIS IS LEAP 150

C GENERAL INFORMATION FOR INSTITUTIONS APPLYING

FOR ACCREDITATION AS ANALYSIS AGENCIES UNDER

THE MODEL MANUFACTURED BUILDING ACT 169

D APPLICATION FORM FOR INSTITUTION APPLYING TO

STATE ADMINISTRATIVE AGENCY FOR ACCREDITATION

UNDER THE MODEL MANUFACTURED BUILDING ACT 174

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E LIST OF ORGANIZATIONS SUPPLYING

INFORMATION FOR THIS STUDY

F INTERVIEW CHECKLIST

G GLOSSARY OF TERMS

ATTACHMENTS

ATTACHMENT A - CONTROL MATRIX

ATTACHMENT B - ANALYSIS FUNCTION

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ABSTRACT

Criteria are proposed by which participating institutions may

be judged for their capability to perform the Analysis function in the

evaluation and regulation of manufactured one and two-family dwellings

and components, including mobile homes. Procedures are also proposed

for use by an examining agency in determining if the criteria are met.

The criteria and methodology are intended as guidelines for objective

examination of applicant public or private institutions who desire to

serve as designees of state government in the analysis of documents

describing a given manufactured building system or component. Based on

a study of the state-of-the-art and current model enabling legislation,

a comprehensive description of the required Analysis function services

is provided as a basis for proposing a level of the criteria acceptable

to the states. Appendices describe proposed institutional mechanisms

and provide supporting information and forms. Implementation of the

proposed criteria and methodology, through the standards making work of

the ASTM E-32 Committee, is intended to provide the states with a basis

for informal reciprocity of institutional accreditations and of buildingevaluation findings.

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PART 1 INTRODUCTION

CONTENTS

IJ GENERAL

1.2 DESCRIPTION OF STUDY APPROACH

K3 STUDY LIMITATIONS
1.1 GENERAL

Building technology is changing rapidly; one manifestation of

this is the increased industrialized production of a wide range of

complex construction components and assemblies. Factory produced

building systems often involve innovative processes not specifically

described in the applicable building code and for which traditional

field experience provides little guidance for the building official.

Moreover, they may also be fabricated beyond the legal jurisdiction

of the installation site. As a result the local building official's

technical evaluation of manufactured buildings for code compliance may

be difficult, and may entail trips to distant factories for prototype

examination and periodic production line inspections.

The National Conference of States on Building Codes and Standards

(NCSBCS), formed in 1967 to consider problems of building regulation,

has suggested that the states may utilize the services and facilities

of qualified public or private institutions to provide building analyses,

testing and inspections. To aid the several states in implementing such

a process, a Department of Commerce Special Working Group developed model

legislation under the title of Model Manufactured Building Act and the

related (but separate) Rules and Regulations.

^DOC Special Working Group No. 1 was composed of representatives from

National Conference of States on Building Codes and Standards, National

Association of Building Manufacturers, Building Officials and Code

Administrators International, Inc., International Conference of Building

Officials, Southern Building Code Congress, U.S. Department of Commerce,

and U.S. Department of Housing and Urban Development.
I

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! To establish an appropriate degree of intra- and interstate

credibility regarding building system evaluations made through use of

either public or private institutions, the states may wish to utilize

an accreditation program for such institutions « For the purpose of

accreditation, the National Bureau of Standards (NBS), was asked to

- develop criteria by which participating institutions may be judged for

their capability to perform identified building-evaluation functions,

and procedures for an examining agency to use in determining if the

criteria are met. To this end, NBS has instituted a research project

identified as the Laboratory Evaluation and Accreditation Program (LEAP).

The American Society for Testing and Materials (ASTM) has been asked to

develop consensus standards for examining such institutions, based on

the Project LEAP documents.

For accreditation purposes, Project LEAP has divided the buildingevaluation services that may be performed by accredited agencies into

three distinct functions; analysis, testing and compliance assurance.

These functional terms are defined below. Additionally, for the purposes

of this report, the term Agency designates the accredited or approved

status of a public or private institution to act as an agent of the state

in the regulation of manufactured building, (e.g. Analysis Agency performs the Analysis function.)

(1) Analysis is the building-evaluation process which includes

analytical examination and review of design and test documents

using professional judgment and experience, to determine whether

a proposed manufactured building or component conforms to applicabje codes and standards.

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The Analysis function is the same as the Evaluation function

defined in the Model Manufactured Building Act, and has also

been referred to by others as Engineering Analysis and

Systems Analysis.

(2) Testing is the building-evaluation process whereby the engineering

properties claimed for manufactured buildings or components are

validated by using appropriate standard test methods or other

approved physical simulations based on recognized engineering

principles.

(3) Compliance Assurance is the building-evaluation process of appraising

the manufacturer's compliance control program, in conjunction with

full-time or periodic monitoring, surveillance or audit, implemented to provide objective evidence that manufactured buildings

or components conform to the approved design drawings and specifications.

Compliance Assurance relates to the Inspection Agency function

as defined in the Model Manufactured Building Act, and has also been

variously referred to as Quality Analysis and Quality Control.

The Compliance Assurance Manual is prepared and the program

implemented by the Compliance Assurance function and approved

by the Analysis function under the Model Manufactured Building Act.

Compliance Control Program is the manufacturer's system, including

directly related quality and process controls, for assuring

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compliance with applicable codes and standards. The Compliance

Control Document is prepared and the program implemented by the

manufacturer and approved by the Compliance Assurance function.

The Compliance Control Document is incorporated into the Compliance Assurance Manual.

For justification and description of the proposed two-part

Compliance Control /Compl iance Assurance approach, see Sections

2.3, 2.3.4, 2.4.7 and Attachment B.

This report related primarily to the first of the three functions—Analysis.

The report is compatible with and an extension of the earlier LEAP documents

on the Testing function and is largely based on a study performed for NBS

by B. A. Berkus Associates. The report is presented in four parts:

Ic Introduction

2o Analysis Function

3. Requirements, Criteria and Methodology for Examining the Analysis

Function

4. Identification of Concerns and Issues

Part 1 serves as an introduction and provides an executive summary of

the document.

Part 2 identifies the tasks and procedures performed by the model Analysis

function. In approaching this study, it was necessary to establish the

criteria for the Analysis function in relationship to the expected services

to be performed, as identified by a study of the state-of-the-art and by the

Model Manufactured Building Act and related Rules and Regulations. Therefore,

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a comprehensive description of the services to be rendered by a model

Analysis Agency is included in this section as a basis for defining an

acceptable level of criteria and the attendant methodology for examination.

Based on the requirements stemming from the identified tasks or

procedures. Part 3 details the criteria and methodology for examining

applicants proposing to serve as Analysis Agencies. Part 4 lists concerns

and issues related to the regulation of manufactured building which have

been brought into focus by this study.

Appendices are included which describe proposed institutional mechanisms

and provide supporting information, forms and a glossary of terms. In

particular. Appendix A suggests possible procedures for states to use in

monitoring and auditing the buidl ing-evaluation process (see asterisks on

Attachment B). A proposed institutional mechanism for accreditations and

for reciprocity of building evaluations is presented in outline in Appendix

B, "This Is LEAP."

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1.2 DESCRIPTION OF STUDY APPROACH

In order to develop criteria and methodology for determining the

capability of an organization to carry out any activity, that activity

Itself must first be analyzed and understood. From such an understanding,

it becomes possible to derive the organization's necessary characteristics.

This observation led to the development of a study approach consisting of

three parts:

(1) A study of current analysis function activities.

(2) Establishment of a model procedure for the Analysis function.

(3) Development of appropriate criteria and methodology for examining

institutions that desire to undertake the Analysis Function.

1.2.1 -STUDY OF CURRENT ANALYSIS FUNCTION ACTIVITIES

The study of current Analysis function activities had two separate

phases. The first was a detailed examination of the One and Two Family

Dwllinq Code^ and American National Standards Institute Standard

ANSI All 9.1 - 1972, Standard for Mobile Homes .

The second consisted of informal interviews conducted by B. A. Berkus

Associates, consultants to Project LEAP, with a selection of code enforcement agencies, building manufacturers and building professionals from across

^The One and Two Family Dwelling Code was jointly developed by the American

Insurance Association, Building Officials and Code Administrators International , Inc. (BOCA) International Conference of Building Officials (ICBO),

and the Southern Building Code Congress (SBCC).

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the nation. These interviews gathered experience and points of view

related to documents, personnel, organizations and procedures currently

used or encountered in the Analysis function.

Both phases of the study of current Analysis functions and activities

distinguished between conventional building and industrialized building

for the purpose of isolating the particular requirements imposed by the

industrialized building process.

The first phase of the study of current Analysis functions concluded

that both of the codes studied were of limited use in the establishment of

model procedures for the Analysis function for industrialized housing.

The One and Two Family Dwelling Code was found too prescriptive in

nature, confined to a limited range of building construction and thus

providing no guidelines for evaluation procedures for any kind of innovative

industrialized housing. This point is discussed more fully in PART 2

Analysis Function .

The ANSI A119.1 - 1972, Standard for Mobile Homes , while confined to

a very limited range of building types, was found to recognize the need

for a performance base by establishing a range of performance objectives to

be met by any system. It, too, however, was found to be of limited use in

establishing the model procedure, as is discussed in PART 2 Analysis

Function .

The second phase of the study of current Analysis functions, the informal

interviews, served primarily to call attention to issues and concerns of

current building process participants and building regulation personnel when

considering the regulation of industrialized building. While in no way

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exhaustive, the following is a partial list of typical concerns:

(1) Local conditions, and especially problems of safety during

construction, must still be regulated when state codes

preempt local codes. These areas must still be regulated.

(2) Current building evaluation and approval procedures are

generally reactive, and an applicant cannot often anticipate

what will be required of him.

(3) Current procedures are not efficient in accommodating technological innovation.

(4) Legal liability in the regulation of building is unclear.

(5) Third-party monitoring of compliance with regulations is

desirable and necessary.

(6) Building regulation must be viewed as an integral part of the

building process, rather than as a law enforcement activity.

The appendix contains a list of organizations interviewed. Copies of

the questionnaire are also included.

1.2.2 ESTABLISHMENT OF MODEL PROCEDURE

The establishment of a model procedure for the Analysis function

resulted from a series of meetings in which comments from the interviews

were reviewed. These comments detailed the current state-of-the-art of

the building-evaluation process and further pointed out the problems and

difficulties faced by the producer desiring approval. Incorporating these

findings, a model procedure meeting four general goals was devised. These

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four goals are:

(1) Develop a procedure which is anticipatory rather than reactive.

Thus, an applicant should have a reasonably clear idea of what

is expected of him when he initiates an application for approval.

(2) Develop a procedure which is capable of processing applications

for products at any level of preassembly. Thus, an application

for a panel or assembly, and an application for a three-dimensional

module or entire house, should be handled by the same documentation

and processing formats.

(3) Develop a procedure which is capable of processing applications

submitted by a variety of building process participants.

(4) Develop a procedure which is capable of processing applications

for approval of products involving innovative materials and/or

assemblies which are not prescribed or approved under current

building codes, as well as serving the needs of conventional

building manufacturing processes,

. The proposed model procedure is fully described in PART 2 Analysis

Function . Its main features can be summarized as follows:

(1) Organizing the Analysis function as a project-oriented,

inter-disciplinary team effort, managed by a project leader

(manager) from start to finish.

(2) Instituting a preliminary meeting of the Analysis Agency project

leader and the applicant, to determine the scope of the product

and process involved in the submission in question.

(3) Drafting a Control Document at the preliminary meeting, to guide

the subsequent analysis and approval process. This document consists

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of a control matrix (see Attachment A for one possible format)

describing the product and its code-required attributes, and a

management plan describing the applicant's role in the proposed

process.

(4) Requiring the formal submission of three documents: 1) a

Product Description Document, consisting of plans, calculations,

specifications, tests reports, etc.; 2) a Compliance Assurance

Manual, consisting of the manufacturer's Compliance Control

Document and documentation of the Compliance Assurance Agency's

program; and 3) an Installation Document, consisting of the site

Installation drawings and instructions, etc. These may be submitted all at the same time, or separately, and the model Analysis

function is designed to respond accordingly.

(5) Requiring inclusion of a proposed performance specification as a

part of the Product Description Document for innovative products

not prescribed by the applicable codes.

In addition to identifying each step in the Analysis function the

proposed model procedures indicate the Analysis Agency's relationship to two

other functions: Testing and Compliance Assurance. The Testing Agency

provides the Analysis Agency with data upon which specific evaluation can be

made. The Compliance Assurance Agency implements the monitoring inspection

procedures described in the Compliance Assurance Manual.

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1.2.3 DEVELOPMENT OF REQUIREMENTS. CRITERIA, AND METHODOLOGY

Finally, the development of appropriate criteria and methodology proceeded from a detailed analysis of the proposed Analysis function procedures

as they would apply to one and two family housing. Specifically, each

of the three submittal documents were examined in terms of the traditional

disciplines and areas of code requirements:

(1 ) Structural

(2) Mechanical

(3) Electrical

(4) Plumbing

(5) Architectural - Health and Safety

(6) Fire Safety

It should be noted here that while a pure application of the performance

concept would identify categories of code-regulated building attributes, such

as serviceability, health and safety, maintainability, etc., and would apply

them across the hardware categories of plumbing, mechanical systems,

structures, etc., the categorization proposed here is more realistic in

light of the state-of-the-art which mixes disciplines by hardware category

with disciplines by attribute category, and will probably be followed in the

staffing of an Analysis Agency. For the purposes of this study, the above

six categories will be referred to as the "building system disciplines."

In each area, the specific items to be analyzed were identified. From

an understanding of the specific requirements, it became possible to develop

the criteria and methodology for examining the personnel charged with carrying

out each activity.

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Additionally, criteria and methodology were developed for the management

of the Analysis Agency, for its coordination with the Testing and Compliance

Assurance Agencies and for the monitoring of the system.

1.3 STUDY LIMITATIONS

It is necessary here to state the limitations of this study. These

relate to two areas: limitations due to resources (time and budget), and

limitations due to scope of building types.

(1) Resources ; While the study of current analysis functions

involved the analysis of several current codes in-depth,

as well as the interviews with the model code groups,

testing agencies, building departments, government agencies,

building manufacturers, product manufacturer associations

and A/E firms, this report is neither a consensus, nor a

representative sample of opinions in the national building

regulatory community.

This report is a statement of the opinions and judgments

of the authors as informed by the interviews. The interviews served to identify problems, issues and areas of concern

and as a checklist against which to test the proposed model

Analysis Agency,

The questions of fee structure and conflict of interest are

beyond the scope of this study.

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(2) Building Types : The specific codes reviewed as part of this

.project were the One and Two Family Dwelling Code , and the

ANSI Ang.l - 1972, Standard for Mobile Homes .

While the proposed Analysis procedures are generic to

housing of all types, and in fact, to other building types

as well, the procedures used to identify the requirements

and to develop examination criteria and methodology were

those relating specifically to one and two family dwellings.

The requirements would remain essentially the same, while

the criteria may change for other building types.

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PART 2 ANALYSIS FUNCTION

CONTENTS

2.1 - DEFINITION OF THE ANALYSIS FUNCTION

RELATIVE TO OTHER FUNCTIONS

2.2 - OBJECTIVES FOR THE DESIGN OF THE

ANALYSIS FUNCTION

2.3 - DOCUMENTS OF THE ANALYSIS FUNCTION

2.4 - STEPS OF THE ANALYSIS FUNCTION

2.5 = APPROVAL

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2.1 DEFINITION OF ANALYSIS FUNCTION RELATIVE TO OTHER FUNCTIONS

The Analysis function in certification of industrialized

housing is one part of a coordinated set of procedures designed to

regulate industrialized building activity. Like all other regulation

of building, it is an exercise of the government's authority to

regulate and control certain activities which affect the public's

health, safety and welfare.

The regulation of industrialized building differs from the regulation of conventional building in several ways:

(1) Industrialized building is likely to involve pre-assembly

of parts at a location remote from the final building site.

It is also likely that such preassembly of parts could not

be inspected for code compliance at the building site without

their dismantling or disassembly. Traditional on-site inspection methods, used effectively in conventional building,

are clearly not suitable for industrialized building and must

be supplemented. This one of the impetuses for Project LEAP.

(2) Industrialized building involves the repetitive application

of a limited number of designed parts in a large number of

buildings. Since the building site is unlikely to be known

at the time of manufacture or of design, and in order to

justify the capitalization necessary for the manufacture of

industrialized building, some form of design approval

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independent of the specific building site necessary.

(3) Since industrialized buildings are likely to be marketed

across areas that transcend the jurisdiction of any one

local government, it would be uneconomical to subject them

to regulation by local building codes that differ widely

in both substance and form. This fact has given rise to

the recent promulgation of state codes for industrialized

building that preempt local building codes. For similar

reasons, efforts are currently underway to develop uniform

procedures that would contribute toward the goal of interstate reciprocity in the area of industrialized building.

(4) Industrialized building carries with it the potential for

technological innovation in both materials and processes.

Its therefore, requires regulatory procedures that are designed to accommodate such innovation, with due regard for

the public health, safety and welfare.

Responding to these distinct characteristics, regulatory procedures

for industrialized building are arranged in three function categories: • Analysis Function • Testing Function • Compliance Assurance Function

The Analysis function examines the documentation submitted by

an applicant as evidence that a particular product, or manufactured

building, is designed in accordance with applicable codes and standards.

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The Analysis function also examines the documentation submitted by

an applicant demonstrating a delivery process (manufacture, transportation, erection) which is controlled and monitored in a manner

assuring that each delivered product has been constructed in accordance with the approved design, and is thus in compliance with

applicable codes and standards. The documentation required by the

Analysis function is described in detail later. The Analysis function

concludes in the granting or the withholding of approval of either

or both the product's design and the plan which documents the program for assuring it's compliance with the applicable codes and

standards.

The Testing function operates when, for any reason, physical

tests must be performed to produce the evidence that a particular

product has been designed or manufactured in accordance with applicable codes and standards, and will usually be required when other

methods, such as calculation or observation, cannot provide such evidence

unambiguously. This evidence then becomes part of the documentation

required by the Analysis function.

The Compliance Assurance function implements monitoring procedures

that are documented in the Compliance Assurance Manual and approved

under the Analysis function, and assures the delivery of products conforming with the approved design, and thus conforming to applicable

codes and standards. (The special question of inspection during

transportation will be raised later.)

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2.2 OBJECTIVES FOR THE DESIGN OF THE ANALYSIS FUNCTION -

The Analysis function is designed to meet four objectives

which have emerged as paramount within the current state-of-the-art

of industrialized building; these are:

(1) Anticipatory rather than reactive,

(2) Applicable to a broad range of product preassembly,

(3) Capable of processing applications submitted by a

variety of building process participants, and

(4) Capable of coping with technological innovation.

Objective (1) above, responds to concerns of the often-heard criticism

of current building regulatory practice as it affects the innovative or

the non-routine; namely that it is a reactive system. It is not uncommon

for a manufacturer to initiate an application for approval without

knowing the time or effort involved. Neither is it uncommon for the

evaluating agency to request additional information, additional tests,

etc., late into the evaluation process. While this type of reactivity

cannot be eliminated entirely, there is no logical reason why a much

higher proportion of activities cannot be anticipated at the start of

the total regulation process. The first objective will be achieved,

or at least approached, by the preliminary meeting which is proposed

as the first part of the Analysis function, and which will be discussed

in detail later.
Objective (2) above, is related to the recognition that any

building can be viewed as a physical hierarachy: for example:

parts, components, assemblies, subsystems and total building.

It is clear that off-site fabrication, or preassembly, can

and does occur at any level of this hierarchy. The actual level

at which it occurs is a function of the system's design, of the

materials used, and of other technical and economic considerations.

Doors, wall panels, room modules, and whole buildings are all capable of preassembly. The distinct characteristics of the regulation

of industrialized building, discussed in the first part of this

chapter, apply equally to any of the foregoing levels of preassembly.

Yet, the substance of the documentation required by the Analysis

function must clearly vary to reflect the level at which preassembly

occurs for any particular case. The proposed Analysis function

procedures are designed to handle applications for approval of products

of a broad range of preassembly, and thus achieve this objective.

Specifically, the design and use of the proposed Control Document, to

be discussed in detail later, are essential to meeting this objective.

Objective (3) above, reflects the realities of current developments

in the building industry and reflects concerns and issues which arose

in meetings with manufacturers. While companies develop the expertise

and resources to design and manufacture complete products or building

systems, others concentrate on developing the management tools and controls necessary for ultimate delivery of the product; they assemble

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building systems from parts designed and manufactured by a number

of different companies. (Th-fs approach had been developed to an

advanced state in the aerospace industry. The term "Boeing model"

has been coined to describe the approach.) The clearest example

of such a system is the Descon-Concordia system consisting of: • A structural scheme employing a specific material

(concrete)

.

• A detailed design of joints between structural

members

.

• A set of space layouts detailing configurations and

dimensions. • A management plan consisting of performance specifications, compliance control programs and procedures

to assure appropriate assembly of a variety of possible

buildings, as well as detailed design of certain elements

(e.g., kitchens and baths within the "black box" shown in

the space layouts, thickness of certain concrete members,

etc.).

It is obvious that working drawings, compliance control and other

documentation of such a system will differ from the conventional.

The idea behind such an approach is that certain parts of a building

system.'may vary to respond to specific local market conditions (e.g.,

capabilities of local precasters, availability of packaged core modules

etc.) without impairing the system's integrity and its response to codes

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and standards. If the Descon System were used 1n two locations, each

one may vary in some details, yet there seem to be advantages to having

Descon apply for system evaluation of the "Descon System," rather than

having each local developer apply for evaluation as for a separate

system. The subsequent approval of undetermined details (yet whose

design is strictly controlled by the "system") may be either a Compliance

Assurance function, a local code function or processed as a change.

It is likely that the Descon-Concordia or Boeing model approach

represents a trend in industrialized building which will grow in the

future. Hence, the postulated goal that the evaluation procedure be

capable of coping with this approach. The proposed model procedure

responds to this goal by:

1. Requiring the development and submission of a management

plan as part of the Control Document, to describe the

applicant's role in the proposed process (Section .2.2).

2. Use of the management plan as input into the Compliance

Assurance and Installation Documents, and thus giving the

Analyn's Agency the opportunity to evaluate the interrelationships and note necessary subsequent inspections

and approvals. (Section 2.3.1.2.)

3. The use of the Control Matrix to display parts of the

building, how they relate, whether and how they are

included in the submission. (Section 2.3.1.1.)

-22-
4. Proposing Matrix Intercept Forms which permit the recording

of options, alternates and interfaces to be considered in

the evaluation. (Section 2.3.1.1.)

Objective (4) above, relates to technological innovation. This

Is most crucial for an Analysis function designed to regulate industrialized

building, since here is where industrialized building's greatest potential

lies. Most current building codes are prescriptive in nature; they fully

prescribe materials and details of assembly for a limited range of

traditional building methods. Their provisions for handling innovative

systems beyond the scope of those prescribed may be typified by the

following excerpt from the One and Two Family Dwelling Code :

Sec. R-180: The provisions of this code are not intended to

prevent the use of any material or method of construction not

specifically prescribed by this code, provided any such alternate

has been approved.

The Building Official may approve any such alternate provided

he finds that the proposed design is satisfactory and complies

with accepted design criteria.

The Building Official may require that evidence or proof be

submitted to substantiate any claims that may be made regarding

Its use.^

' One and Two Family Dwelfing Code Under the Nationally Recognized Model

Codes, 1971 Edition. Basic Building Code, Building Officials and Code

Administrators, International, Inc.; National Building Code, American

Insurance Association; Southern Standard Building Code, Southern Building

Code Congress; Uniform Building Code, International Conference of

Building Officials. Page 4

=23-
Beyond the reference to "accepted design criteria," or something

similar, most codes do not provide the building official with any

instruments to assist him in discharging this responsibility for

approval of alternates.

ANSI A119.1 - 1972, Standard for Mobile Homes is often cited as

an example of a code which does provide such an instrument:

1.4. ..An enforcement agency may approve any such alternative if

it finds the proposed design is satisfactory for the purpose

intended, and. . .is. . .at least the equivalent performance of

that prescribed in this standard considering quality, strength,

effectiveness, durability, safety, and protection of life and

health....

This goes beyond the One and Two Family Dwelling Code in that it

specifies the "purpose intended" and provides the building official

six areas of performance where equivalency must be established. The

ANSI A119.1 - 1972 proceeds to enunciate basic prinicples at the start

of at least two of its major subdivisions (Body and Frame Design and

Construction, Plumbing, Heating, Electrical). These basic principles

may be viewed as performance goals, directly related to, and derived

from, the six areas of performance mentioned above. The Standard then

lists specific requirements. However, neither the derivation of specific

^ANSI All 9.1 - 1972. Standard~for Mobile Homes . Sponsored by: Mobile

Homes Manufacturers' Association, National Fire Protection Association,

Trailer Coach Association. Page 11.

-24-
requirements from the performance goals, nor the derivation of the

latter from the six areas of performance, Is made explicit in any

way. Moreover, ANSI All 9 - 1972 permits the manufacturer to propose

tests that may prove the equivalency of performance, but without

providing the building official with any guidelines for evaluating

acceptability of those tests. The proposed Analysis function procedure responds to the fourth objective by requiring the submission

of a proposed performance specification with and application for

approval of any innovative system or part. This submission, and

its evaluation as part of the Analysis function, together will

make explicit the links between performance objective, particular

requirements and test methods, thereby providing usable instruments

for the evaluation of technological innovations.

-25-
2.3 DOCUMENTS OF THE ANALYSIS FUNCTION

The documentation required by the Analysis function can be

grouped into four basic items:

(1 ) Control Document

(2) Product Description Document

(3) Compliance Assurance Manual

(4) Installation Document.

The first of these is prepared by the applicant and the Analysis

Agency jointly and serves to control the processing of the other

three. The second and fourth documents are prepared by the applicant

and submitted for processing through the Analysis function.

The third document is developed as follows: Under the currently

proposed Model Rules and Regulations For The Model Manufactured Building

Act, the applicant is responsible for documenting the program for

controlling product compliance and the Administrative Agency or

Analysis (i .e., evaluation) Agency is responsible for approving

the program, "'t is suggested here that an intermediate step be

introduced as illustrated by the dashed lines in Attachment B.

Using the suggested approach, the manufacturer's compliance

control program is submitted in the form of a Compliance Document,

for detailed review by the Compliance Assurance function. 3 jhis

«^See, Appendix G Glossary for a proposed definition of the

Compliance Assurance Function.

-26-
document then forms the basts for preparation of, and is incorporated

Into the Compliance Assurance Manual by the Compliance Assurance

function. The Compliance Assurance Agency adds it's proposed regulatory compliance assurance program to the manufacturer's compliance control program to form a single integrated document which is submitted to

the Administrative Agency or Analysis Agency for approval. Advantages of

this two-step approach include:

(1) The Compliance Assurance function is brought into the

program at a time when it can make an effective contribution.

(2) The integrated Manual provides the Analysis function

with a more effective basis for estimating the effectiveness

of the Compliance Assurance Program and for evaluating key

inspection check points and procedures.

(3) The manufacturer and the Compliance Assurance function

document only that program for which each exercises

effective control

.

(4) Continuity between building-evaluation functions will be

enhanced, when passing from the approval to the production

stage.

The intermediate step suggested above would not effectively change

the Model Rules but would enhance continuity and clarify responsibilities.

2.3.1 CONTROL DOCUMENT

The Control Document delineates the scope of the product being
submitted for approval, the range of tf^s attributes regulated by

the applicable codes and standards, and the process by which the

concept is translated into a product. It is designed to preclude

arbitrariness in the Analysis function and to make that function

as free of surprises as possible.

The Control Document consist of two parts:

(1) A Control Matrix which describes the product and serves

as a checklist. This is accompanied by forms and

questionnaires.

(2) A Management Plan which describes the product's delivery

process.

2.3.1.1 The Control Matrix (See Attachment A) ;

The Control Matrix is a generic model of a building and its

attributes, reflecting the hierarchy of building elements. It

enables one to discuss attributes of elements at each level of the

aggregation, while retaining the hierarchial relationship. One

possible form rf the Control Matrix is suggested in Attachment A.

The horizontal axis of the Control Matrix is the hierarchical

description of the building. It provides a graphic means for

displaying the functional scope of the product proposed; by deleting

those building parts not included in the application. At the same

time, the relationship of the proposed product to the total building

can be kept in mind and referred to when necessary. The degree of

-28-
detail to which the vertical axis is carried ts purely a matter of

convenience - there is clearly no logical limit.

The vertical axis of the Control Matrix lists the regulatory

requirements for the building. These can include all the attributes

or they can be limited to those attributes regulated by a particular

code. Again, it is a matter of convenience as to how far one needs

to carry the detail, (It should be kept in mind that while certain

attributes, such as acoustics, are not regulated by most current

building codes, the scope of public environmental concerns is rapidly

expanding, and that such exclusions cannot be considered permanent.)

The Control Matrix intercepts of building elements and attributes

could also be indexed to special forms, called Matrix Intercept Forms,

which contain a variety of information such as the following:

(1) Code requirements and criteria.

(2) Name and type of document indicating the product's

compliance with the requirements (drawing, specification,

calculation, test report, sample, etc.) including indexed

references.

(3) Indication if the requirement is site-specific and/or

climate-specific, and if so, the specific load conditions

or phenomena to which it applies.

(4) Indication if the particular product or element proposed

is subject to an option or alternate of any kind (for

the user, the builder, etc.), and if so, the conditions

and ramifications of choosing them.

=29-
(5) Indication If the particular attribute or element imposes

any special interface conditions on other parts of the

building (which in turn may or may not be included in the

scope of the applicant's product.)

The Matrix Intercept Forms may eventually also include the specific

conclusions of the Analysis function, e.g., compliance or non-compliance,

degree of compliance or actual performance level, notes to various inspectors, etc. Thus, the Control Matrix and its accompanying forms indicate the scope of the proposed product, the scope of the necessary

evaluation within the Analysis function, and those building elements

which remain to be approved at the local level.

2.3.1.2 The Management Plan

In addition to the Control Matrix, the Control Document includes

a Management Plan that describes the applicant's proposed process from

raw materials acquisition to occupancy and use of the finished product

or building. It precisely defines the applicant's role in each step

of the proposed process, distinguishing between steps performed by him

directly, and those performed by others under his direct or indirect

control. The Management Plan thus provides direct input into the Compliance Assurance Document and the Installation Document discussed

below. It also draws attention to two aspects of building whifch are

regulated by current building codes and which may not appear as explicit items on the Control Matrix:

(1) Safety during erection/installation,

-30-
(2) Control of pollution or other unwanted output resulting

from the building or product in use.

2.3.2 Performance Specifications

As mentioned above, it is proposed that an applicant be required

to submit performance specifications for those products or part of

products not prescribed by the applicable codes and standards whose

design and construction process does not follow the traditional. In

most cases, this would apply to products using innovative materials,

assemblies, configurations or processes- The need to submit performance specifications is determined at the preliminary meeting

discussed in detail later and is recorded on the Control Matrix

Intercept Forms, by identifying proposed building elements not prescribed by the codes. Clearly, performance specifications may be

required for an entire submission, or for specific portions of an

otherwise conventional submission.

The performance specifications should follow the format proposed

in the Construction Specification Institute (CSI) Manual of Practice ,

MP-2D, May, 1972, "Organization and Format for Performance Specifying."

This format employs four types of statements: • Requirement Statements • Criteria Statements • Tests Statements • Commentary.

-31-
The commentary should cover the following points:

(1) The relationship of the proposed requirement to the

particular attribute regulated by the code.

(2) Support for the proposed criteria carrying out the

code's intent.

(3) Support for the proposed test's validity and reliability

in simulating the conditions regulated.

(4) Reference to subsequent documents where verification

evidence may be found.

These performance specifications provide the Analysis function

with an instrument that bridges the gap between the intent of the

code (or its explicit performance goals, if stated, as in the case

of ANSI All 9.1 - 1972 ) and unambiguous criteria for approval or

•rejection. While it may be argued that such an instrument should be

developed by an agency in the public service such as the Analysis

Agency, there are technical, administrative and historical reasons

for requesting the applicants to do so. The Analysis Agency is

still charged .'ith evaluating and accepting the proposed performance

specifications. Thus, the performance specifications developed by

applicants become as valid as those that would be developed by the

Analysis Agency.

2.3.3 Product Description Document

The Product Description Document is a complete description of

the proposed product demonstrating its compliance with the applicabl

-32-
codes and standards, and/or with the proposed performance specifications discussed above. It is prepared by the applicant in accordance

with the scope and guidelines noted in the Control Document, and is

submitted for evaluation and approval through the Analysis function.

The product Description Document consists primarily of the

traditional building design documents, which fall into two categories:

(1) Descriptive documents • drawings • schedules • specifications • samples.

- (2) Verification or support documents • calculations • test reports • standards and references.

In addition to these traditional design documents, the Product

Description Document may include an operation profile. This would

be required if the product involved any kind of operation, and if

the applicable codes and standards regulated fuel consumption and

pollution. It may very well be that such an operation profile would

ultimately become a general environmental impact statement (general,

rather than site-specific). In the least, it would be an energy input/output analysis.

-33-
2.3.4 Compliance Assurance Manual

The Compliance Assurance Manual, prepared in two-parts by the

applicant and the Compliance Assurance Agency, is a complete

description of all the procedures that must be followed to assure

that the product delivered to a building site will be indentical

to the product described in the Product Description Document and

approved in the Analysis function. When combined with the procedures described in the Installation Document below, the product's

final installation in a building will be assured to comply with the

applicable codes and standards. When approved, the Compliance

Assurance Manual forms the basis for a compliance assurance program,

implemented by a Compliance Assurance Agency, and culminating in the

affixing of a label to each individual product.

The compliance control procedures described in this document

relate to each step of the delivery process. Thus, the question

of which steps, as described in the Control Document, are to be

carried out by others, is clearly germane. The specific process

steps covered are the following:

(1) Material supply - Measures and procedures necessary to

the integrity and performance level of the supply of raw

^For a more detailed discussion of the Compliance Assurance Manual

and the Compliance Control Document, see "Criteria For Compliance

Assurance Agencies For Manufactured Building, One and Two Family

Dwelling Systems and Components," Project LEAP, April 1973.

-34-
materials and components necessary for the fabrication of

the proposed product.

(2) ^teter^a^ storage and handling - Measures and procedures

necessary to assure the integrity of raw materials and

components during their in-=plant handling and storage.

(3) Fabrication/assembly = Measures and procedures necessary

to maintain the integrity of materials and components

through the fabrication/assembly process, and to assure

that the fabrication/assembled product is in accordance

with the approved drawings and specifications.

(4) Product storage and handling - Measures and procedures

necessary to maintain the integrity of the product through

Its handling and storage prior to shipment.

(5) Product transportation - Measures and procedures necessary

to assure the proposed product's integrity throughout its

transportation to the building site.

(6) Construction - Measures and procedures necessary to

investigate faults reported by a local inspector as

being beyond local remedial action.

The manufacturer's Compliance Control Document includes the

following:

(1) Detailed layouts of the various manufacturing phases within the manufacturing facility.

(2) Shop drawings and specifications for the product.

=35-
(3) Manufacturer's inspection manuals, including a rationale

for the frequency of sampling for the various levels of

inspection.

(4) Forms for reporting, managing and monitoring the inspection

procedures.

2.3.5 Installation Document

The Installation Document is a complete description of the procedures that must be followed on the building site with regard to

the approved product's erection or installation in an otherwise

approved building, to assure that the completed building or the

erection of a complete building will conform to the applicable codes

and standards. These procedures follow sequentially those covered

by the Compliance Assurance Document as discussed above. The division

between the two documents reflects the physical distinction between

central manufacturing procedures and construction site procedures,

and the jurisdictional distinction between attributes regulated by

a state code aid those regulated by a local building code.

Since the approved product, as described by the Control Matrix,

may be somewhat less than the total building or even a complete subsystem, the Installation Document is not a complete manual for the

building inspector. It does, however, provide him with all that he

needs to know and all that he needs to inspect to assure interfaces

and site-specific attributes.

-36-
The specific process steps covered by the Installation Document

are the following:

(1) Product storage and handling on-site - Measures and procedures necessary to maintain the product's integrity

through its handling and storage on the site prior to

erection/instal 1 ation

.

(2) Erection/installation - Measures and procedures necessary

to maintain the integrity of the product and its regulated

attributes through the erection/installation process.

(3) Field testing - Measures and procedures required by the

applicable codes and standards relative to field testing

of the installed product.

The Installation Document includes the following:

(1) Product installation drawings and specifications.

(2) Inspection manuals, including the rational sequencing of

inspection and construction procedures.

(3) Forms for reporting, managing and monitoring the inspection

procedure.

=37-
t

2.4 STEPS OF THE ANALYSIS FUNCTION (see Attachment B)

The Analysis function should flow smoothly and fit into the

overall building process, the industrialized building process in

particular, in such a way as to impose a minimal constraint on its

participants in terms of both time and expense. In order to do this,

the Analysis function may be viewed as a mirror image of the design

and development process - a process with which extensive experience

exists.

This experience indicated that the most suitable organization

for the design and development process, in areas as complex as

industrialized building, is one that replaces the traditional horizontal structuring by design discipline (architecture, structure,

mechanical, plumbing, electrical, etc.) with a vertical structuring

by project. This type of project management involves the assembling

of a project team consisting of all the disciplines required to solve

the problems raised by the particular project manager who acts as the

team leader.

It is suggested that the above principles of project management

should be employed in the Analysis function, and that a project manager

be appointed for each application received. It is the project manager's

responsibility to coordinate the entire process of the Analysis function

relative to the particular application. With the benefit of recoiranendations

by his lead engineers, the project manager selects the evaluation team,

and the applicant throughout the Analysis function process.

-38-
The project manager, as the team leader, must have a detailed

understanding of the applicable codes and standards and of building

in general as both a product and a process (see Section 3.4)-

2.4.1 Preliminary Meeting

The Analysis function project manager's first task in the

proposed procedure is convening the preliminary meeting with the

applicant.

The proposed preliminary meeting precedes and formal submission

of documents. It has several purposes:

(1) To introduce the applicant to the Analysis function project

manager assigned to process his applicationc

(2) To acquaint the Analysis function project manager and lead

engineers with scope and nature of the specific application.

(3) To acquaint the applicant with the specific code-regulated

attributes of his proposed product.

(4) To establish the scope of the subsequent evaluation procedure for each building system discipline.

(5) To draw up the Control Documents discussed earlier.

The preliminary meeting is the primary instrument in achieving

the Analysis function objective of becoming an anticipatory rather

than a reactive process. It brings together the two principle parties

to the Analysis function - the applicant and the evaluator. The applicant knows and controls the scope and details of the product he is

proposing to submit for evaluation and approval, as well as the process

=39-
proposed for delivering the product to the marketplace. The evaluator

knows the scope and details of the codes and standards applicable to

the proposed product, and he controls the execution of the evaluation

procedures required by the codes and standards. Together they can

determine the required scope of the documents to be submitted and

of the subsequent evaluation procedures, so that these do not come

as a surprise at a later date.

The scope of both submission and evaluation are shown in the

various parts of the Control Document as described above. This

document could be completed in a schematic form as the preliminary

meeting progresses. It could then be completed in detail by the

applicant, by the Analysis Agency or by both.

At the conclusion of the preliminary meeting, the applicant is

in a position to prepare his Product Description Document, Compliance

Control Document and Installation Document for submission as applicable.

After the preliminary meeting with the applicant and again after

the submittal of documents, the project manager will review the scope

of submittal w.th the lead engineers for each technical discipline in

order to determine the technical resources needed and the schedule for

performing the actual analyses.

2.4.2 Submission Of Documents

The three documents that must be submitted to the Analysis function

for approval have been discussed earlier. They consist of the Product

5See "Evaluation of Compliance Assurance Manual", paragraph 2.4.7.

-40-
Description Documents the Compliance Assurance Manual and the Installation

Document.

These documents do not all have to be submitted at the same time.

It Is conceivable that an applicant may want to obtain design approval

on a proposed product prior to determining details of its production

and delivery systems. There may be good economic reasons for such an

approval, and this would require the initial submission of the Product

Description Document only. Such a design approval would not be sufficient for the marketing of the product, and to be so it would have to

be followed with the submission and approval of the other two documents

at a later date.

At the time of the submission, the Control Document is attached

to the other documents and follows them throughout the Analysis function.

Also, at this time, the appropriate fee (which may depend, as discussed

later, on the number of documents submitted on the scope of the product

as shown on the Control Matrix and on whether the product is innovative

or traditional) is collected from the applicant. The submission and fee

collection are both officially noted.

2.4.3 Staffing

The suggested staffing procedure is intended to lend the flexibility '

which is essential to efficient performance of the Analysis function,

while assuring that engineering judgment enters into the definition

of scope of effort.

=41-
Immediately following the submission of documents (or, in some

cases, possibly even proceeding it) the Analysis function project

manager with the recommendation of the lead engineers, staffs the

team that will actually evaluate the submission. The method used

for staffing should employ the specific talents and unique experiences of individuals as well as the minimum criteria proposed in

Part 3.

For the Product Description Document evaluation, staffing

requirements would be derived from the Control Matrix which could

be made to show the building system disciplines; i.e., those involved

in the product's design (architectural, structural, mechanical,

electrical, plumbing), as well as the special consulting disciplines

of fire safety and acoustics. Staffing here would also depend on

whether or not a performance specification for innovative products

must be evaluated.

For the Compliance Assurance Manual and Installation Document

evaluation, staffing requirements would be derived from the preliminary meeting and the management plan portion of the Control Document,

where the specific materials, manufacturing processes and installation

procedures are covered.

Once the staffing requirements are determined, the project manager

can assemble the team. The team may consist entirely of members of

his own organization, or may be supplemented by contract personnel from

a pool of approved technical staff. One person, properly qualified,

may also cover several disciplines.

-42-
2.4.4 Evaluation of Prescribed Systems

The evaluation of the Product Description Document for products

prescribed by the applicable codes and standards is the portion of the

Analysis function closest to the "plan-checking" activity of a

traditional building department. This activity involves the determination of completeness and consistency of the drawings, specifications,

calculations and occasional test reports, since the code describes

exactly how the product should be designed. The specific requirements here vary for each of the traditional disciplines and are spelled

out in detail in Part 3.

It will suffice to state here that structural evaluation would

Involve the checking of calculations, as well as the applicability

of specific calculations to the product as described in the drawings

and specifications. Mechanical evaluation would require similar

activities. Both of these would require the recognition of the correct

use of site-specific and climate-specific load data.

Finally, the evaluation of prescribed systems, as well as the

evaluation of every other aspect of the submission as discussed

below, requires the ability to concisely and efficiently request

additional information and/or changes if any part of the submission

Is found to be incomplete or in non-compliance. This should be done

in a manner which assists the applicant in expediting the new information.

=43-
2.4.5 Evaluation Of Performance Specifications

The evaluation of proposed performance specifications involves

two distinct steps:

(1) Ascertaining that the proposed requirements and criteria

offered by the applicant carry out the intent of the

applicable code.

(2) Verifying that the proposed tests validly and reliably

establish the product's compliance with the proposed

criteria.

The interpretation of the code's intent requires a generalist's

understanding and approach to problems of environmental regulation

and control, and familiarity with the interface between behavior and

environment. It requires the ability to translate abstractions like

adequacy, privacy, comfort, etc.* into concrete and measurable terms.

It also requires an understanding of the interaction between different

parts of the building in achieving the desired attributes.

The evaluation of proposed performance tests requires expertise

in two interrelated areas:

(1) The ability to simulate use conditions and phenomena to

which the proposed product will be subjected. Such

simulation covers the full range from mathematical analysis

to physical testing, and requires that the specimen

tested, and the procedures applied both are valid and

reliable replications of the real use conditions.

-44-
(2) The ability to anticipate modes of failure. For innovative

products J this ability is analagous to the design ability,

for it must assure that every relevant mode of failure of

the product has been covered by a criterion and has been

adequately tested.

Together, these qualifications for evaluating performance specifications

are analagous to those for a general ist designer with an analytical

background.

2.4.6 Evaluation Of Innovative System

As discussed above, innovative systems whose design and construction

process does not follow the traditional are evaluated for compliance

with performance specifications which are submitted as part of the

Product Description Document. Once the performance specification

is accepted, the evaluation of innovative systems is very similar to

the evaluation of prescribed systems described earlier, in that the

determination of completeness, consistency and mutual applicability

of drawings, specifications, calculations and test reports all are

involved. Two differences might be noted:

(1) It is likely that innovative systems would rely on test

reports for substantiation of compliance to a much greater

extent than prescribed systems. Thus, more experience in

the analysis and interpretation of test reports may be

required.

-45-
(2) Innovative structural systems, or Innovative inaterlals

used structurally, may require some non-traditional

structural calculations as part of the evidence of

compliance. The ability to check such calculations

may call for an evaluator with more experience or

theoretical background than otherwise.

2.4.7 Evaluation of Compl lance Assurance Manual

The evaluation of the Compliance Assurance Manual Is an activity

which Is unique to the regulation of manufactured building, since It

has virtually no parallel In traditional building code enforcement.

Under the Rules and Regulations for the Model Manufactured Building

Act, the responsibility for approval of the Compliance Assurance

Manual is given to the Administrative Agency or Analysis Agency.

The agency performing this function requires expertise in three

broad areas:

(1) Understanding the characteristics and attributes of the

particular materials and products employed in the application under consideration.

(2) Understanding the industrialized manufacturing processes

and monitoring and control procedures in general.

(3) Predicting the modes of failure of materials and products

undergoing processing of various kinds, so that the

measures proposed for monitoring and preventing failures

can be assessed.

»46-
Evaluating the Compliance Assurance Manual also requires, in

addition to the evaluation of the proposed Compliance Assurance

program, an assessment that the particular applicant under consideration has in fact, the technical and managerial capabilities

to implement the proposed program. As suggested in Section 2.3,

it is proposed that responsibility for the detailed assessment of

these managerial capabilities be borne by the Compliance Assurance

Agency, in conjunction with it's review of the applicant's Compliance

Control Document. Overall approval of the Compliance Assurance

Manual, including the Compliance Control Document, is then the

responsibility of the Analysis function. These relationships can

be made visible to all concerned with the help of the management

plan included in the Control Document and discussed earlier. Attach-,

ment B illustrates the submittal sequence.

2.4.8 Evaluation of Installation Document

The installation Document is intended for use by local building

inspectors, and its evaluation requires the expertise in field construction experience which such inspectors should have. The fact that

we are dealing with manufactured products, or manufactured buildings,

adds two related^ points that must be covered:

(1) The problem of safety during construction may require an

added dimension, or additional complication, in the case

of manufactured bui-ldings. Procedures for safety during

erection are covered in the Installation Document. The

evaluation of the safety procedures will require that

additional expertise be obtained by the local building

inspector.

.47.
(2) As tn the Compliance Assurance Manual evaluation, the

ability to predict the modes of failures of materials

and products undergoing a process Is germane to evaluation of the Installation Document. The only difference

Is that in this case we are talking about the field

erection process, and the expertise in that process

necessary to cover the proposed measures for monitoring

and preventing such failures.

The evaluation of the Installation Document may require that the

particular applicant, or some other party, have the technical and

managerial capabilities to implement the proposed erection/installation process; the Control Document's management plan is of use

for this purpose.

-48-
2.5 APPROVAL

The Analysis function procedure diagram (see Attachment B) shows

the Approval activity "box" as being half-in and half-out of the

heavy line area bordering the Analysis function. The reason for

this graphic peculiarity is that while it is anticipated that the

state could delegate the entire Analysis function, or any part of

1t, to an appropriate qualified private or governmental agency,

there may be legal or other constraints to delegating the actual

activity of approval. In such cases, an Analysis Agency might

recommend approval, with the state actually granting it.

Approval can be given to any one of the three documents submitted,

but only approval to all three can be viewed as a license to use the

product in actual buildings.

While it is beyond the scope of this report to discuss the

approval function in detail, it should suffice to list the possible

uses of a formal approval

(1) To be included in an application by a local builder for

a local building permit for a proposed building using

the approved product.

(2) To accompany an application by the applicant for approval

of his product in another state, with which the approving

state has a reciprocity agreement.

(3) To indicate approval of only one of the documents, for the

applicant's further use.

-49-
Finally, if approval cannot be granted for any reason, the Analysis

function should develop and document information which could be

transmitted to the applicant with the notice of non-approval, so

that any necessary remedial actions on his part would be facilitated.

Thus, in cases of non-approval, the Analysis function itself would

enhance the chances for approval at a future date. ^

-50-
PART 3 REQUIREMENTS, CRITERIA AND METHODOLOGY

FOR EXAMINING THE ANALYSIS FUNCTION

CONTENTS

3.1 = GENERAL DISCUSSION AND DEFINITIONS

3.2 - EXAMINING THE ANALYSIS FUNCTION

3.3 - CRITERIA AND METHODOLOGY FOR EXAMINING THE

ANALYSIS ORGANIZATION

3.4 = CRITERIA AND METHODOLOGY FOR EXAMINING THE

MANAGEMENT STAFF

3.5 = CRITERIA AND METHODOLOGY FOR EXAMINING

TECHNICAL STAFF EVALUATING PRESCRIBED

PRODUCT DESCRIPTION DOCUMENTS

3.5.1 - STRUCTURAL

3.5.2 = MECHANICAL (HVAC)

3.5.3 = ELECTRICAL

3.5.4 - PLUMBING

3.5.5 = ARCHITECTURAL = HEALTH AND SAFETY

3.5.6 - FIRE SAFETY

3.5.7 - ACOUSTICS

3.6 - CRITERIA AND METHODOLOGY FOR EXAMINING

TECHNICAL STAFF EVALUATING INNOVATIVE

PRODUCT DESCRIPTION DOCUMENTS

3.6.1 - STRUCTURAL

3.6.2 - MECHANICAL (HVAC)

3.6.3 - ELECTRICAL

3.6.4 = PLUMBING

3.6.5 - ARCHITECTURAL - HEALTH AND SAFETY

-51"
3.6.6 - FIRE SAFETY

3.6.7 - ACOUSTICS

3.7 CRITERIA AND METHODOLOGY FOR EXAMINING

TECHNICAL STAFF EVALUATING COMPLIANCE

ASSURANCE MANUALS

3.8 - CRITERIA AND METHODOLOGY FOR EXAMINING

TECHNICAL STAFF EVALUATING INSTALLATION

DOCUMENTS

•52-
3.1 GENERAL DISCUSSION

PART II described in detail the various functions the Analysis Agency

must perform in evaluating a building system or component. In this

part. Analysis procedures for both management and the building-system

desciplines are further broken down to identify:

Task " Procedure or element of a particular function; often

implied by the related "Requirement" and thus unstated.

Requirement - Attributes such as knowledge, skill or judgment needed to perform the task.

Criteria - Standard or limits describing the minimum

satisfactory embodiment of the stated requirement.

Methodology - Procedures for the examining agency to use in

determimng if the criteria for a building-evaluation

function are met by an applicant institution.

The methodology of examining the Analysis Agency's capabilities to

perform these functions requires a two-phase review. The first

involves the management functions and the second involves the technical

j capabilities of the staff.

The Analysis Agency may be a public or private organization or combination of the two. This is to be determined by the desires of the

particular state. The Agency may be approved to provide services

and facilities for evaluating either prescriptive or innovative manufactured building systems, or both. The Agency may be staffed fully

or depend, in part, upon consultants and specialists as the need

arises.

'For definitions of the terms Architect, Engineer and Engineering

Technican as used in this report, see Appendix G Glossary.

°53-
It is anticipated that a number of specialists may be approved indepen

dently, providing a pool of personnel for the building-system evaluation process. However, in order to qualify as an Analysis Agency,

lead engineers from each of the building-system disciplines must be

either on the staff or under contract for the purposes of providing

engineering judgment during the preliminary screening process.

Engineering judgment is necessary to determine the level of technical

competence needed to do the actual building-evaluation work in each

disciplinary area.

Proposed examinations of individual capabilities (Sec. 3.2) should result in approvals of management personnel and technical specialists

which are recognitions of the actual individuals performing the evalua

tion rather than the firms themselves. Approvals should be given for

a definite period with re-examination at intervals.

While examination of management and technical specialists may be

reasonably objective, certain criteria for examining the Analysis

Agency are subjective in nature. These include adequate facilities to accomodate the required technical personnel, support staff

and technical library. In addition, the management's professional

background should be reviewed for any potential conflicts of interest.

3.2 EXAMINING THE ANALYSIS FUNCTION

An institution designed to carry out the Analysis function requires

both management/organizational capabilities and competent technical

-54-
personnel to perfonn the bull ding -system evaluations. Figure 1 illustrates the proposed approach to examining the organizational and personnel

capabilitieSe

Examination of the Analysis function is performed by an approved

Institution Examining Agency (lEA)^ in accordance with standard criteria

and methodology. The examining agency goes through a two-step process:

• Advance Submittal • On-Site Visit

During the Advance Submittal Phase, the examining agency reviews information provided by the applicant on the application form^ and its

attachments. This review may include a check of technical references

and followup of other sources of pertinent information suggested by the

-applicant. The application form includes questions covering the

following attributes of the applicant institution: • Organizational Structure and Procedures • Facilities • Related Experience • Technical Resumes

® Subcontractors

For additional details on the proposed Institution Examining Agency

refer to the brochure Appendix B "This is LEAP."

3a proposed application form is included in the Appendix. To assist

the applicant in interpreting the application form and the requirements

of the institutional accreditation program, a suggested "General

Information..." sheet has also been included.

=55-
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-56-
If the completed application reflects a critical limitation in

technical capability in relation to the standard criteria, such limitation is brought to the attention of the applicant.

The examining agency schedules an On-Site Visit after all critical

deficiencies in the Advance Submittal have been resolved. The purpose

of the visit is to collect information, photographs and impressions

that can best be obtained through personal interviews and observations.

4

The examiner is aided in preparing for the On-Site Visit by means of

an examiner training program and through his detailed review of the

Advance Submittal.

Examination of the organizational aspects of the Analysis function is

based on procedures which are readily available and which are expected

- to change very little after startup of the process. However, as

illustrated in Figure 1, the examination approach for Analysis personnel

is depicted as undergoing a change between the time of start-up of the

program (see NOW) and a more advanced stage (see FUTURE).

In the advanced stage, a "National Board of Building System Evaluators"

is envisioned, consisting of several peer groups coming together for

the purpose of conducting a volunteer examination program for certifying

building-system evaluators. .Several groups would be needed to adequately

4

' For a more detailed description of procedures to be used by the

examiner, see "Methodology for Examining Testing Laboratories," NBSIR

73-22, June 1972.

°57-
represent the varying concerns ranging from the technican to the professional-specialist^, and covering prescriptive and innovative systems.

At the advanced stage, the examination work of the lEA would primarily

be directed to the organizational aspects of the Analysis function, and

perhaps to serving as the secretariat to the "National Board of Building

System Evaluators." However, since this National Board does not yet

exist, the startup mode would require the lEA to perform a more

cursory examination of an individual's technical qualifications and provide a conditional certification of technical competence based largely

on education, related experience, references and examples of previous

work. The conditional certification would expire ( ) year(s)^

after the initiation of peer group certification.

The end product of the examining agency's work is a report of findings

regarding the technical capability of the applicant institution to

function as an Analysis Agency. This report is used by the Administrative Agency or it's designee as one of the bases'' for granting or

denying accreditation of the applicant institution to act as an Analysis

Agency.

For related work already going on in other fields, see T. deS. Furman,

"Specialty Registration for Engineers?^" Civil Engineering - ASCE,

December 1972.

^Time period to be determined by NCSBCS.

7

It is proposed that examination of the non-technical, business-related

aspects of the Criteria be conducted by the State Administrative Agency

or its designee. See Section 4.3 The Role of the State and Appendix B This Is LEAP, under "Administrative Agency."

-58-
Recommendations for the standard to be used by the Institutional

Examining Agency are described in detail in the following task-oriented

sections: • Criteria and Methodology for Examining the Analysis Organization • Criteria and Methodology for Examining the Management Staff • Criteria and Methodology for Examining Technical Staff

Evaluating Prescribed Product Description Documents • Criteria and Methodology for Examining Technical Staff

Evaluating Innovative Product Description Documents • Criteria and Methodology for Examining Technical Staff

Evaluating Compliance Assurance Documents and, • Criteria and Methodology for Examining Technical Staff

Evaluating Installation Documents.

Each section is arranged by Task , Requirement, Criteria and Methodology.

3.3 CRITERIA AND METHODOLOGY FOR EXAMINING THE ANALYSIS ORGANIZATION

Requirement - Provide physical, administrative and financial framework

for successfully managing the Analysis function.

Criteria -

A. Facilities - Provide adequate facilities to house

support technical personnel, including:

Task definitions are included only where necessary to clarify the

Requirements.

-59-
1. Conference space for use of entire

evaluation team and meetings with applicants.

2. Space and facilities for plan checking.

3. Equipment for calculations and for checking

of calculations.

4. A suitable technical library.

5. Equipment for typing reports and correspondence.

6. Storage facilities for correspondence and

reports.

B. Support Staff - Provide adequate secretarial,

administrative and managerial staff to support

the activities of technical personnel.

C. Information - Provide effective methods for

keeping the professional staff technologically

current.

D. Financial Capability - Demonstrate the availability of adequate financial resources to support

the required facilities, staff and activities. .

E. Conflict of Interest - Provide positive evidence

of a total absence of potential financial conflict

of interest. (See Appendix A Monitoring and

Auditing, for a discussion of this issue.)

F. Experience - Provide a substantial background of

successful completion of similar work.

-60-
Methodology -

A. Facilities - Adequacy of facilities shall be verified

by submitted evidence , and by a field inspection of

the applicant's facilities

,

B. Support Staff - Adequacy of support staff shall be

verified by submission of a management and

organizational chart,

C. Information - Availability of current technological

information shall be verified by:

1. Memberships in professional and technical

societies .

2. Subscription to technical and research

publications

.

3. Participation of professional staff in relevant

continuing education programs.

Financial Capability - Adequacy of financial

resources shall be verified by financial statements

and bank references

.

7 E. Conflict of Interest - Absence of financial sources

for conflicts of interest shall be verified by

financial statements and other evidence.

F, Experience -Successful similar experience shall be

verified by project histories and references. Pro-

-61-
ject histories shall indicate specific activities

performed by the agencies , and measures of success.

They shall also indicate work done by the agency's

own professional staff and work done by contract.

Care shall 2>e taken in interpreting term "similar

experience in light of the newness of the field

of industrialized building evaluation, as well as

the potentials of technological transfer from other

fields.

3.4 CRITERIA AND METHODOLOGY FOR EXAMINING THE MANAGEMENT STAFF

Task - Provide the services of a project manager in the Analysis

function, including:

A. Convening and Conducting the Preliminary Meeting -

For the purpose of familiarizing the applicant with the

Analysis function, and familiarizing himself with

the forthcoming application.

B. Assisting in Preparation of the Control Document -

To establish the scope of the submission and the

evaluation effort.

C. Determining Need for Performance Specification

Submission - Assessing the extent of innovation

Involved in the forthcoming submission in terms

of identifying any part of the proposed product

that is beyond the scope of prescribed systems.

-62-
D. Staffing of the Analysis Function - Selecting

the appropriate team to undertake the forthcoming evaluation, consisting of in-house staff

^nd consultants.

Ec Scheduling the Analysis Function Activities -

Preparation of a complete management plan for the

forthcoming Analysis function effort.

Fc Monitoring Progress of Analysis Function Activities

To keep it on schedule and performing effectively.

6. Establishing Contact with Applicant - To become

the sole point of contact for receiving and

transmitting information, raising and responding

to questions, etc.

Requirements -

A. General Expertise in Building Systems and Systems

Building - Experience and familiarity with the state

of-the-art of new developments in building hardware

and in the building process.

B. Knowledge of Codes and Standards - Thorough understanding of building codes and standards.

C. Knowledge of the Analysis Function - Thorough

understanding of the Analysis Agency (of which he

Is a part) as well as all details of the Analysis

function procedure.

=63=
.-^.S TRTTERTA AND METHODOLOGY FOR EXAMINING TECHNICAL STAFF EVALUATING

PRESCRIBED PRODUCT DESCRIPTION DOCUMENTS

3.5.1 Structural

Task - Assess the following aspects of the submission against the

applicable code for sufficiency:

A. Load Capacity - such as:

1. Vertical Loads

a. Dead Load

b. Live Load

c. Snow Load

d. Soils - Generally based on an assumed soil load

2. Lateral Loads

a. Wind Load

b. Seismic Load

3. Transportation and Handling

(The Compliance Assurance and Inspection Document should

be coordinated with this item.)

B. Stiffness

1. Deflection Limitation

C. Local Damage Resistance

Using :

A. Engineering Drawings - Including plans, elevations,

sections and details

-66-
C. Abi 1 i ty - Adequate performance on an examination

related to the requirements.

D. Desirable traits

1. A Building Generalist - An individual with

experience enabling him to view the building

process from several points of view; i.e.,

owner, builder, design professional, etc.

2, Experience in dealing with and managing professional personnel, including work assignment

and scheduling.

Methodology ~

A. Education - Shall be verified by certified proof

of graduation or other written confirmation

,

B. Experience - Shall be verified by submission of a

detailed resume including a minimum of three

references. In addition, capability shall be

demonstrated in the form of previous reports and

tests .

C. Examination - May be written or oral (before

a board.) The applicant shall answer adequately

questions relating to each of the requirements

.

Failure on any one of the requirements shall be

deemed failure of the examination ^ This examination shall test synthesis as well as analysis

ability.

=65-
F. Knowledge of the Analysis Process - Understanding and

appreciation of the Analysis unction process.

Criteria -

A. Education - A bachelor's degree- in civil engineering

with specialized course work in structures.

B. Experience

1. One year as a structural plan check engineer,

or proposal evaluator;

or 2. Two years as a structural design engineer;

or 3. Two years of field structural engineering

experience.

. C. Abi 1 i ty - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation.

B. Experience - Shall be verified by submission of a

detailed resume including a minimum of three

references .

C. Examination - May be written or oral (before a

board) . The applicant shall answer adequately

questions relating to each of the requirements

.

Failure on any one of the requirements shall be

deemed failure of the examination.

-68-
B. Engineering Calculations

C. Test Reports = May relate to a particular subsystem

or subassembly within the structure.

D. Materials and Product Specifications - Only partially

complete in the Product Description Document. Complete

specifications will be used by the Compliance Assurance Agency, and accompany the Compliance Assurance

Manual

.

E. Site and climate-related load data.

Requirements -

A. Knowledge of Codes and Standards - Knowledge of structural

provisions of the applicable codes and standards, including geographic distribution of various load conditions including packing, vibrations, and others

imposed during transportation.

B. Knowledge of Structural Engineering - Understanding of

conventional structural engineering principles and

practices.

C. Ability to Interpret Drawings - Ability to read and

interpret drawings for code compliance, completeness,

and coordination with calculations.

D. Analytical Ability - Ability to evaluate calculations

for compliance with the applicable codes and standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

and specification requirements^

-67-
E. Site- and climate-related load data.

F. Operation profile (energy input-output).

Requirements -

A. Knowledge of Codes and Standards - Knowledge of the

mechanical provisions of the applicable codes and

standards, including geographic distribution of

various load conditions.

B. Knowledge of Mechanical Engineering - Understanding

of accepted mechanical engineering practices, including equipment operation under dynamic conditions.

C. Ability to Interpret Drawings - Ability to read and

interpret drawings for code compliance and completeness.

D. Analytical Ability - Ability to evaluate calculations

for compliance with applicable codes and standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

and specification requirements.

F. Knowledge of the Analysis Process - Understanding and

appreciation of the Analysis function process.

Criteria -

A. . Education - A bachelor's degree in mechanical engineering

B. Experience

1. One year as a mechanical plan examiner or

proposal evaluator;

or 2. Two years as a mechanical design engineer.

-70-
3.5.2 MECHANICAL (HVAC)

Task - Assess the following aspects of the submittal against the

applicable code for sufficiency:

A. Adequacy For Use

1. Thennal Comfort

2. Ventilation

3. Extreme Temperature

B. Operation

1. Ease of Service

2. Economy of Maintenance

C. Health, Safety, and Fire Safety

1. Accident Prevention

2. Ignition Prevention

D. Energy Consumption and Pollution

Using :

A. Engineering Drawings including plans, elevations,

sections and details.

B. Engineering Calculations.

C. Test Reports - May relate to a particular subsystem or

subassembly within the mechanical systems.

D. Material and Product Specifications and Manufacturers'

Literature - Only partially complete in the Product

Description Document. Complete specifications

accompany the Compliance Assurance Document.

=69-
3.5.3 Electrical

Task - Assess the following aspects of the submission against the

applicable code for sufficiency:

A. Adequacy For Use

1. Illumination

2. Spatial Relationships (Arrangement

B. Operation

1 , Ease of Service

2. Economy of Maintenance

C. Health, Safety, and Fire Safety

le Accident Prevention

2. Ignition Prevention

3. Vermin Penetration Resistance

D. Energy Consumption

Using ;

A. Drawings including plans, elevations, sections and

detai 1 s.

B. Calculations.

C. Test Reports - May relate to a particular subsystem

or subassembly within the electrical systems.

D. Material and Product Specifications - Only partially

complete in the Product Description Document. Complete specifications accompany the Compliance

Assurance Manual

.

-72-
NOTE: In lieu of Engineering degree, 5 years of

mechancal plan examiner experience or 5

years as a mechanical contractor may be

substituted.

C. Ability - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation.

S. Experience - Shall be verified by submission of a

detailed resume including a minimum of three

references .

C. Examination - May be written or oral (before

& board,) The Applicant shall answer adequately

questions relating to each of the requirements

.

Failure on any one of the requirements shall be

deemed failure of the examination.

=71"
or 2. Two years of additional journeyman experience

may be substituted for the plan examining

experience.

C. Abi 1 i ty - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education ~ Shall be verified by certified proof of

graduation or other written confirmation.

B. Experience - Shall be verified by submission of a

detailed resume including a minimum of three

references

.

C. Examination ~ May be written or oral (before a

board). The Applicant shall answer adequately

relating to each of the requirements . Failure

on any one of the requirements shall be deemed

failure of the examination.

-74-
Requirements -

Ae Knowledge of Codes and Standards - Knowledge of

electrical provisions of the applicable codes and

standards.

B. Knowledge of Electrical Practices - Understanding

of conventional electrical construction principles

and practices.

C. Ability to Interpret Drawings - Ability to read

and interpret drawings for code compliance, completeness and coordination with calculations.

D. Analytical Ability - Ability to evaluate the calculations for compliance with the applicable codes and

standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

and specification requirements.

Fc Knowledge of the Analysis Process - Understanding and

appreciation of the Analysis function process.

Criteria -

A. Education - Equivalent to graduation from high

school. Some junior college or trade school

(Engineering) training desirable.

B. Experience

le One year as an electrical plan examiner and

five years as a journeyman electrician;

=73-
Requirements -

A. Knowledge of Codes and Standards - Knowledge of

plumbing provisions of the applicable codes and

standards.

B. Knowledge of Plumbing Practices - Understanding of

^ conventional plumbing systems and practices.

C. Ability to Interpret Drawings - Ability to read

and interpret drawings for compliance with the

applicable codes and standards.

D. Analytical Ability - Ability to evaluate calculations for compliance with the applicable codes and

standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

and specification requirements.

F. Knowledge of the Analysis Process - Understanding

and appreciation of the Analysis function process.

Criteria -

A. Education - Equivalent to graduation from high

school. Junior college or trade school training

desirable.

B. Experience

1. Eight years field experience including five

years as a journeyman or master;

or 2, One year plumbing plan examination and five

years as a journeyman plumber;

"76-
3.5.4 Plumbing

Task - Assess the following aspects of the submission against the

applicable code for sufficiency:

A. Adequacy For Use

1. Spatial Relationships (Arrangement)

2. Configuration

B. Operation

1 . Ease of Service

2. Economy of Maintenance

C. Health and Safety

K Sanitation

2. Fire Resistance

3. Foreign Media Penetration Resistance

Dc Water Conservation (possible future requirement)

Using:

A. Drawings including plans elevations, sections and

details.

B. Calculations (where applicable).

C. Test Reports - May relate to a particular subsystem or

subassembly within the plumbing systems.

D. Material and Product Specifications -- Only partially

complete in the Product Description Document. Complete

specifications accompany the Compliance Assurance

Documents.

0
3.5.5 Architectural - Health and Safety

Task " Assess the following aspects of the submission against the

. applicable code for sufficiency:

A. Adequacy For Use

1. Dimension/Configuration

2. Spatial Relationships

3. Adequacy for Storage

4. Illumination

5. Acoustics

6. Ventilation

7. Thermal Comfort

8. Foreign Media Penetration

B. Durabil ity

1. Deterioration Resistance

2. Economy of Maintenance

3. Ease of Service

C. Health and Safety

1. Dimension/Configuration

2. Sanitation

3. Accident Prevention

Using :

A. Drawings including plans, elevations, sections,

details and schedules.

-78-
or 3. Four years of plumbing design experience.

C» Ability - Adequate performance on an examination

related to the requirements.

Methodology -

A, Education - Shall be verified by certified proof

of graduation or other written confirmation.

S. Experi ence - Shall be verified by submission of a

detailed resume including a minimum of three

references

.

C. Examination - May be written or oral (before

a board). The applicant shall answer adequately

questions relating to each of the requirements

.

Failure on any one of the requirements shall be

deemed failure of the examination.

0 -11"
Criteria -

A. Education - Equivalent to two years of engineering

or arcKitecture.

Bo Experience

1. One year plan evaluation experience;

or 2. Two years building design experience.

C. Abil 1 ty - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof of

graduation or other written confirmation.

B. Experience - Shall be verified by submission of a

detailed resume including a minimum of three references

.

C. Examination - May be written or oral (before a board)

.

The applicant shall answer adequately questions relating to each of the requirements . Failure on any

one of the requirements shall be deemed failure of

the examination.

=80-
B. Area and other dimensional calculations.

C. Test Reports = May relate to a particular subsystem

or subassembly within the total building.

D. Material and Product Specifications - Only partially

complete in the Product Description Document. Complete specifications accompany the Compliance

Assurance Document.

Ec Samples.

Requirements -

A. Knowledge of Codes and Standards - Knowledge of archi

tectural and health and safety provisions of the

applicable codes and standards.

Be Knowledge of Construction Practices - Understanding

of conventional construction principles and practices

C. Ability to Interpret Drawings - Ability to read and

interpret drawings for code compliance, completeness,

coordination with calculations, and consistency.

D. Analytical Ability - Ability to evaluate dimensional

calculations for compliance with the applicable codes

and standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

and specification requirements.

F. Knowledge of the Analysis Process - Understanding and

appreciation of the Analysis function process.

•=79-
and standards including site-related attributes

imposed by Fire Zone locations.

B. Knowledge of Fire Safety Practices - Understanding

of conventional fire safety practices.

C. Ability to Interpret Drawings - Ability to read

and interpret drawings for code compliance, completeness, coordination and accuracy.

D. Analytical Ability - Ability to evaluate calculations

for compliance with the applicable codes and

standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

requirements. Review test specimens for compliance

with test reports.

F. Knowledge of the Analysis Process - Understanding and

appreciation of the Analysis function process.

Criteria -

A. Education - High school or equivalent; additional

junior college training desirable.

B. Experience

1. One year plan review experience;

or 2. Two years as a fire prevention officer.

C. Abil ity - Adequate performance on an examination

related to the requirements.

-82-
3.5.6 Fire Safety

Task Assess the following aspects of the submission against the

applicable code for sufficiency:

A. Egress Adequacy

Fire Resistance

Flame Spread (Combustibility)

Smoke Generation

Toxicity

Fuel Content

Ignition Prevention

Dimension/Configuration

Fire Protectlves (Fire doors windows, etc.)

Using :

A. Drawings including plans, elevations, sections,

details and schedules.

B. Calculations.

C. Test Reports - May relate to a particular subsystem

or subassembly within the building.

D. Material and Product Specifications - Only partially

complete in the Product Description Document.

Complete specifications accompany the Compliance

Assurance Document.

Requirements -

A. Knowledge of Codes and Standards - Knowledge of

fire safety provisions of the applicable codes

=81-
3.5.7 Acoustics

Introductory statement - Acoustic requirements did not form an

explicit part of the codes surveyed for this study nor are they

included in most current building codes. However, the current

trends in codes, standards and other guidelines (e.g., FHA standards) indicate a growing concern for acoustical environmental

quality, and it is for this reason that the following requirements and criteria are included here.

Task - Assess the following aspects of the submission against

the applicable code for sufficiency:

Ac Control of sound generating parts of

the proposed system (e.g., mechanical

equipment).

B. Control by parts of the proposed system of

sounds generated within the dwelling by

normal use.

C. Control by parts of the proposed system of

sounds generated outside the dwelling.

Using :

A. Drawings including plans, elevations, sections,

details and schedules.

B. Calculations.

C. Test Reports - May relate to a particular

subsystem or subassembly within the building.

=84-
D, Material and Product Specification ^ Only partially

complete in the Product Description Document.

Complete specifications accompany the Compliance

Assurance Document.

E. Site-related data (ambient noise levels),

Fc SamplesRequirements -

Ac Knowledge of Codes and Standards - Knowledge of

acoustic provisions of the applicable codes and

standards including site-related attributes imposed

by ambient noise levels as a function of proximity

to noise-generating sources.

' Be Knowledge of Acoustics Practices - Understanding

of conventional architectural acoustics practices.

C. Ability to Interpret Drawings - Ability to read

and interpret drawings for code compliance, completeness, coordination and accuracy.

D. Analytical Ability - Ability to evaluate calculations for compliance with the applicable codes and

standards.

E. Ability to Evaluate Reports - Ability to evaluate

test reports for validity and compliance with code

requirements. Review test specimens for compliance

with test reports.

-85-
F. Knowledge of the Analysts Process - Understanding

and appreciation of the Analysis function process.

Criteria -

A. Education - Equivalent to graduation from high

school. Some junior college or trade school

(engineering) training desirable.

B. Experience

1. One year plan review experience and three

years of acoustic product testing, development related experience;

or 2. Two years of additional acoustic product

experience may be substituted for the plan

review experience.

C. Ability - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation.

B. Experi ence - Shall be verified by submission of a

detailed resume including a minimum of three

references

.

C. Examination - May be written or oral (before a

board) . The applicant shall answer adequately

questions relating to each of the requirements.

Failure on any one of the requirements shall be

deemed failure of the examination.

-86-
3.6 CRITERIA AND METHODOLOGY FOR EXAMINING TECHNICAL STAFF

EVALUATING INNOVATIVE PRODUCT DESCRIPTION DOCUMENTS

3.6.1 Structural

I. Performance Specffication Evaluation

Task " Assess the adequacy of the performance specifications

to carry out the intent of the applicable code.

Subtask I " Assess the requirements and criteria for adequacy.

Using :

A. Code Intent Statement - An explicit statement

of the intent of the applicable code with regard

to structural safety and serviceability. The

intent should describe the general concepts of

loads and stiffness, as well as durability, and

the health and safety requirements.

B. Performance Specifications - Comparison with

previous performance specifications.

C. Reference Material - Applicable reference materials

such as other codes and standards, similar specifications, technical books and journals.

D. Interface With Conventional Materials - A review

of connection materials and their environment.

Determine need for special connections or protective

measures.

=87-
Requirements -

A. Knowledge of Code - Knowledge of the i ntent of the

applicable code. Thorough understanding of the

intent of the structural provisions of the applicable code, as well as an understanding of the

general concepts of health and safety requirements.

B. Knowledge of Research Methods - Access to related

reference material and understanding of reference

search methods.

C. Advanced Structural Concepts - Knowledge of stateof-the-art advanced structural concepts. Awareness

of current structural research relative to the

material and process.

D. Design Perception - Design perception relative to

the proposal must be used to anticipate potential

areas of incompatabil ity. Areas of potential

failure relative to the structure, other systems

and the occupants should be anticipated and

reviewed.

E. Building Process - Understanding how the constraints

of procurement leadtime and accessibility for sequential assembly operations influence the design

selection of components and their interface connections.

-88-
Subtask II - Assess the proposed tests for adequacy in demonstrating compliance vritPi the proposed criteria.

Using :

A. Detafled test method write-ups of each proposed

test.

B. Proposed structural calculation theory.

C. Texts on the rationale and history of structural

calculation and simulation methods.

Requirements -

A. Proposals for Performance Testing - Ability to

evaluate the appropriateness of the test method

proposed for the innovative system or material

in terms of validity, reliability, sampling, etc.

B. Results of Performance Testing - Knowledge of

testing, equipment and methods and evaluation of

testing to performance specifications. An understanding of test methods and their applicability

to different materials is essential.

C. Accepted Engineering Procedures - Knowledge of

accepted engineering prcedures and their applicability procedures and their applicability to

new and innovative materials. The appropriateness

of analysis by calculations versus physical testing for these materials is a critical analysis

phase determination.

=89-
Criteria -

A. Education - A bacPielor^s dagree. in civil engineering

with- specialization in structures.

B. Experience

1. Four years of recent structural plans evaluation

experience with a minimum of one year in evaluatin

innovative materials and systems;

or 2. Five years in recent structural design experience

including a minimum of two years in the design

and evaluation of innovative systems.

NOTE: A master's degree may be substitutued for

one year of the required experience.

C. Ability - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation.

B. Experience - Shall he verified by submission of a

detailed resume including a minimum of three

references . In addition, capability shall be demonstrated in the form of previous reports and tests.

C. Examination - May be written or oral (before a

board). The applicant shall answer adequately questions relating to each of the requirements. Failure

-90-
on any one of the requirements shall be deemed

failure of the examination. This exam shall

test synthesis as well as analysis ability,

11. Product Evaluation

Requirements, criteria and methodology here are the same as those for

Prescribed Product Description Documents (See 3.5.1), except that the

evaluation uses the proposed and approved performance specification

instead of the codes and standards.

Since calculations and test reports with innovative systems may be

more complicated, the evaluator must have the ability to follow and

assess such calculations and test reports.

3.6.2 MECHANICAL (HVAC)

I. Performance Specification Evaluation

Task - Assess the adequacy of the performance specifications

to carry out the intent of the applicable code.

Subtask I - Assess the proposed requirements and criteria for adequacy.

Using ;

A. Code Intent Statement - An explicit statement of the

intent of the applicable code with regard to thermal

and atmospheric comfort and environmental impact as

well an an understanding of the general health and

safety requirements.

Be Performance Specifications - Comparison with previous

performance specifications.

C. Reference Material - Applicable reference materials such

=91-
as other codes and standards, simtlar specifications,

technical books and Journals.

D. Interface with Conventional Materials - A review of

connection materials and their environment. Determine

need for special connection or protective measures.

Requirements -

A. Knowledge of the Intent of the Applicable Code - Thorough

understanding of the intent of the mechanical provisions

of the applicable code. The intent should describe the

general concepts of ventilation and comfort, as well as

durability, and health and safety.

B. Access to Related Reference Material - Adequate reference

material and understanding of reference search methods.

C. Advanced Mechanical Systems Concepts - Knowledge of the

state-of-the-art advanced mechanical systems concepts.

Awareness of current heating, ventilating and air condition

ing research relative to the material and processes in

question.

D. Design Perception - Design perception relative to the

proposal to anticipate potential areas of incompatibility.

Areas of potential failure relative to the mechanical

systems and the occupants should be anticipated and reviewed.

E. Building Process - Understanding how the constraints of

procurement leadtime and accessibility for sequential

assembly operations influence the design selection of

components and their interface connections.

.92-
Subtask II - Assess the proposed tests for adequacy in demonstrating

compliance with the proposed criteria.

Using :

A. Detailed test method writeups of each proposed

test.

B. Texts on the rationale and history of thermal and

atmospheric testing, calculation and simulation.

Requirements -

A. Proposals for Performance Testing - Ability to evaluate

the appropriateness of the test method proposed for the

innovative system or material in terms of validity,

reliability, sampling, etc.

B. Results of Performance Testing - Knowledge of testing,

equipment and methods and evaluation of testing to

performance specifications. An understanding of test

methods and their applicability to different materials

is essential

,

C. Accepted Engineering Procedures - Knowledge of accepted

engineering procedures and the applicability to new

and innovative materials. The appropriateness of

analysis by calculations versus physical testing for

these materials is a critical analysis phase determination.

A. Education - A bachelor's degree in mechanical engineering.

B. Experience

1. Four years of recent mechanical plans evaluation

experience with a minimum of one year in evaluating

-93=

Criteria
Innovative materials and systems

or 2. Five years in recent mechanical design experience

including a minimum of two years in the design

and evaluation of innovative systems.

NOTE: A master's degree may be substituted for

one year of the required experience.

C. Abil ity - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation,

B. Experience - Shall be verified by submission of a

detailed resume including a minimum of three references.

In addition, capability shall be demonstrated in the

form of previous reports and tests.

C. Examination - May be written or oral (before a board).

The applicant shall answer adequately questions relating to each of the requirements. Failure on any

one of the requirements shall be deemed failure of

the examination. This examination shall test synthesis

as well as analysis ability.

COMMENTARY: Design experience of innovative systems

should involve new methods and materials

rather than the assembly of standard "catalog"

i terns

.

-94-
n. Product Evaluation

Requirements, criteria and methodology here are the same as those

for Prescribed Product Description Documents (See 3.5.2), except

that the evaluation uses the proposed and approved performance

specification instead of the codes and standards.

Since calculations and test reports may be used more extensively

with innovative systems and may be more complicated, the evaluator

must have the ability to follow and assess such calculations and

test reports.

3.6.3 Electrical

I. Performance Specification Evaluation

Task » Assess the adequacy of the performance specifications

to carry out the intent of the applicable code.

Subtask I - Assess the proposed requirements and criteria for adequacy.

Using :

A. Code Intent Statement = An explicit statement of the

applicable code with regard to electrical serviceability

and safety. The intent should describe the general concepts

of illumination, as well as durability and the health and

safety requirements.

B. Performance Specifications - Comparison with previous

performance specifications.

C. Reference Material - Applicable reference materials such

as other codes and standards, similar specifications,

technical books and journals.
D. Interface with Conventional Materials - A review of

connection materials and their environment. Determine

need for special connections or protective measures.

Requirements -

A. Knowledge of the Intent of the Applicable Code -

Thorough understanding of the intent of the electrical

portions of the applicable code as well as an understanding of the general concepts of health and safety

requirements.

B. Access to Related Reference Material - Adequate reference

material and understanding of reference search methods.

C. Advanced Electrical Concepts - Knowledge of the stateof-the-art of advanced electrical concepts. Awareness

of current electrical research relative to the material

and process in question.

D. Design Perception - Design perception relative to the

proposal must be used to anticipate potential areas

of incompatibility. Areas of potential failure relative

to the electrical systems and the occupants should be

anticipated and reviewed.

/ E. Building Process - Understanding how the constraints of

procurement leadtime and accessibility for sequential

assembly operations influence the design selection of

components and their interface connections.

-96-
Subtask n - Assess the proposed tests for adequacy in demonstrating

compliance with the proposed criteria.

Using :

A. Detailed test method write-ups of each proposed test.

B. Text on the rationale and history of electrical testing,

calculation and simulation.

Requirements -

Ac Proposals for Performance Testing - Ability to evaluate

the appropriateness of the test method proposed for the

innovative system or material, in terms of validity,

reliability, sampling, etc.

B. Results of Performance Testing - Knowledge of testing,

equipment and methods and evaluation of testing to

performance specifications. An understanding of test

methods and their applicability to different materials

is essential

.

C. Accepted Engineering Procedures - Knowledge of accepted

engineering procedures and the applicability to new and

innovative materials. The appropriateness of analysis

by calculations versus physical testing for these materials

is a critical analysis phase determination.

Criteria =

A. Education - A bachelor's degree in electrical engineering.

B. Experience -

1. Four years of recent electrical plans evaluation

experience with a minimum of one year in evaluating

Innovative materials and systems;
or 2. Five years in recent electrical design experience

including a minimum of two years in the design and

evaluation of innovative systems.

NOTE: A master's degree may be subsituted for one

. year of the required experience.

C. Abil ity - Adequate performance on an examination related

to the requirements.

Methodology -

A. Education - Shall be verified by certified proof of

graduation or other written confirmation.

B. Experience - Shall be verified by submission of a detailed

resume including a minimum of three references. In addition

,

capability shall be demonstrated in the form of previous

reports and tests.

C. Examination - May be written or oral (before a board)

.

The applicant shall answer adequately questions relating

to each of the requirements . Failure on any one of the

requirements shall be deemed failure of the examination.

This examination shall test synthesis as well as analysis

ability.

11. Product Evaluation

Requirements, criteria and methodology here are the same as those for

Prescribed Product Description Documents (See 3.5.3), except that the

evaluation uses the proposed and approved performance specification

instead of the codes and standards.

-98-
Since calculations and test reports with innovative systems may

be more complicated, the evaluator must have the ability to

follow and assess such calculations and test reports.

3.6.4 Plumbing

I. Performance Specification Evaluation

Task - Assess the adequacy of the performance specifications

to carry out the intent of the applicable code.

Subtask I - Assess the proposed requirements and criteria for adequacy.

Using :

Ao Code Intent Statement - An explicit statement of the intent

of the applicable code with regard to plumbing network

serviceability and effectiveness. The intent should

describe the general concepts of spatial relationships

as well as the health and safety requirements.

Be Performance Specifications - Comparison with previous

performance specifications.

C. Reference Material - Applicable reference materials such

as other codes and standards, similar specifications,

technical books and journals.

D. Interface with Conventional Materials - A review of connection

materials and their environment. Determine need for special

connections or protective measures.

Requirements -

A. Knowledge of the Intent of the Applicable Code -

Thorough understanding of the intent of the plumbing

portion of the applicable code as well as an understanding

=99-
of the general concepts of health and safety requirements.

B. Access to Related Reference Material - Adequate reference

material and understanding of reference search methods.

C. Advanced Plumbing Engineering Concepts - Knowledge of

the state-of-the-art of advanced plumbing concepts.

Awareness of current plumbing research relative to the

materials and processes in question.

D. Design Perception - Design perception relative to the

proposal to anticipate potential areas of incompatibility.

Areas of potential failure relative to the structure, other

systems and the occupants should be anticipated and reviewed.

E. Building Process - Understanding how the constraints of

procurement leadtime and accessibility for sequential

assembly operations influence the design selection of

components and their interface connections.

Subtask II - Assess the proposed tests for adequacy in demonstrating

compliance with the proposed criteria.

Using :

A. Detailed test method write-ups of each proposed test.

Be Texts on the rationale and history of plumbing system

testing, calculation and simulation.

Requirements -

Ac Proposals for Performance Testing - Ability to evaluate

the appropriateness of the test method proposed for the

innovative system or material in terms of validity, reliability, sampling, etc.

B. Results of Performance Testing - Knowledge of testing,

-100-
equipment and methods and evaluation of testing to

performance specifications. An understanding of test

methods and their applicability to different materials

1s essential

.

Accepted Engineering Procedures - Knowledge of accepted

engineering procedures and the applicability to new and

innovative materials. The appropriateness of analysis

by calculations versus physical testing for these materials

is a critical analysis phase determination.

Criteria

A. Education - A bachelor's degree in either civil or

mechanical engineering.

B. Experience

1. Four years of recent plumbing plans evaluation

experience with a minimum of one year in evaluation of

innovative materials and systems;

or 2. Five years in recent plumbing design experience

including a minimum of two years in the design .

and evaluation of innovative systems.

NOTE: A master's degree may be substituted for one

year of the required experience.

C. Abil ity - Adequate performance on an examination related

of the required experience.

Methodology -

Ac Education - Shall be verified by certified proof of

graduation or other written confirmation,

B. ^Experience - Shall be verified by submission of a

-101-
detailed resume Including a minimum of three re"

ferences. In addition , capability shall be demonstrated

in the form of previous reports and tests

C. Examination - May be written or oral (before a board)*

The applicant shall answer adequately questions relating to each of the requirements. Failure on any

one of the requirements shall be deemed failure of

the examination. This examination shall test synthesis

as well as analysis ability,

II. Product Evaluation

Requirements, criteria and methodology here are the same as those

for Prescribed Product Description Documents (See 3.5.4), except

that the evaluation used the proposed and approved performance

specification instead of the codes and standards.

Since calculations and test reports with innovative systems may be

more complicated, the evaluator must have the ability to follow

and assess such calculations and test reports-.

3.6.5 ARCHITECTURAL - HEALTH and SAFETY

I, Performance Specification Evaluation

Task - Assess the adequacy of the performance specifications

to carry out the intent of the applicable code.

Subtask I - Assess the proposed requirements and criteria for adequacy.

Using :

A. Code Intent Statement - An explicit statement of the intent

of the ,appl icable code with regard to comfort, health and

-102-
safety, adequacy for use, etc. The intent should describe

the general concepts of spatial relationships for usability,

comfort, adequacy for use, as well as durability and health

and safety requirements.

B. Performance Specifications - Comparison with previous

performance specifications.

C. Reference Material - Applicable reference materials such

as other codes and standards, similar specifications,

technical books and journals in the area of human factors,

domestic accidents, comfort, etc.

D. Interface with Conventional Materials - A review of connection

materials and their environment. Determine need for special

connections or protective measures.

Requirements -

A. Knowledge of the Intent of the Applicable Code - Thorough

understanding of the intent of the general provisions of

the applicable code.

B. Access to Related Reference Material - Adequate reference

material and understanding of reference search methods in

the areas of human factors, comfort, etc.

C. Advanced Building Concepts - Knowledge of the state-of-theart of advanced building concepts. Awareness of current

building research if relative to the material and process

in question, as well as to advanced spatial concepts.

De Design Perception - Design perception relative to the

proposal to anticipate potential areas of incompatibility.

Areas of potential failure relative to any part of the

"103-
building and the occupants should be reviewed.

E. Building Process - Understanding how the constraints of

procurement leadtime and accessibility for sequential

assembly operations influence the design selection of

components and their interface connections.

Subtask II - Assess the proposed tests for adequacy in demonstrating

Compliance with the proposed criteria.

Using :

A. Detailed test method write-ups of each proposed test.

It is assumed that most architecture, health and

safety tests, except those for weathering and deterioration,

will be observation tests of architectural drawings, models

or full scale buildings.

;B. Texts on the rationale and history of human factors

and comfort testing, calculation and simulation, as

well as physical testing of building components.

Requirements -

A. Proposals for Performance Testing - Ability to evaluate

the appropriateness of the test method proposed for

the innovative system or material, in terms of validity,

reliability, sampling, etc.

B. Results of Performance Testing - Knowledge of testing,

equipment and methods and evaluation of testing to

performance specifications. An understanding of test

methods and their applicability to different materials

is essential

.

-104-
C. Accepted Building Procedures - Knowledge of accepted

procedures and the applicability to new and innovative

materials. The appropriateness of analysis by calculation

versus physical testing for these materials is a critical

analysis phase determination.

Criteria -

A. Education - A bachelor's degree in architecture or

engineering.

Be Experience

1. Four years of recent architectural (health and safety)

plans evaluation experience with a minimum of one year

in evaluating innovative materials and systems;

or 2. Five years of recent building design experience

including a minimum of two years in the design

and evaluation of innovative systems.

NOTE: A master's degree may be substituted for one

year of the required experience.

C. Abil ity - Adequate performance on an examination related

to the requirements.

Methodology -

A. Education -= Shall be verified by certified proof of

graduation or other written confirmation.

B, Experience - Shall be verified by submission of a

detailed resume including a minimum of three references.

In addition, capability shall be demonstrated in the

form of previous reports and tests,

Ce Examination - May be written or oral (before board),

0

-105-
The applicant shall answer adequately questions

relating to each of the requirements » Failure on

any one of the requirements shall be deemed failure

of the examination. This exam shall test synthesis

as well as analysis ability,

II. Product Evaluation

Requirements, criteria and methodology here are the same as those

for Prescribed Product Description Documents (See 3.5,5), except

that the evaluation uses the proposed and approved performance

specification instead of the codes and standards.

Since calculations and test reports with innovative systems may

be more complicated, the evaluator must have the ability to follow

and assess such calculations and test reports.

3.6.6 Fire Safety

I. Performance Specification Evaluation

Task . - Assess the adequacy of the performance specifications

to carry out the intent of the applicable code.

Subtask I - Assess the requirements and criteria for adequacy.

Using :

A. Code Intent Statement - Ana explicit statement of

the intent of the applicable code relative to life

safety, structural protection and durability, and

protection of building and contents in case of fire.

B. Performance Specification - Comparison with previous

performance specifications.

-106-
Ce Fire research Reference Material ° Applicable reference

materials such as other codes and standards » similar

specifications, technical books and journals.

Dc Interface with Conventional Materials - A review of

connection materials and their environment. Determine

need for special connections or protective measures.

Requirements -

A. Knowledge of the Intent of the Applicable Code -

Thorough understanding of the intent of the life

safety provisions of applicable codes as well as

an understanding of the general concepts of health

and safety requirements,

B. Access to Related Reference Material - Adequate reference

material and understanding of reference search methods

in fire research.

C. Advanced Fire Safety Concepts - Knowledge of the stateof-the-art of advanced fire concepts. Awareness of current

research relative to the material and process in question.

D. Design Perception - Design perception relative to the

proposal, to anticipate potential areas of incompatibility.

Areas of potential failure relative to fire hazard and its

effects on life safety and the integrity of the structure

should be anticipated and reviewed.

E. Building Process - Understanding how the constraints of

procurement leadtime and accessibility for sequential

assembly operations influence the design selection of

materials, components and their interface connections.

-107-
F. Systems Approach - Knowledge, understanding and use of

the systems approach to fire safety.

Subtask II - Assess the proposed tests for adequacy in demonstrating

compliance with the proposed criteria.

Using :

A. Detailed test method write-ups of each proposed test.

B. Texts on the rationale and history of fire testing,

calculation and simulation.

Requirements -

A. Proposals for Performance Testing - Ability to evaluate

the appropriateness of the test method proposed for the

innovative system or material, in terms of validity,

reliability, sampling, etc.

B. Results of Performance Testing - Knowledge of testing,

equipment and methods, and evaluation of testing to

performance specifications. An understanding of test

methods and their applicability to different materials

is essential

.

C. Accepted Fire Safety Engineering Procedures - Knowledge

of accepted fire safety engineering procedures and

applicability to new and innovative materials.

Criteria -

A. Experience/Education

1. Eight years of recent fire safety plans evaluation

experience with a minimum of one year in evaluating

innovative materials and systems ;

or 2. Nine years in recent fire and safety design experience

including a minimum of two years in the design and

-108-
©valuation of innovative systems.

NOTE? a. A bachelor's degree 1n an appropriate

scientific or engineering specialty

may be substituted for a maximum of

four years of the required experience,

b. A master's degree in the appropriate

specialty may be substituted for an

additional year of required experience.

Co A bachelor's degree in fire protection

engineering may be substituted for a

maximum of five years of the required

experience,

d. Design experience should be broadbased

rather than design of one system such as

automatic fire sprinklers.

Be Abil ity «• Adequate performance on an examination

related to the requirements.

Methodology -

Ac Education - Shall be verified by certified proof of

graduation or other written confirmation^

S. Experience - Shall be verified by submission of a

detailed resume including a minimum of three

references^

Ce Examination - May be written or oral (before a board) .

The applicant shall answer adequately questions relating

to each of the requirements^ Failure on any one of the

requirements shall be deemed failure on the examination

°109-
This examination shall test synthesis as well

as amdysis ed>ility^

Comtentary: Fire engineering is extremely diverse

and involves many disciplines and areas

of expertise. As a result, no one formal

degree could define the appropriate in~

dividual^ Therefore, experience is the

perferred qualification with credit given

for education where appropriate

,

II. Product Evaluation

Requirements, criteria and methodology here are the same as those

for Prescribed Product Description Documents (See 3.5.6), except

that the evaluation uses the proposed and approved performance

specifications instead of the codes and standards.

Since calculation and test reports with innovative systems may be

more complicated, the evaluator must have the ability to follow

and assess such calculations and test reports.

-no-
3.6.7 Acoustics

I. Perfonnance Specification Evaluation^

Task - Assess the adequacy of the performance specifications

to carry out the intent of the applicable code,

Subtask I - Assess the requirements and criteria for adequacy.

Using ;

A. Code Intent Statement - An explicit statement

of the intent of the applicable code relative to

acoustical comfort.

B. Performance Specifications - Comparison with previous

performance specifications.

C. Acoustical Research Reference Material - Applicable

reference materials such as other codes and standards,

similar specifications, technical books and journals.

D. Interface with Conventional Materials - A review of

connection components and their acoustical environment. Determine need for special isolation.

Requirements -

A. Knowledge of the Intent of the Applicable Code -

Thorough understanding of the intent of the acoustic

provisions of the applicable code as well as an

understanding of the general concepts of health and

safety and comfort requirements.

Be Access to Related Reference Materials - Adequate

reference material and understanding of reference

search methods in acoustical research.
C. Advanced Acoustics Concepts -Knowledge of the stateof-the-art of advanced acoustics concepts. Awareness

of current research relative to the material and process in question.

D. Design Perception - Design perception relative to the

proposal to anticipate potential areas of incompatibility. Areas of potential failure relative to sound

generation, sound attenuation and sound isolation

should be anticipated and reviewed. In particular,

this must include a keen awareness of the relationships

between interior and exterior ambient noise levels,

sound generation and acoustic environments.

E. Building Process - Understanding how the constraints

of procurement leadtime and accessibility for sequential

assembly operations influence the design selection of

material s, components and their connections.

F« Systems Approach - Knowledge, understanding and use of

the systems approach in acoustical analysis.

Subta^k II - Assess the proposed tests for adequacy in demonstrating

compliance with the proposed criteria.

A. Detailed method write-ups of each proposed test,

B. Texts on the rationale and history of acoustical

testing, calculation and simulation.

Requirements -

A. Proposals for Performance Testing - Ability to evaluate

the appropriateness of the test method proposed for

the innovative system or material in terms of validity.

-112-
reltability, sampling-j etc.

Be Results of Performance Testing = Knowledge of

testings equipment and methods and evaluation of

testing to performance specifications. An understanding of test methods and their applicability

to different materials is essential.

Cc Accepted Architectural Acoustics Procedures -

Knowledge of accepted acoustical engineering

procedures and the applicability to new and

innovative materials is necessary.

Criteria -

Ac Education - A bachelor's degree in physics, architectural engineering or architecture.

Be Experience

Ic Four years of recent acoustic plans evaluation

experience with a minimum of one year in evaluating

the acoustical attributes of innovative materials

and systems;

or 2. Five years of recent architectural acoustics

design experience including a minimum of two

years in the design and evaluation of innovative

systems

,

NOTE: A master's degree may be substituted for

one year of required experience.

C. Ability - Adequate performance on an examination

related to the requirements.

=113-
Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation.

B„ Experience ~ Shall be verified by submission of a

detailed resume including a minimum of three

references. In addition, capability shall be

demonstrated in the form of previous reports and

tests .

C. Examination - May be written or oral (before a

board) . The applicant shall answer adequately

questions relating to each of the requirements

Failure on any one of the requirements shall be

deemed failure on the examination. This examination shall test synthesis as well as analysis

ability.

II. Product Evaluation

Requirements, criteria and methodology here are the same as those for

Prescribed Product Description Documents (See 3.5.7), except that the

evaluation uses the proposed and approved performance specifications

instead of the codes and standards.

Since calculation and test reports with innovative systems may be

more complicated, the evaluator must have the ability to follow

^nd assess such calculations and test reports.

»114-
3.7 CRITERIA AND METHODOLOGY FOR EXAMINING TECHNICAL STAFF

EVALUATING COMPLIANCE ASSURANCE MANUALS

Under the Model Manufactured Building Act and the attendant Pules

and Regulations, the Analysis (i.e. Evaluation) Agency is charged

with approving the Compliance Assurance Manual. The TaskSg Requirements, Criteria and Methodology for fulfilling this responsibility apply as well to the Compliance Assurance Agency task of

review of the manufacturer's Compliance Control Document. It is

the responsibility of the Analysis function to review and approve

both the Compliance Assurance Manual and the incorporated Compliance

Control Document, particularly as they relate to the specific concerns

brought out during analysis of the other submittal documents. (See 2.3.)

Task = Assess the following aspects of the Compliance Assurance

Manual relative to the product's code compliance:

Ac Integrity of Raw Material Supply - Verification of

methods for acceptance or rejection of incoming

materials for damage and compliance with purchase

documents.

Be Integrity of Raw Materials Storage and Handling -

Verification that equipment and facilities for storage

and handling of raw materials has been provided for.

Storage facilities should provide weatherproof space

for materials that may be damaged by weather and

materials whose moisture content must be controlled.

C. Assembly/Fabrication - Checking of fabrication or

assembly sequence for appropriateness of inspection

=115-
locations. Verification that systems are not covered

prior to any required test or inspection. The system

should be reviewed for the appropriate means of replacing or repairing unacceptable materials to control

damage or disassembly of previously accepted portions.

Dc Product Storage and Handling - The method of storage

and handling accepted products prior to shipment must

be reviewed for adequacy. The method of weatherproofing

units to be stored outside, the means of transporting

the units from the assembly area to the storage area, and

the ongoing means of rechecking the product's integrity

during storage must be checked.

E. Product Transportation - The method of transporting the

product from the assembly site to the installation site

must be reviewed. Some items to be checked include:

potential impact loads on all the building systems;

required bracing and anchoring in-transit; adequacy of

weather protection in-transit; and height and width of

units based on transportation means.

Using :

A. Approved Design and Shop (fabrication) Drawings -

The design drawings are part of the Product Description

Document. Fabrication drawings, while helpful, may not

be available at the time of consideration of the Compliance Assurance Manual.

B. Specifications and Manufacturer's Literature -

More complete specifications than those approved with

»116-
the Product Description Document are utilized

In this review. Manufacturer's installation

literature is also used at this point.

Cc Manufacturer's Inspection Manual - (Part of the

Compliance Control Document —- See 2. 3. 4) The

document detailing inspection tasks to be performed

at various assembly and subassembly points is

reviewed for completeness.

D. Tests -= Verification tests on various building

materials and systems and their appropriateness,

E. Plant and Manufacturing Process Layout Drawings.

Requirements -=

Ac Understanding of Materials in Proposed System -

Experience with the specific materials proposed, such as their characteristics and attributes.

B. Understanding of Production Techniques Applicable

to Specific Submission - Knowledge of construction

assembly and fabrication,

C. Ability to Read and Interpret Drawings and other

Documents - Understanding of engineering design

drawings, specifications and other documents

(inspection manual, etc.). Ability to evaluate

such manuals and drawings for sufficiency.

D. Applicability of Proposed Tests ° Review of test

proposed for appropriateness as well as frequency,

type of sampling, and other test parameters.

Ec Understanding of Quality Assurance Theory - General
appreciation and understanding of quality

assurance methods and concepts and an understanding of their application to the specific compliance

assurance process proposed.

Fo Ability to Anticipate Modes of Failure - The process

design perception providing the evaluator with an

understanding of where materials and products undergoing a process may fail , and leading to the understanding

of need for preventative measures, monitoring or inspection.

Task n - " Assess the manufacturer's capabilities to Implement

and to manage the proposed processes covered in the

Compliance Control Document.

Using :

A. Management plan of the Control Document.

B. Compliance Control Section of the Compliance

Assurance Manual

.

Requirement - Understanding of Process Management - The ability to

judge an organization's capability to perform, based

on its management and administrative structure.

Task III - Assess the adequacy of the Compliance Assurance

Agency's program to monitor and to communicate

the effectiveness of the manufacturer's compliance

control program.

Using :

A. Management plan of the Control Document.

B. Compliance Assurance Section of the Compliance.

-118-
Assurance Manual.

Requirement = Understanding of the Compliance Assurance Function

and the inten-relationshipsof responsibH Ity and

authority between the manufacturer, the buildingevaluation agencies, and the Administrative Agency

Citeria -

A« Education - A bachelor's degree in one of the following:

Ic Architect and Engineer

2c Quality Assurance Engineer

3. Industrial Engineer

B. Experience -

1. Two years construction or factory production

experience with the various raw materials proposed,

or 2. Two years experience and understanding of tests

and test methods relative to construction

c

Cc Abil ity - Adequate performance on an examination

related to the requirements.

Methodology -

Ac Education - Shall be verified by certified proof

of graduation or other written confirmation^

S. Experience = Shall be verified by submission of a

detailed resume including a minimum of three

references^

Ce Examination - May be written or oral (before a board) .

The applicant shall answer adequately questions relating to each of the requirements shall be deemed

failure of the examination^
3.8 CRITERIA AND METHODOLOGY FOR EXAMINING TECHNICAL STAFF

EVALUATING INSTALLATION DOCUMENTS

Task - Assess the following aspects of the Installation

Document related to:

A. Site Product Storage and Handling - The method

of storage and handling products to their

erection/installation must be reviewed for

adequacy. The method of weatherproofing

products to be stored outside, the means of

transporting products from the storage area

to the building, and the ongoing means of rechecking the product's integrity during storage

and handling must be checked.

B. Erection/Installation - Methods of erecting and/

or install ating the product in the building,

including equipment, personnel, etc., must be

reviewed. Special attention must be paid to

safety during erection.

C. Occupancy Completion - Items requiring completion

prior to occupany and issuance of any certificate

of occupancy must be assessed.

Using :

A. Installation Drawings - Drawings detailing the

various steps of installation of the unit.

B. Specifications - More complete specifications

than those approved under the Product Description

^ Document are used in this review.

-120-
Ce Inspection Manual -= The Inspection manual detailing

the required inspections for installation of the

product.

D. Field Test - Field test schedule for tests required

by the particular design and specified codes and

standards.

Requirements -

A. Ability to Read and Interpret Construction Drawings -

Understanding of such drawings, specifications, inspection manuals, etc, and ability to evaluate their

sufficiency.

Be Understanding of Site Construction Procedures .

Ce Familiarity with Required Field Tests - Knowledge of

code-required tests and how they fit into the construction procedures and schedule.

Dc Ability to Anticipate Modes of Failure - The construction

process design perception providing the evaluator with

an understanding of where materials and products undergoing field construction processes may fail. This may

involve structural design perception to anticipate

structural failure during erection.

Criteria -

A. Education -

Ic High school or equivalent.

2, Degree in engineering may be required in some

cases.

B. Experience - Five years of construction experience

-=121-
In a supervisory position.

C. Ability - Adequate performance on an examination

related to the requirements.

Methodology -

A. Education - Shall be verified by certified proof

of graduation or other written confirmation^

B. Experience - Shall be verified by submission of

detailed resume including a minimum of three

references .

C. Examination - May be written or oral (before a

board). The applicant shall answer adequately

questions relating to each of the requirements.

Failure on any one of the requirements shall be

deemed failure of the examination.

-122-
PART 4 IDENTIFICATION OF

CONCERNS AND ISSUES

CONTENTS

4.1 ° EDUCATIONAL PROGRAM

4.2 = MANPOWER EVALUATION

4.2.1 ° EDUCATION vs. EXPERIENCE

4.2.2 " THE ROLE OF PROFESSIONAL REGISTRATION IN

ESTABLISHING QUALIFICATIONS OF TECHNICAL

PERSONNEL

4.3 ° THE ROLE OF THE STATE

4.3.1 » ACCREDITING BUILDING AGENCY

4.3.2 » ASSIGNMENT OF EVALUATION JOBS

4.3.3 » ALTERNATIVE APPROVAL METHODS FOR BUILDING

SYSTEMS

4.4 COSTS AND FEES

4.5 - LIABILITY

4.6 - RESPONSIBILITY FOR INSPECTION IN-PLANT,

IN-TRANSIT AND ON-SITE

-123-
PART 4

This current study has focused attention on concerns and issues

related to the regulation of industrialized building, some of which

would benefit from further study and research and others which could

be handled by the development of additional model rules and regulations.

The following list is not arranged in any order of priority nor is it

Intended to be exhaustive.

0 =124-
4.1 EDUCATIONAL PROGRAM

Manufactured building regulation and its component activities

of Analysis, Testing and Compliance Assurance are not subjects

directly and fully covered by any current educational curriculum,

whether professional, technical or vocational. Development of

training programs for building officials at various levels could

be based on the requirements, criteria and methodology that re=

suit from the standards-making process described in Section Id.

It also could benefit from an extensive survey of current eductional programs at both professional and vocational levels to find

the applicable state-of-the-art. Such a program could have both

Immediate and long-range benefits, in terms of both staffing

Analysis Agencies with capable personnel, and in the long run improving the Analysis function itself.

=125-
4.2 MANPOWER EVALUATION

If brought to reality, the proposed "National Board of Building

System Evaluators" (See 3.1) would face the necessity for dealing

with several issues of which only the key ones will be suggested

here.

4.2.1 Education vs. Experience

The proposed criteria and methodology indicate education and

experience required to carry out various activities. While these

recommendations are firm in some areas and tentative in others, the

entire issue of the tradeoff between education and experience is

one which is open to question. This is endemic to the whole regulatory process and is exacerbated in manufactured building

regulation because of its novelty.

Further study might delve into this issue in-depth, attempting

to identify the separate parameters of building education and building

experience as they relate to the specific activities of industrialized

building regulation.

4.2.2 The Role of Professional Registration in Establishing Qualifications

of Technical Personnel

Some current state registration laws for professional engineers and

architects fall short of meeting the regulatory needs of manufactured

building in one or more of five areas:

1. Non-uniformity of state laws and registration exams leading to

' -126-
a lack of universal reciprocity of registrations. State

regtstration laws and examinations which restrict their

scope to the environmental requirements peculiar to the

subject state » may preclude acceptance of professional

registrations by reciprocity in states having more

stringent environmental requirements. A manufacturer

marketing buildings in a regional area may find his

product inacceptable in states having greater environmental design requirements.

2e Limited scope of competency levels» covering only professional

engineers and architects. The majority of work associated

with building system evaluations of the prescriptive type are

carried on today by sub-professional technicians not covered

under professional registration laws. At the other end of

the scales, certain specialist or "super-professional " engineers not included in current registration catagories may be

needed to evaluate innovative building systems dealing with

new materials or processes.

3e Limited scope of disciplines . Present registration examination

practices do not recognize all of the necessary building system

disciplines. Due to other purposes being served by the registration lawSs the trend is in the opposite direction in some states,

with registrants being recorded only as a "Professional Engineer,"

etCe

-=127-
4. No evaluation of technical obsolescence . With few exceptions

the state registration laws do not deal with the problem of

technical obsolescence. In the assessment of current competence,

particularly that needed for evaluating innovative manufactured

building, a re-examination period or other procedure needs to be

incorporated in order to maintain the viability of certification

of individual technical competence.

5. Knowledge and use of building codes and standards is not assessed

by most registration examinations for professional engineers.*

As has been pointed out, there is a need for specialty certification

of building evaluation personnel on a regional or national basis, with a

built-in mechanism for avoidance of technical obsolescence. The question

needs to be resolved as to whether registration as a professional engineer

by the several states can or should have a place in the objective assessment

of technical competence to perform the specific building evaluation functions

proposed in this report, or should simply be noted for the benefit of those

states which may require registration for legal purposes. In addition, the

time period before requiring re-examination or other updating assessment,

needs to be established.

California 's written examination for registered Structural Engineer

Is one exception.

-128-
4.3 THE ROLE OF THE STATE

4.3.1 Accrediting Building Evaluation Agencies

Among the issues that need to be resolved is the role of the state

in accrediting building evaluation (i .e., Analysis, Testing^ Compliance

Assurance) agencies. One possible approach is outlined in Appendix B

"This Is LEAP" where it is suggested that the State Administrative

Agency or its designee should conduct any non-technical investigations

of applicant institutions, i .e., investigations which relate to business

operations, independence of judgment, etc. However, since these

attributes may be at least as important as technical competence, criteria

and methodology should be developed for such non-technical examinations

as a basis for objectivity and reciprocity of accreditations.

4.3.2 Assignment of Evaluation Jobs

Another issue concerns the states' roles in assigning particular

accredited agencies to conduct specific building system evaluations.

In this report, a straight forward, direct role is envisioned; see

Reciprocity of Building Functions in Appendix B "This Is LEAP." In

this approach the team lineup of agency(s) performing the Analysis,

Testing and Compliance Assurance Functions on a specific job would be

established by the state and would be made known to all interested

parties from the outset. This approach allows the state any mix it

chooses regarding the selection of governmental and private agencies

for a particular team, with each participant meeting the criteria

established as a basis for reciprocity.

"129-
4.3.3 Alternative Approval Methods for Building Systems

The earlier discussion of the Analysis function raised the issue

of who actually issues the approval of a system found to be in compliance with the applicable code. This issue relates to the question

of liability, and has both legal and administrative aspects.

While it is clear that the Analysis function can, and in many

cases will, be carried out by a third party, the question is whether

a state can actually delegate the actual approval function, or whether

it must itself give approval based on third party recommendation. The

answer may vary from state to state and may depend on each state's laws,

or it may be uniform.

Laws should be surveyed to answer this legal question and the

technical and administrative implications of the various alternatives

should be explored in order to complete this rather specific, but multidisciplined study.

In all of these considerations, a maximum degree of flexibility

of approach is desirable among the states as to the minimum set of

activities which must be carried out directly by the State Administrative

Agency in order to fulfill its responsibilities. This is both a legal

and political question.

0 »130-
4.4 COST AND FEES

The basis of the proposed Analysis function procedure is that it

must be applicable to a broad range of product preassembly, to the

full range of technological innovation, and to a variety of possible

delivery processes. Clearly, the costs of carrying out the Analysis

function will vary greatly depending on the characteristics of each

particular submission within the possible range, as mentioned earlier.

Under these circumstances, it is important that the fee structure imposed on applicants, on the building industry, and/or on society in

general, reflect the variation in cost while being equitable.

A study of the Analysis function costs and the development of the

proposed fee structures should follow on the comparison of several

models which identify costs borne by society in general, costs borne

by the building industry and costs borne by particular applicants.

-=131-
4.5 LIABILITY

Liability was one of the areas of concern most often heard in

the informal interviews carried out for the present study. Such

questions as whether or not the liability imposed on third party

evaluators for manufactured building causes a competitive disadvantage vis-a-vis conventional building were raised. Clearly,

such questions suggest the delicate nature of the problem, since

liability in manufactured building must be studied in the context

of liability in building in general.

Thus, a study of liability is again a well-defined area where

legal, economic and administrative factors meet and interact.

"132-
4.6 RESPONSIBILITY FOR INSPECTION IN-PLANT. IN-TRANSIT AND ON-SITE

The description of documents required for the Analysis function

has covered the Compliance Assurance Manual and the Installation

Document. Between them, they cover all the procedures and inspections

necessary to assure the approved product's integrity throughout its

delivery process, from supply of raw materials in the factory to

installation of the building on the final building site. The Compliance

Assurance Function is implemented in the plant by a third-party agency,

which affixes a compliance label, and the Installation is implemented

In the field by the local building official.

The question arises as to where lies the responsibility for procedures

of inspection of the product In-transit to the site and what if any added

responsibility does the state have where local citizens do not choose to

support a code enforcement officer. If the label is affixed at the plant,

who asserts that the product's integrity has not been impaired in transit?

Where does the Compliance Assurance Agency sign-off on the product?

These questions are related to a similar set of questions as to

who Is responsible for inspection when the product involves an on-site

factory, as do many concrete panel systems.

This brief discussion is sufficient to suggest that the border

between Compliance Assurance and field inspection is rather fuzzy, if

not entirely variable, as a function of specific materials, products,

systems and processes.

The study of this subject must zero in on the detailed description

of the total building process, analyze the specific characteristics of

r "133-
plant activities, transportation activities, and site activities,

and synthesize a model of enough breadth and generality to cover

all the alternatives realistically possible in the building

Industry.

=134-
APPENDICES

CONTENTS

A " MONITORING AND AUDITING

B - THIS IS LEAP

C » GENERAL INFORMATION FOR INSTITUTIONS APPLYING FOR

ACCREDITATION AS ANALYSIS AGENCIES UNDER THE MODEL

MANUFACTURED BUILDING ACT.

D ° APPLICATION FORM FOR INSTITUTION APPLYING TO STATE

ADMINISTRATIVE AGENCY FOR ACCREDITATION UNDER THE MODEL

MANUFACTURED BUILDING ACT.

E - LIST OF ORGANIZATIONS SUPPLYING INFORMATION FOR

THIS STUDY

1 - EVALUATING AGENCIES

2 - MANUFACTURERS, ETC.

F " INTERVIEW CHECKLIST

1 - CHECKLIST FOR EVALUATING AGENCIES

2 - CHECKLIST FOR ARCHITECTS, ENGINEERS.

INDUSTRIALIZED HOUSING MANUFACTURERS AND

BUILDING MATERIALS ASSOCIATIONS

G - GLOSSARY OF TERMS

-135-
Appendix A

MONITORING AND AUDITING

r- NEED FOR MONITORING

1 " ASPECTS OF MONITORING

3 - FREQUENCY OF MONITORING

4 » MONITORING PROCEDURES

=136-
Appendix A

MONITORING AND AUDITING

In the course of developing criteria and methodology for examining

Institutions, the role of the state in monitoring the performance of

delegated building-evaluation functions was identified as an important

factor. While it is beyond the scope of this report to consider the

state's role in detail, various possibilities and opportunities for

monitoring did evolve from the development of the criteria and methodology. They are summarized in this appendix for further consideration

by NCSBCS and the individual states.

137-
1 NEED FOR MONITORING

Analysis Agencies will be approved by the State Administrative

Agency by applying the requirements, criteria and methodology described

1n the previous chapter. Such approval will last for a predetermined

length of time, after which re-approval will be required. Among other

factors in determining the re-approval will be the reports prepared

as a result of ongoing monitoring by the Administrative Agency. In

addition to determining the re-approval of a particular Analysis

Agency, this monitoring will also serve as a basis for updating the

requirements, criteria and methodology themselves. This latter aspect

is desirable because of the empirical character of the requirements,

criteria and methodology for certain aspects of the Analysis function

(e.g., evaluation of performance specifications, evaluation of Compliance Assurance Manuals, etc.).

The requirements for monitoring the Analysis Agencies may also

have a legal basis, as a condition of a state's delegating the Analysis

function to a third party.

It is beyond the scope of this report to establish all the detailed

activities and staffing of the monitoring function. Rather, based on the

detailed description of the proposed Analysis function procedure, various

monitoring possibilities and'options will be identified.

0 -138-
2 ASPECTS OF MONITORING

Monitoring the Analysis function has two main aspects:

financial and technical.

The financial aspect combines the assurance that no conflicts

of interest occur and that fees are established consistently and

collected equitably.

The technical aspect of monitoring concerns the assurance that

an Analysis Agency is competent to carry out its assigned evaluation

tasks, as well as to manage the entire Analysis function efficiently.

°139=
2.1 Conflicts of Interest

It is clear that an Analysis Agency must be an objective third

party acting as an agent of the state. As such, the agency itself,

and any members of its staff of consultants must not have any direct

financial interest in the organization whose application is

being considered. However, several other sources of potential conflict must be considered:

(1) Financial interest or other business relationships

with an applicant's competition. Complete elimination

of this source of conflict would imply disqualification

of any person actively engaged in any aspect of industrialized

building from working for or consulting to an Analysis

Agency. This could be impractical as well as undesirable,

for it could eliminate the use of highly expert professionals.

Thus judgment must be exercised in eliminating this source

of conflict of interest.

(2) Financial interest or other business relationship with any

supplier of materials or services to the building industry.

This is related to the source of conflict in (a) above,

except that it related to the total building industry rather

than to industrial i-zed building. Should an interest in wood

products, or in aluminium, for example, disqualify a person

from evaluating a concrete building system? Here, too,

judgment must be exercised.

=140-
(3) Any other professional participation in the building process.

This source of conflict of interest is the hardest to grasp.:

or to controls because it is mostly a question of attitude.

To the extent that industrialized building represents innovation of both product and process in the building industry,

ft might be viewed as a threat to certain established ways

of doing things. Specifically, it may be viewed by certain

professionals as a threat to the future of their profession

as they know it. Similar points have been raised in various

discussions of institutional response to technological innovation generally t and it is not unique to building. Clearly,

however, the expertise and experience required to carry out

Analysis function activities reside in the very professions

whose continued existence may be threatened (whether in fact

or only in perception is irrelevant here). Here is where

the most judgment is required, and no precise guidelines

can be established. Perhaps the only thing that can be

stated with certainty is that the evaluation of innovation

requires people who are open to innovation.

(4) Another conflict of interest might involve an agency performing

compliance assurance on a system it has evaluated „ This could

lead to a possible intentional covering of errors made in the

evaluation.

While it might be possible to avoid entering into a situation with

a specific conflict of interest, we should raise the further question

-141-
of whether a conflict ts not generated by the very fact that the fee

for the Analysis function may be paid in whole or in part by the

applicant. While it is perhaps improper to call into question professional ethics, one must not lose sight of the extremely competitive

nature of the building industry in general, and building professions

in particular. It is conceivable that in a state with a rapidly

growing industrialized building industry, several Analysis Agencies

would be authorized to evaluate building systems. In such a case,

even with fees established by law, cannot applicants engage in

"approval shopping?" It is a question that will not be considered

and cannot be solved here. Perhaps the state could undertake the assignment of each application to a specific Analysis Agency on a random

or rotational basis, and by this means minimize the potential for

developing such a conflict of interest.

=142-
2.2 Payment Methods and Fees

The proposed Analysis Function Procedure covers a broad range

of product preassembly of technological innovation and of applicant

participation in the building process. Thus, the Analysis Agency's

scope of work may vary widely from one application to the next in

terms of staffing, time and effort. It is clear that the Analysis

Agency must be reimbursed in a manner commensurate with its efforts.

TheSs a fee schedule must be developed.

Such a schedule will respond to each of the following parameters:

(1) The scope of the system (Is the proposed product a complete

building, a subsystem, a component, etc.?)

(2) The degree of technological innovation (Is a performance

specification to be proposed and evaluated?)

(3) The extent of applicant participation (Are all three documentsj Product Description, Compliance Assurance, Installation,

to be submitted and evaluated, or only one of them?)

The fee pertaining to a specific application can be determined at the

preliminary meeting.

The question of methods of payment is one which relates to conflict

of interest as well as to a variety of other legal and administrative

Issues, Its resolution is beyond the scope of this report, and this

brief discussion is confined to a listing of several alternatives:

(1) All Analysis Agency fees can be paid by the applicant at

the time of submission of documents.

=143-
All fees can be paid by the state from its general

tax revenues.

All fees can be paid by the state from a variety of

taxes imposed on the building industry in general.

A basic fee can be paid by each applicant, and the

difference between it and the total reimbursement can

be made up by the state in either of the previous

alternatives.

The fees can be paid to the Administrative Agency, and

in turn, to the Analysis Agency thus insulating the

Analysis Agency from any direct financial dependency

upon the applicant.

»144-
3 FREQUENCY OF MONITORING

The frequency of monitoring 1s related to the workload of the

Analysis function or the number of applications being processed, to

the length of time the Analysis Agency has been in operation and to

the method of monitoring. A discussion of the latter point

follows.

In principle, there are two distinct methods of monitoring.

One method would select a particular application and monitor every

phase of its processing through the Analysis function.. This could

be viewed as vertical monitoring. The other method would select

and monitor specific points in the Analysis function procedure

without regard to whether one or more applications were being covered.

Tbis could be called horizontal monitoring.

Each method has its advantages and disadvantages. Since the

proposed Analysis function procedure is one which clearly stresses

the need for a holistic approach to the regulation of industrialized

building, the vertical monitoring might give a better picture of the

operation of the total process. However, the Analysis Agency's

knowledge that it is being monitored could spur it to a typical performance. Perhaps some combination of the two methods would be in

order. '

-145"
4 MONITORING PROCEDURES

The following is a brief discussion of possible monitoring

procedures and where they occur in the proposed Analysis function

procedure (see Attachment B).

»146-
4.1 Observations

Certain of the Analysis function procedures lend themselves to

optional monitoring by the State through direct observation.

(1) Preliminary meeting is the first such activity s where

the viability of the meeting itself 5 as well as its

specific procedures and documents can be assessed.

(2) Check of submission adequacy and fee collection .

This is a routine activity, and its smoothness of

operation can be assessed.

(3) Selection of the evaluation team . Observe the management

meetings called by the project leader to select the evaluation team. In this way, the viability of the project

management approach to the Analysis function can be assessed

(4) Evaluation activities . These will be related to the

size of the document and will also involve staff meetings

or individual efforts which can be monitored directly.

=147 =
4.2 Review Documents, Correspondence, Reports

This procedure involves the review of the output of the various

Analysis function activities.

(1) Control Document . This is produced by the preliminary

meeting and can be assessed as to its effectiveness in

providing a framework for the entire Analysis function

procedure.

(2) Staff Selection Documents . Any documents used by the

project leader for staff selection (e.g., management

plans, schedules, manpower loadings) may be reviewed

for usefulness and effectiveness.

(3) Document Evaluation . Documents and forms used in the document

evaluation (for recording, rating, requesting additional

information, etc.) can be evaluated.

(4) Notations of Communications . Any notations or conmunications from the Analysis Agency to either the Compliance

Assurance Agency or to the local building official may be

reviewed.

(5) General Correspondence . All correspondence between the

Analysis Agency and the applicant may be reviewed for

clarity, purpose, and usefulness.

=148-
4.3 Meet with Participants

These meetings, with participants in the Analysis function

procedures, are carried out individually, and are designed to

elicit less formals possibly more candid reactions to the procedure.

The following meetings may be useful:

(1) With applicant and his consultants ^ to obtain their

opinions on the effectiveness of the procedure in presenting

the fewest constraints to the development and building processes.

(2) With Analysis Agency staff and consultants - to obtain

their opinions on technical and administrative aspects

of the procedure, as well as on the project management

approach.

(3) With Analysis Agency management - to obtain their opinion

on the efficiency of operation, on fee structure, and on

staffing.

(4) With Compliance Assurance Agencies - to obtain specific

information on the effectiveness of compliance assurance

programs approved by the Analysis Agency.

(5) With inspection agencies or local building officials -

to obtain specific information on the effectiveness of

field inspection procedures approved by the Analysis Agency.

i

=149-

i
Appendix B

THIS IS LEAP.

The sample brochure "This Is LEAP" was prepared by the Center

for Building Technology, National Bureau of Standards, for the

National Conference of States on Building Codes and Standards (NCSBCS).

The context of the brochure is that the State Administrative Agency

is answering a request for information from an interested party regarding the Laboratory Evaluation and Accreditation Program (LEAP).

This is a revised version of the brochure under the same title,

dated November 1971, which is included in the Project LEAP document

"Methodology for Examining Testing Laboratories," June 1972.

»150-
THIS IS LEAP*

Revised April , 1973

Administrative Agency

State of

*Laboratory Evaluation and Accreditation Program

151"
INTRODUCTION

The State Manufactured Building Act provides for establishment

of an Administrative Agency to implement rules and regulations for

manufactured building. In carrying out its responsibilities for

evaluating and approving manufactured building systems, the Administrative Agency may utilize the services and facilities of public or

independent, private institutions.

To establish credence in and to facilitate intra- and interstate

reciprocity among building system evaluations made through use of

either public or private institutions, the Administrative Agency

plans to initiate an accreditation program for such institutions.

For State accreditation purposes these building-evaluation

services are divided into three functions: analysis, testing and

coiTipliance assurance. These functional terms are defined as follows:

(1) Analysis is the building-evaluation process which includes

analytical examination and review of design and test documents

using professional judgment and experience, to determine

whether a proposed manufactured building or component conforms to applicable codes and standards.

(2) Testing is the building-evaluation process whereby the

engineering properties claimed for manufactured building

or components are validated by using appropriate standard

test methods or other approved physical simulations based

on recognized engineering principles.

-152-
Compliance Assurance Is the building-evaluation process

of appraising the manufacturer's compliance control program,

in conjunction with full-time or periodic monitoring, surveillance or audit, implemented to provide objective evidence

that manufactured buildings or components conform to the

approved documents.

Note: 1. Compliance Assurance relates to the Inspection

Agency function as defined in the Manufactured

Building Act, and has also been variously referred

to as Quality Analysis and Quality Control. The

Compliance Assurance Manual is prepared and the

program implemented by the Compliance Assurance

function and approved by the Analysis Function

under the Manufactured Building Act.

2. Compliance Control Program is the manufacturer's

system, including directly related quality and

process controls, for assuring compliance with

applicable codes and standards. The Compliance

Control Document is prepared and the program

implemented by the manufacturer and approved by

the Compliance Assurance Function. The Compliance

Document is incorporated into the Compliance

Assurance Manual

.

3c Agency , designates the accredited or approved

status of an institution to act as an agent of

the state in the regulation of manufactured

°153-
building, (e.g., Analysis Agency performs the

Analysis Function.)

A program, hereafter referred to as LEAP (Laboratory Evaluation

and Accreditation Program), has been instituted under the rules and

regulations of the Manufactured Building Act. Under this program,

interested institutions may apply for accreditation to provide

services and facilities covering any or all of the three buildingevaluation functions.

WHAT DOES IT ALL MEAN?

FOR THE BUILDING-EVALUATION INSTITUTIONS — Accreditation by the

State Administrative Agency means that the work of the building-evaluation

Institution will be accepted by the Administrative Agency whether or not the

manufacturer or the institution itself is located within the borders of

this state.

FOR THE MANUFACTURER — The LEAP Project is designed to assure

equitable evaluation of manufactured building, products or techniques,

including those of an innovative nature.

FOR THE CITIZEN — The LEAP Project is one of the key elements

needed to assure that building components, fabricated and assembled

through an industrialized process, will be subjected to inspections

equivalent to those given to on-site constructions.

FOR THE STATE — The LEAP Project enables the Administrative

Agency to summon the best combination of government and privatelyowned technical resources to the task of evaluating the design of

proposed manufactured building systems or components and of certifying

=154-
conformance of production units with approved building system documentation by providing follow-up, compliance monitoring services.

The LEAP Project also opens the door for government building-evaluation

departments to request accreditation by the Administrative Agency. The

credibility established by accreditation is intended to be the basis

for interstate reciprocity of manufactured building certification

programs^ thus making possible the economics of large scale production.

°155-
INSTITUTIONAL ACCREDITATION

The accreditation "teams" lineup and relationships are

illustrated in Figure 1. A sunmary of the functions and responsibilities of each member of the team follows.

STATE

MANUFACTURED

BUILDING ACT

Authority for the LEAP Project stems from the State Manufactured

Building Act. Basic elements of the Rules and Regulations promulgated

under the authority of this act include:

e Objectives and scope

e Establishment of a State Administrative Agency

©' Authority to designate accredited Analysis, Testing

and Compliance Assurance Agencies and recognize those

of other states,

e Adoption of nationally recognized consensus building

standards (s)

.

© Establishment of an Appeals Procedure.

ADMINISTRATIVE

AGENCY

The State Administrative Agency is charged in Pa^^ with

statutory responsibility for approving building-evaluation institutions. Functions of the Administrative Agency or it's

designee include:

-156-
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'157-
• Answers requests for institutional accreditation. • Initiates the processing of an accreditation request

by employing a designated examining agency, utilizing

nationally recognized standard criteria and methodology. • Investigates non-technical aspects of an applicant's

operations, such as finance, corporate relationships,

credit, insurance, business reputation, objectivity

and independence. • Accepts a report from the examining agency covering the

applicant's capability to do the required work. • Grants or denies initial accreditation based on results

of it's own investigation of the institution operations

and the examination of technical capability. • Withdraws accreditation, for cause, based on follow-up

reports on agency operations or technical performance,

or the results of the regular, periodic re-examinations

specified in the Rules and Regulations for the Manufactured

Building Act.

Information gathered by the Administrative Agency or it's

designee, and by the examining agency, is considered proprietary

and will be handled as provided by the rules and regulations.

=158-
INSTITUTION

EXAMINING

AGENCY

The Institution Examining Agency (lEA) is designated by

the Administrative Agency to determine the capability of applicant

institutions to perform tests, analyses or monitor compliance

control programs conducted under the Rules and Regulations. The

agency is composed of examiners skilled in the respective building

system disciplines.

The standard for examining institutions^ provides the

criteria and methodology for lEA's examination of an applicant

building-evaluation institutionc Cost of the examination is

borne by the applicant. The examination itself is composed of

three parts:

9 Review of advance information on technical resources

furnished by the applicant upon request of lEA.

# On-site examination of administrative procedures and

technical resources including procedures for conducting

required tests, analyses or compliance assurance tasks. • Submission of a report of findings by the lEA to the

Administrative Agency or it's designee.

While the examining agency operates at the convenience of

the state, the agency is staffed and supervised by an independent,

lOevelopment of, the standards to be used by the examining agency

was begun in August 1972 by ASTM Committee E-32,

-159-
nationally-recognized organization and functions neither as an

arm of state government nor as a commercial or public analysis,

testing or Compliance Assurance Agency (See "Institutions" below).

INSTITUTIONS

ANALYSIS AGENCY

TESTING AGENCY

COMPLIANCE ASSURANCE AGENCY

The term "Institution" is used here to describe organizations

applying for accreditation to serve as agents of the state in performing any one or a combination of the three building-evaluation

functions. Applicants may include public or private, profit or

non-profit institutions. Orqanization and functions of the state anH

the building system producer, are briefly summarized in "Interagency

Relationships" below. These relationships are defined in greater

2

detail in the standard criteria and methodology.

An institution having the appropriate competence may apply for

accreditation in any or all three of the above building-evaluation

functions. However, the institution will be examined for competence

using separate criteria for each of the functional areas requested.

Continuation of the accredited status of an agency is contingent on

successful re-examinations, which are periodically conducted in

accordance with the Rules and Regulations for the Manufactured

Building Act.

^ Ibid .

.160-
Test Agencies only are specifically accredited in one or more

of the following building-system diciplines. The Analysis Agency

is accredited only if it has access to all of the building-system

diciplineSc Accreditation by building-system discipline is considered to be unnecessary for the Compliance Assurance Agency.

# Electrical • Fire Safety • Mechanical (HVAC)

9 Plumbing

# Structural

CRITERIA FOR

EXAMINING

(STANDARD)

METHOD OF

EXAMINING

(STANDARD)

The standards used in the examination of institutions provide

the criteria and procedures used by the lEA in examining the capability of a particular applicant, lEA examines the applicant's

stated capability to analyze, test, or provide compliance assurance

services with reference to nationally accepted building standards

adopted under the Rules and Regulations. As discussed under "Institutions," the standard provides that a qualified applicant may apply

for state accreditation to perform services covering any one or all

three of the building-evaluation functions.

c °161"
APPEALS

BOARD

If the institution believes that improper interpretation or

application of the Rules and Regulations by the Administrative-^

Agency or it's designee has caused the denial of accreditation

or the withdrawal of previous accreditation, the institution has

recourse. The Rules and Regulations include an appeals procedure

and the establishment of an objective appeals board.

RECIPROCITY OF BUILDING EVALUATIONS

The previous section describes how interested government or

private institutions may become accredited to act as agents of

the State Administrative Agency. If the Administrative Agency

finds that the standards for the fabrication and evaluation of

manufactured buildings or building components prescribed by statute

or rules and regulations of another State, or other governmental

agency, meet the objectives of the Manufactured Building Act, the

Rules and Regulations provide that the Administrative Agency shall

accept manufactured buildings or building components which have

been certified by such other State or governmental agency, and shall

assure that the appropriate label is attached thereto. Reciprocity

is extended by the Administrative Agency by:

(1) Notifying the requesting manufacturers;

(2) Notifying the Administrative Agency of the other

jurisdiction;

-162-
(3) Publishing a notice of the grant of reciprocity in

3

(4) Giving notice to all local enforcement agencies in

this State.

Figure 2 illustrates the process of reciprocal certification

of building evaluations. The manufacturer submits a request for

approval to the Administrative Agency of State "A" (Step 1). Depending on workload and organizational accredited arrangement,

the Administrative Agency assigns the work to its own accredited

government Analysis Agency or to an independents accredited

Analysis Agency (Step 2). The state will also select accredited

Compliance Assurance and Test Agencies to participate in appro-=

priate phases of the building-evaluation process.

The assigned Analysis Agency then carries the project through

to approval. Submittal of documents and communications takes place

directly between the manufacturer and the Analysis Agency (Step 3).

Approved sets of documentation are sent to the manufacturer and to

the Administrative Agency of State "A" (Step 4).

Subsequently, the manufacturer from a jurisdiction to which

reciprocity has been extended may submit to the Administrative

Agency of this state evidence that his building system and

"^Insert name of journal designated by State for publication of

legal notices.

-163-
aVOINMOM

NO aasva in3wnoissv

-164-
pi lance assurance program have been approved by such state or

governmental agency. The Administrative Agency then verifies

the approval and notifies the manufacturer in writina of such

verification and that properly labeled buildings or building

components of his manufacture will be accepted.

INTERAGENCY RELATIONSHIPS

A system has been described of recognizing the capability

and work of building-evaluation institutions and of achieving

reciprocity of building evaluations among the states. One

manner in which these agencies might work together to approve

and certify a particular building system is illustrated in

Figure 3. After the work has been assigned by the Administrative

Agency s the scope of effort is defined in a meeting between the

manufacturer and the Analysis Agency. The subsequent submittal

of required building system documentation and all related communications take place directly between the Analysis Agency

project manager and the manufacturer until the project is

approved, is abandoned or is under appeal (Step 1),

If it is not possible to approve the building system through

analytical means alone, a Testing Agency may be required to

perform supporting tests. The resulting test reports then become part of the submittal documentation. (Step 2 = optional.)

In order to grant full approval of a proposed building

system, the Analysis Agency must approve three documents; the

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Product Description, Compliance Assurance and Installation Documents.

Submittal of these documents may be made at one time or in phases,

at the discretion of the manufacturer.

Preparation and submission of the Product Description and

Installation Documents are the responsibilities of the manufacturer.

To assure completeness as well as effective implementation during

the production phase, the Compliance Assurance Agency designated by

the Administrative Agency reviews the manufacturer's Compliance Control Document for preliminary approval. (Step 3.) The approved

Compliance Control Document is then incorporated by reference as

part of the Compliance Assurance Manual, which is submitted to the

Analysis Agency for overall approval.

When the building system is approved and goes into production

(Step 4), the Compliance Assurance Agency continously monitors the

effectiveness of the manufacturer's Compliance Control Program and

may be designated to control the product certification labels issued

by the Administrative Agency (Step 5).^

Ifs after production commences, significant tests are necessary

which (a) require the issuance of a full test report and (b) are

necessary to demonstrate equivalency of substitute materials or

processes or the correction of a defective process, such work is

performed by the Testing Agency at the request of the Compliance

Assurance Agency or Analysis Agency.

^Details regarding the monitoring of the transportation function

are not included in this brochure.

-167-
The local code enforcement jurisdiction provides inspection

services during the Installation (Step 6) and Final Inspection

Activities (Step 7), and issues the Occupancy Permit (Step 8).

By buil ding-in a high degree of flexibility for the method

of application, the type of process suggested in Figure 3 can

accommodate a broad scope of products ranging from wall panels

to complete buildings, whether prescriptive or innovative in

nature, while providing the necessary assurance of compliance

with applicable codes and standards.

NEED MORE INFORMATION?

If you want additional information or you desire to apply

for accreditation, contact:

Administrative Agency

State of

Phone

-168-
Appendix C

GENERAL INFORMATION FOR INSTITUTIONS APPLYING FOR ACCREDITATION

AS ANALYSIS AGENCIES UNDER THE MODEL MANUFACTURED BUILDING ACT

The first step in examining the technical resources of an

applicant institution is the Advance Information Phase. This

consists of a review of information provided on the application

form and attachments. To assist the applicant in interpreting

the application forms an information sheet is furnished with the

form. A suggested information sheet is provided in this Appendix,

directed to the informational needs of the applicant.

"169-
GENERAL INFORMATION FOR INSTITUTIONS APPLYING FOR ACCREDITATION

AS ANALYSIS AGENCIES UNDER THE MODEL MANUFACTURED BUILDING ACT

It is the purpose of this information sheet to assist you

in interpreting the application requirements for technical resource examination under the LEAP^ Program for manufactured

building. The discussion that follows pertains to three documents: • Form for making application to State Administrative

Agency for accreditation • Standard criteria for examining Analysis Agencies • Applicable building standards

A thorough understanding of the applicable building standards

and the standard examining criteria will be necessary in order to

successfully complete the applications.

You have indicated interest in accreditation as an Analysis

Agency, to provide services and facilities for evaluating manufactured building systems and components. Definitions describing

the building evaluation functions of Analysis, Testing and. Compl iance

Assurance are given in the brochure "This Is LEAP." Note that an

institution applying for accreditation as an Analysis Agency must

have direct access (i.e. full* time staff or established contractural

relationships) to technical personnel in all of the following building

system disciplines: ___

'Laboratory Evaluation and Accredition Program

°170-
# Acoustics

9 Architectural - Health and Safety

9 Electrical

9 Fire Safety

« Mechanical (Heating, Ventilating and Air Conditioning)

9 Plumbing

# Structural

The Institutional Examining Agency^ will collect data on your

organization's technical resources and technical competence. The

examining agency will submit this data to the State Administrative

Agency for evaluation along with certain other information gathered

by the state.

The technical resource examination conducted by the examining

agency consists of two parts:

9 Advance written and graphic information supplied to

this office by your organization, as indicated on the

application form.

9 An on-site visit by an examiner to inspect facilities

to verify advance information regarding technical

competance of personnel

,

The application form includes several questions regarding

the willingness of the applicant to allow the examiner to do his

job in a specific way. For example, a "no" answer to question

See Appendix B "This Is LEAP" for details.

--171-
(14) under General Information, or to question (4) under Related

Analysis Experience, may result in rejection of the application.

In order to qualify as an Analysis Agency it will be necessary

to show in-house capabflity to provide analysis services and facilities

for all of the building system disciplines. However, the Administrative

Agency may, under certain circumstances, permit a small part of the

required building system disciplines to be subcontracted, or a pool

of backup personnel to be maintained under contract to assist key

personnel in performing jobs of large scope. Conditions for granting

such exceptions will include, but not be limited to the following:

1) The percentage of the total required building system

disciplines to be subcontracted must be less than

approximately^ % .

' 2) The prime Analysis Agency assumes full responsibility for

work done by the subcontractor.

3) The subcontractor is examined for technical competance

by the examining agency, and is approved as an individual

only (See 3.1). Note: The subcontractor will not be

independently accredited as an Analysis Agency.

4) A full description of the building-system evaluations

to be subcontracted and a copy of the contractural provisions are furnished by the candidate prime Analysis

Agency and approved by the State Administrative Agency.

3Percentage figure to be established by NCSBCS.

-172-
5) Once accredited, the prime Analysis Agency agrees to

maintain the approved contract in force with the subcontractor until the prime Agency requests and receives

approval for different subcontract arrangements from

the State Administrative Agencyc Failure to comply

with this requirement may subject the prime Analysis

Agency to immediate revocation of accreditation.

A schedule for the on-site examination will be proposed by

the examining agency, subject to approval by the applicant, after

the completed applications have been received and accepted.

Please send completed forms to: „_____________„_____

°173»
Appendix D

APPLICATION FORM FOR INSTITUTION APPLYING TO STATE ADMINISTRATIVE

AGENCY FOR ACCREDITATION UNDER THE MODEL MANUFACTURED BUILDING ACT

This appendix contains a suggested application form to be

filled out by applicant institutions desiring to be examined for

accreditation as Analysis Agencies. Advance information supplied

on this form is reviewed by the Institutional Examining Agency to

establish that the applicant meets basic requirements of the standard

criteria, before an on-site examination is conducted.

-174-
APPLICATION FORM FOR INSTITUTION APPLYING

TO STATE (ADMINISTRATIVE AGENCY) FOR

ACCREDITATION UNDER THE (MANUFACTURED BUILDING ACT)

Except as otherwise authorized by the applicants information furnished

in this application and in the subsequent on-site examination will be

employed by the Institutional Examining Agency and the cognizant State

Administrative Agencies solely for the purposes of establishing accreditation of the applicant.

GENERAL INFORMATION

Ic Name of the applicant institution

2c Name and address of parent or affiliate organizaiton

3c Location of facilities ________________^

4c Mailing address

"

(City) (State) (Zip Code)

5c Chief Executive Name

Title

Telephone

(Area Code) (Number)

6c Indicate the category of Analysis function (prescriptive, innovative)

for which your institution claims competance and seeks accreditation.

7c List the building standards for which your institution claims

competence to perform the Analysis function.

8c List each in-house building-system discipline for which you claim

"175-
competence in performing the Analysis function. Note: Select

from the following list: Acoustics, Architecture - Health and

Safety, Electrical, Fire Safety, Mechanical (Heating, Ventilation

and Air Conditioning), Plumbing, Structures.

9. List agencies from which your institution has received approval

or accreditation.

Agency Type of Approval Effective Period

From To

Institutional affiliations with technical or professional

organizations

lie Describe the scope of services provided by your institution and

years experience. Briefly outline the institution's objectives

regarding future scope and type of services.

12. Attach a brief description of the methods and procedures used

by your institution to establish specific individuals have

attained the necessary competence.

a) To supervise the Analysis function of a building-system

evaluation.

b) To conduct the Analysis function of a building-system

evaluation.

-176-
13. Institution Liaison^

Name

TUle

Telephone

^(Area Code) (Number)

14c Has the Institution liaison thoroughly reviewed the LEAP

Criteria and clarified all questions that he may have had

regarding the indicated requirements?

YES _____ NO _____

15c Do you authorize the examiner to photograph pertinent facilities

in your institution?

YES NO

^This is the staff member or officer of your institution who

will coordinate the institution's preparation of and participation

tn the examination program.

»177=
RELATED ANALYSIS EXPERIENCE

1. List building-system evaluations conducted by your institution

during the last five years which are closely related (see

Methodology 3.3-F) to evaluations required by the building

standards for which competence is claimed.

Analysis Product Product Analysis

Function Analyzed Manufacturer Performed Year

Performed for

Whom

2. Attach typical examples of recent Analysis reports whose format

and scope are typical of that proposed for use.

3c List recent analysis experiences not necessarily related to the

applicable standards but which you believe are indicative of

your institutions capability to analyze building systems or subsystems. Attach typical reports.

Analysis Product Product Analysis

Function Analyzed Manufacturer Performed Year

Performed for

Whom

Do you authorize the Institutional Examining Agency to contact

producers and customers identified in this application in order

to check references?

YES . NO „ -178-
5c Has your Institution been the defendant in a lawsuit within

the last five years wherein technical competence in evaluating

building systems, subsystems or components was at issue:

YES NO . If the answer is yes, provide

all pertinent details including current status,

6e Within the last five years s has your institution lost any

accreditation conferred by a state, county, or city government

jurisdiction or by an independent accreditation association?

YES NO . If the answer is yes, provide

all pertinent details including current status.

PERSONNEL

Ic Attach a current organization chart indicating lines of authority

in your organization.

2. Attach a list of all full-time, and consulting personnel engaged

in supervision, operations or technical support activities.

Employment Status Responsible For

(Check One) Which Building

System Discipline

Position Held Full- Part- Con- As Tech- As EngiName (Responsibility) Time Time tract nician neer

3. Attach resumes for each person listed above. Resumes should be

limited to one typewritten page and should relate to the Criteria

specified for the prescriptive or innovative category selected under

=179°
Item 6 General Information. Include the name and a brief summary

of education, training, experience, pertinent technical society

or consensus standard affiliations, and pertinent publications.

Where applicable, list pertinent licenses or registrations,

including the certificate number and authority.

-180-
FACILITIES

Ic Attach a sketch of your offtee and work areas. Include all

pertinent Information related to the basic requirements for

the Analysis Agency as given in the Criteria,

2. Attach a list of pertinent technical and standard references

which are contained in your reference library (Refc Criteria),

Including edition and year.

ANALYSIS PROCEDURES

1. Does your institution employ standard written procedures for

conducting building-system or component evaluations?

YES ____ NO _____

2c If yes, approximately what percentage of the Analysis functions

required in the Criteria are presently covered by written procedures? %

3c Please attach a representative copy of one of your more detailed

Analysis procedures.

SUBCONTRACTORS

le List any of the disciplinary areas required by the Criteria for

the Analysis function, wWch will be performed by a subcontractor.

2c List any of the Analysis functions required by the Criteria for

the Analysis function, which will be performed by a subcontractor.

NOTE: If any (discipline) (Analysis function) is to be subcontracted, proceed to the following items..

=181-
3. Attach a copy of the contract between your institution and the

subcontractor (s )

.

4. For a subcontracted analysis function only, a separate application form and attachments must be completed by the subcontactor(s)

.

in the same manner and to the same degree of completeness as

required for your primary application.

5. Will your institution be responsible for timely scheduling of an

on-site examination visit to a subcontractor performing an analysis

function?

YES NO

OWNERSHIP

1. Does your institution have legal ownership of all the facilities

which you have listed in the application?

YES ____ NO

2. If the answer to item (1) is no, identify the items not owned,

describe the terms of usage and identify the lessor/loaner.

CONFIRMATION

The information contained on this application and its attachments

has been reviewed by me and it is true to the best of rny knowledge.

-182-
signature of Chief Officer of applicant institution

Date

Notary Public

Date

Seal

ft

"183-
Appendix E

LIST OF ORGANIZATIONS SUPPLYING INFORMATION FOR THIS STUDY

In conducting "it's study of the Analysis function for Project

LEAPj B. A, Berkus Associates contacted a variety of building

evaluating agencies and building-system or component manufacturers.

A listing of the evaluation agencies contacted is given in paragraph

1. The manufacturers contacted are listed in paragraph 2.

"184-
LIST OF ORGANIZATIONS SUPPLYING INFORMATION

1 EVALUATING AGENCIES

Building Officials and Code Administrators International, Inc., Chicago, Illino

Underwriters' Laboratories, Inc., Northbrook, Illinois

City of Chicago, Illinois

Glendon Mayo, Hartford, Connecticut

United States Testing Corp., Hoboken, New Jersey

City of New York, New York

Heery & Heery, Atlanta, Georgia

City of Atlanta, Georgia

International Conference of Building Officials, Whittier,

California

'City of Los Angeles, California

Pittsburgh Testing Laboratory, Pittsburgh, Pennsylvania

Department of Housing & Urban Development ° FHA,

Washington, D. C.

County of Los Angeles, California

-185-
LIST OF ORGANIZATIONS SUPPLYING INFOFlMATION

2 MANUFACTURERS

Zimcp Homes, Pompano Beach, Florida

Davenport Homes, Largo, Florida

Perry Building Systems, Riviera Beach, Florida

Building Systems Development Corp., San Francisco, California

Descon-Concordia Systems, Ltd., Montreal, Canada

Phil Bobrow, Montreal , Canada

Omni Housing Systems, Inc., Santa Anna, California

Gypsum Association, Chicago, Illinois

H. B. Zachry Co., San Antonio, Texas

Owens - Corning Fiberglas Corporation, Toledo, Ohio

American Plywood Association, Tacoma, Washington

»186-
Appendix F

INTERVIEW CHECKLIST

Checklists were used 1n an Informal manner to guide interviews conducted by B. A. Berkus Associates under Project LEAP

Contract No. 2-35943« The checklist used for interviewing evaluating

agencies is included under Section 1. The checklist for interviewing

architects, engineers, industrialized housing manufacturers and

building materials associations, is given in Section 2o

°187»
INTERVIEW CHECKLISTS

CHECKLIST FOR EVALUATING AGENCIES

-186-
PROJECT LEAP ° NAMEi

CONTRACT #2-35943 DATE:

CHECKLIST FOR EVALUATING AGENCIES

L • ORGANIZATION & PERSONNEL

Ae K Do you have a current organizational chart of your agency?

2. What type of ownership?

B. 1. What is total number of personnel? • Professional? • Technical?

9 Managerial?

9 Support?

2c What is the breakdown of personnel into disciplines? • Architectural? 9 Acoustical? • Structural? m Legal? • Mechanical? 9 Quality Assurance? • Plumbing? • Fire Safety? • Electrical? • Other?

3. Indicate experiences, education and registrations for your

personnel in the above disci pi ines« [Get company's qualifications

brochure.] Look for other qualifications such as trade

experience.

°189-
II. INFORMATION

A. 1. Can you explain, or do you have a chart explaining the

flow of Information through your organization (applications,

approvals, backup)?

2. What are all the alternative entry points for information

into your organization?

B. 1. What information formats are required for applications?

9 Drawings? • Plans? • Sections? • Elevations?

9 Details? • Shop Drawings? • Schedules? • Specifications? • Other written descriptions? • Test reports? • Management plans? • Other?

2. Are these informatioi^ formats the same for industrialized

housing and conventional construction? If not, what is

the difference?

-190
3e What codes, criteria and other technical information do

you use for plan evaluation?

Cc What forms, if any, do you use for processing information?

Is there a code reference for each item? • Checking? • Permits? • Approvals? • Other?

IIL INNOVATIONS

Ac 1 c Do you approve new assemblies, products or materials?

2c If you do, are applications for such approvals handled

by your regular organization or by a research bureau?

3c How do you establish criteria for approval of products

using materials not qualified under current codes or

standards?

B. Ic Have you any experience with approvals or industrialized

housing?

What percentage of your total approvals?

2. Has your experience with industrialized housing covered

frame systems, panel systems and modular (3-dimensional

)

systems?

3c Do you use a uniform method of processing industrialized

housing applications of any level of preassembly?

°191-
4. Do you approve components conditionally when they form

parts of larger assemblies?

5. Do you have a method for approving alternative options

of a single model or system based on climate, site

and/or consumer variables?

C. 1. Do you give approvals to prototypes of industrialized

housing systems, which recognize their future change

or evalution?

2. Have you any experience in expediting the approvals of

an Industrialized housing system by any kind of "on-board"

reviews and approvals?

D. 1. Do you allow the substitution of testing documentation

for evaluation?

How?

2. If so, how are the tests specified?

By you?

By manufacturer?

3. What relation, if any, do you have with testing

laboratories?

Ee 1 . What is your experience with performance criteria and

performance testing?

IV. COMPLIANCE ASSURANCE

Ac Do you require the submission of compliance assurance

programs as part of your normal approval mechanism?

-192-
Be Do you require the submission of compliance assurance

programs as part of your approval of industrialized

housing systems?

C. Are your approvals of industrialized housing systems

conditional on the implementation of specific compliance

assurance programs and Inspections?

Dc Do you issue directives to local Inspectors regarding

approved systems?

Are there standards for workmanship?

Vc CHANGES

A. How do you handle changes in products or systems which

have been approved?

Vie SEALED DOCUMENTS

Ac Is a registered architect or engineer required to seal

documents for approval?

9

"193-
INTERVIEW CHECKLIST

CHECKLIST FOR ARCHITECTS, ENGINEERS, INDUSTRIALIZED HOUSING

MANUFACTURERS AND BUILDING MATERIALS ASSOCIATIONS

-194-
PROJECT LEAP

CONTRACT #2-35943

CHECKLIST FOR A/Es, INDUSTRIALIZED HOUSING

MANUFACTURERS AND BUILDING MATERIALS ASSOCIATIONS

I. MINIMUM SUBMISSION

Ao 1. What would you consider to be the minimum documentation

required for approval of housing by an evaluation agency? • Conventional? • Industrialized?

2. What documents and information would you prepare as a

professional/manufacturer if there were no formal agency

review, evaluation and approval of building systems?

3e Have you had any experience with such a condition

(of no formal review^ evaluation and approval)?

lie EXPERIENCE

Ac 1. What has been your experience to-date with submissions

to evaluate agencies? • of conventional building? • of industrial ized, housing?

2c Do you view such evaluation (for design approvals; not

Inspection for compliance) as a constraint to your design/

construction process? • in terms of time? • in. terms of money? • In terms of manpower? -195-
3. Do you employ special personnel to prepare subralsslons

to evaluating agencies?

4e Does the documentation required by an evaluating agency

serve any other function in your design/production process

5. Are you involved with total design development of product?

What was your experience with the Operation Breakthrough

evaluation process, in terms of all the points covered

above?

"196-
NAME?

III. SPECIAL PROCUREMENT PROJECTS

A. 1 c Have you had any experience as a destgner/btdder on

any building procurement project where a technical

evaluation of the proposals was part of the bidding

procedure?

9 Federal government (DOD, GSA, etc,)?

9 Local government or public agency?

9 Private client?

2c Have you had any experience as a consultant to the

owners of such building procurement projects?

3c Have you participated in the evaluation of proposals

for any such building procurement projects?

'B. Have you had any experience with the use of performance

specifications in the procurement of buildings « building

systems, or products? • As writer of the specifications?

# As designer/manufacturer responding to specifications?

9 As evaluator of responses to specifications?

=197-
NAME:

IV« INNOVATIONS

A. 1. Have you had experience with the industrialized housing

process from prototype design to steady-state production?

2. What are your views on the current agency evaluation

procedures with respect to the evaluation from prototype

design to steady-state production?

3. Can you envision a system of prototype approvals which

would not constrain the evaluation to steady-state

production?

B. 1. Have you had any experience with the approval of products

at a lower level of preassembly than complete 3-d1mens1onal

modules (e.g., subsystems, assemblies, components)?

2. Can you envision a uniform method of approval of products

at all levels of preassembly so that subsystems could be

approved both independently and as parts of larger systems?

V. COMPLIANCE

A. Have you submitted compliance assurance programs as part of

product evaluation?

B. Have you developed a manual, guideline, or other information

for the use of Inspectors 'charged with the compliance assurance

of your buildings?

C. Ic Have you administered compliance assurance programs for

industrialized housing? • Experiences:

# Recommendations:

=198-
2c Can you envtston a untform system of evaluatton and compMance

assurance for all types of industrialized housing systems?

3e Who monitors system?

# Manufacturer?

# Build'ing official?

9 Third party?

4. Who pays for monitoring the system?

Vr. CHANGES

Ac Have you had any experience with developing and implementing

ehanges in an approved building system?

Be K Do you view the current procedures of evaluation agencies

as constraining the development and implementation of

such changes?

2c Do you have any recommendations regarding procedures for

reviews evaluation and approval of changes in approved

building^systems?

=199-
Appendix G

GLOSSARY OF TERMS

For the purpose of this report, the listed terms are defined as

« fol 1 ows

Administrative Agency is a generic name for the state agency

charged with administering the State's Manufactured Building

Act.

Agency signifies the accredited or approved status of an institution

to act as designee agent of the State Administrative Agency in

the regulation of manufactured building, (e.g., Analysis Agency

performs the Analysis Function.)

Analysis is the building-evaluation process which includes analytical

examination and review of design and test documents using professional judgment and experience, to determine whether a

proposed manufactured building or component conforms to applicable

codes and standards.

Architect is one who has general knowledge of the basic principles,

theories and practices in the field of architecture such as

may be acquired through completion of a full architectural curriculum leading to a bachelor's degree from an accredited college

or university, or through training equivalent in type, scope and

thoroughness.

Building-Evaluation Agencies 1s a collective term for the group of

agencies, accredited to perform one or more of the building-

-200-
evaluation services of Analysts » Testing and Compliance

Assurance,

Compliance Assurance is the building-evaluation process of appraising

the manufacturer's compliance control program in conjunction

with full-time or periodic monitoring, surveillance or audit,

implemented to provide objective evidence that manufactured

buildings or components conform to the approved documents.

Compliance Control Program is the manufacturer's system, including

directly related quality and process controls, for assuring

compliance with applicable codes and standards.

Criteria are standards or limits establishing the minimum satisfactory embodiment of equirements.

Engineer is one who has general knowledge of the basic principles,

theories and practices in a given field of engineering such

as may be acquired through completion of a full engineering

curriculum leading to a bachelor's degree from an accredited

college or university, or through training equivalent in type,

scope and thoroughness.

Engineering Technician is one who has knowledge of the basic principT

theories, and practices in a given field of engineering such as

may be acquired through* the completion of at least two years

of engineering curriculum at an accredited engineering college

or university, or has graduated from a specialized technical

vocational institute appropriate to his field, or through

training equivalent in type, scope and thoroughness.

c

=201-
Institution Is any candidate organization, government or^jrivate,

profitmaking or not-for-profit, applying for accreditation

to provide any one or all^f the building-evaluation services

of Analysis, Testing, and Compliance Assurance.

Manufactured Building Act refers to the Model Manufactured Building

Act developed by Department of Commerce Special Working Group

No. 1, or to any such equivalent Act as may be adopted by the

State.

Methodology is the body of procedures for the examining agency to

use in determining if the criteria for a building-evaluation

function are met by an applicant institution.

Requirements are the attributes such as knowledge, skill or judgment

needed to perform a task.

Task is the procedure or element of a particular building-evaluation

function; often implied by the related requirement and thus

unstated.

Testing is the building-evaluation process whereby the engineering

properties claimed for manufactured buildings or components

are validated by using appropriate standard test methods or

other approved physical simulations based on recognized

engineering principles*

=202-
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U.S. DEPT. OF COMM. 1. PUBLICATION OR REPORT NO. 2. Gov't Accession

Dini lA^DADUl^ nATA - NO.

SHEET NBSIR T3-lo6

3. Recipient's Accession No.

4. TITLE AND SUBTITLE

"Criteria And Methodology For Examination Of Analysis

Agencies For Manufactured Building", "One And Tvo Family

Dwelling Systems And Components"

S. Publication Date

6. Petfocmiag Organization Code

7. AUTHOR(s) James U. Bryson Uertram M. Vogel

Jim L. Heldenbrand

8. Performing Organization

'imsiR 73-186

9. PERFORMING ORGANIZATION NAME AND ADDRESS

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, D.C. 20234

10. Project/ Task/ Work Unit No. 4601131

11. Contract/Grant No.

12. SpoQsoring Organization Name and Address

National Bureau of Standards

13. Type of Report & Period

Covered gtudy Report

Fall '72 & Spring '73

14. ^onsoring Agency Code

15. SUPPLEMENTARY NOTES

Intend to sulDmit to WERE after review "by sponsor.

16. ABSTRACT (A 200-word or less factual summary of most significant information. If document includes a significant

bibliography or literature survey, mention it here.)

Criteria are proposed by which participating institutions may be Judged for their

capability to perform the Analysis function in the evaluation and regulation of

memufactured one and two-family dwellings and components, including mobile homes.

Procedures are also proposed for use by an examining agency in determining if the

criteria are met. The criteria and methodology are intended as guidelines for

objective examination of applicant public or private institutions who desire to

serve as designees of state government in the analysis of dociments describing a given manufactured building system or component. Based on a study of the stateof-the-art and current model enabling legislation, a comprehensive description of

the required Analysis function services is provided as a basis for proposing a level of the criteria acceptable to the states. Appendices describe proposed

institutional mechanisms and provide supporting information and forms . Implementation of the proposed criteria and methodology, through the standards making

work of the ASTM E-32 committee, is intended to provide the states with a basis

for informal reciprocity of institutional accreditations and of building-evaluation

findings

.

17. KEY WORDS (Alphabetical order, separated by semicolons) Accreditation; Agency; Approval; Analysis;

Building; Building-Evaluation; Evaluate; Examine; Factory Built; Industrialized

Building; Manufact\ired Building; Mobile; Modular; Plans; Specifications

18. AVAILABILITY STATEMENT 19. SECURITY CLASS

(THIS REPORT)

21. NO. OF PAGES

1 1 UNLIMITED.

UNCL ASSIFIED

207

FOR OFFia AL DISTRIBUTION. DO NOT RELEASE

TO NTIS.

20. SECURITY CLASS

(THIS PAGE)

UNCLASSIFIED

22. Price

USCOMM-tJC a6244-P71

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