Draft Proposal CB-3 

This concept has been developed by the DOE Building Energy Codes Program (BECP) as a possible code

change proposal to the Commercial provisions of the 2012 International Energy Conservation Code

(IECC).   Interested parties are asked to submit any and all comments on DOE's initial concepts and draft

code change proposals. For instructions on submitting comments, visit:

www.energycodes.gov/development/commercial/codes/iecc/concepts/

Inspections (CB-3) 

Objective:  Improve/enhance details governing inspections of construction and examination of

documents associated with compliance verification.

Suggested Code Change Proposal

Revise Section C103.3 and delete Section C104 and replace as follows:

C103.3 Examination of documents. The code official shall examine or cause to be examined the 

accompanying construction documents and shall ascertain whether the construction indicated and 

described is in accordance with the requirements of this code and other pertinent laws or ordinances. In 

causing the documents to be examined to verify compliance with this code, the code official shall be 

permitted to utilize a registered design professional not affiliated with the building design professionals or 

other approved authority in conducting some or all of the review of the plans and specifications for 

compliance with the code.

C104.1 General. Construction or work for which a permit is required shall be subject to inspection by 

the code official or his designated agent, and such construction or work shall remain accessible and 

exposed for inspection purposes until approved. Approved as a result of an inspection shall not be 

construed to be an approval of a violation of the provisions of this code or of other ordinances of the 

jurisdiction. Inspections presuming to give authority to violate or cancel the provisions of this code or of 

other ordinances of the jurisdiction shall not be valid. It shall be the duty of the permit applicant to cause 

the work to remain accessible and exposed for inspection purposes. Neither the code official nor the 

jurisdiction shall be liable for expense entailed in the removal or replacement of any material, product, 

system or building component required to allow inspection to validate compliance with this code.

C104.2 Preliminary Inspection. Before issuing a permit, the code official is authorized to examine or 

cause to be examined the building site, and in the case of work to or on existing building the building, for 

which an application has been filed. 

C104.3 Required inspections. The code official or his designated agent, upon notification, shall make 

the inspections set forth in Sections C104.3.1 through C104.3.6.
C104.3.1 Footing and foundation inspection. Inspections of basement or crawl space walls having 

insulation applied exterior to or integral with the walls, slabs on grade, buried duct systems associated 

with HVAC systems, piping systems associated with HVAC or service hot water systems and freeze 

protection/snow melt systems shall be made before backfilling and concealment. The inspection shall 

verify compliance with the code as to R-value, location, thickness, depth of burial and protection of 

insulation as required by the code and approved plans and specifications.

C104.3.2 Framing and rough-in inspection. Inspections at framing and rough-in of wall, floor and 

roof/ceiling assemblies that are part of the building thermal envelope shall include verification of all 

required insulation types and corresponding R-values and their correct location and proper installation 

in the building thermal envelope, the correct fenestration thermal properties (U-factor, SHGC and 

VT) and proper installation of fenestration, installation of required vestibules, and air leakage control 

either through inspection or testing as required by this code.

C104.3.3 Plumbing rough-in inspection. Inspections at plumbing rough-in shall include 

verification of hot water piping insulation level and proper installation and protection, the existence of 

required temperature controls on potable hot water systems, installation of automatic time switches on 

circulating hot water systems or heat trace and installation of heat traps on hot water storage tanks 

associated with non-circulating systems.

C104.3.4 Mechanical rough-in inspection. Inspections at mechanical rough-in shall include 

verification of installed HVAC equipment type, efficiency and size, installation of gravity and 

motorized dampers where required and leakage rates of the dampers, installation of required demand 

control ventilation, required type, R-value, thickness and proper installation of insulation for ducts, 

plenums and piping associated with the HVAC system, sealing and any required leakage testing of 

ducts and plenums, installation of required economizers and associated controls, required 

temperature, humidity and zone controls, required sizing of HVAC system fans and motors, energy 

recovery capability where required, means to balance HVAC systems, required controls for HVAC 

and hydronic systems, limitations on hot gas bypass for cooling systems and limitations on 

installation of radiant heating systems.

C104.3.5 Electrical rough-in inspection. Inspections at electrical rough-in shall include verification 

of the existence and proper installation of all required lighting controls, the installation of all lighting 

system components (fixtures and lamps) as being in accordance with the approved plans and 

specifications and installation of individual electric meters for each dwelling unit in multi-family 

residential buildings.

C104.3.6 Final inspection. The final inspection shall include verification of installation of all 

required building controls and their proper operation and documentation verifying the activities 

associated with building commissioning have been conducted and the findings corrected. Buildings, 

or portions thereof, shall not be considered for a final inspection until the code official has received a 

letter of transmittal from the building owner acknowledging that the building owner has received the 

Preliminary Commissioning Report as required in Section C408.2.4.

C 104.4 Inspection agencies. The code official is authorized to accept reports of approved inspection 

agencies not affiliated with the building design professionals, provided such agencies satisfy requirements 

as to qualifications and reliability relevant to the building components and systems they are inspecting.
C104.5 Inspection requests. It shall be the duty of the holder of the permit or their duly authorized agent 

to notify the code official when work is ready for inspection. It shall be the duty of the permit holder to 

provide access to and means for inspections of such work that are required by this code.

C104.6 Approval required. Work shall not be done beyond the point indicated in each successive 

inspection without first obtaining the approval of the code official. The code official, upon notification, 

shall make the required inspections and shall either indicate the portion of the construction that is 

satisfactory as completed or shall notify the permit holder or their duly authorized agent those portions of 

the construction that fail to comply with this code. Any portions that do not comply shall be corrected 

and such portion shall not be covered or concealed until inspected and approved by the code official. 

Reason:  The current provisions of Section C103.3 require the code official to examine the construction

documents to verify compliance with the code.  Those provisions also allow the code official to delegate

that authority to another party (e.g., cause to be examined) but are not specific as to the qualifications

of that party.  Depending on the type and size of a commercial building, the plans and specifications can

be very complex and an appropriate level of review challenging for a jurisdiction that may not see many

large commercial projects in a given year.  Currently there is no specificity in the code about the

qualifications of any third party reviewer, so the permittee could argue against the imposition of a

registered design professional requirement by the jurisdiction.   The proposed language makes it clear

that, should the code official decide to delegate their authority to another party, the code official can

require that party to have specific qualifications—something very important because that party is acting

on behalf of the code official.  

The current provisions of Section C104 covering inspections are not as specific as they could be with

respect to energy efficiency.  The proposed language, which is consistent with that in the International

Existing Building Code (IEBC), provides the required detail to better ensure compliance with the code

and through compliance delivery of the energy efficiency potential associated with the provisions of the

code.

Cost Impact:  There is no cost impact associated with this proposed change.