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14 February 2017

Tower of Babel

"Come, let Us go down and there confuse their language, that they may not understand one another’s speech."

I recently enjoyed watching a video clip of a senate confirmation hearing, in which Scott Pruit, EPA Administrator nominee, was being grilled by Joni Ernst, Senator from Iowa. At issue was the term WOTUS, or "Waters of the United States." Not knowing at the time I watched it what the term meant, it was amusing to see that 97 percent of Iowa would be governed by expansion of the existing definition. Further discussion focused on puddles and on a definition of a parking lot puddle as a "degraded wetland."

The labyrinthine regulations of the federal government reminded me of regulations we in construction deal with every day. They are similarly complex and obscure, differing only in extent. I was not surprised that I didn't understand the subjects of the senate hearing, but on further thought, I realized I really don't know much about the countless codes and regulations that govern construction. Nor, I'm sure, does anyone else.

The picture that accompanies this article shows just a few of the code books we use at my office. In the picture are a few versions of the IBC, a couple of Wisconsin code binders, several books of Minnesota codes, a few versions of NFPA 101, an elevator code book, and a few books that explain what's in the codes. This collection is nowhere near complete; we have many additional code books for Minnesota and Wisconsin, plus others for North Dakota, South Dakota, and Iowa, as well as for a couple of other states. I can only imagine what national and international firms have in their libraries.

Presumably, when someone certifies documents, that certification implies that the responsible person (or someone under that person's direct supervision) understands everything in every statute, code, rule, and regulation governing the work of the project, and that the project complies with all of them. What does that tell us?

First, I think it's safe to say that most of most regulations simply codify what was already common practice, much of which was based on empirical evidence. We build walls of 2 x 4s at 16 inches on center because it's been done that way a long time and it seems to work. Later additions were added after due consideration; someone probably tested walls with framing at 24 inches on center and that worked, too.

Many requirements were added in response to building failures. Even then, I suspect much of what's in the code is based on intuition, rather than on basic research beginning with the question, "What is required?" Though useful for comparative evaluations, code requirements often are not based on real-world applications. (See "Faith-based specifications.")

I also think it's safe to say it's unlikely that any building complies with all regulations. Regardless of the source or value of those requirements, it's clear that there are too many for any one person, or even several people, to understand. Making things more difficult is the fact that some information is restated in different codes, often in slightly different fashion, and some codes are more restrictive than others.

The International Code Council (ICC) publishes a dozen or so building and fire codes, which reference hundreds of standards published by ASHRAE, ASCE, and various other organizations, including about 50 of the 375 published by NFPA. These secondary codes also cite other standards, and so on, and so on, and so on. States then modify the basic codes, as do local jurisdictions. Some variations are required by local seismic and weather conditions, but many make little sense. All of these form the basic reference library for everyone involved in construction. Codes are continually being updated, usually on a three-year cycle. But not everyone is on the same cycle; some states update to follow the major codes more quickly than others, and different states will use different versions of the same codes.

My firm does mostly medical work, which must comply not only with the IBC and state codes, but also with NFPA 101, dictates of the Centers for Medicare & Medicaid Services and the Joint Commission, as well as requirements of individual clients. I'm sure we're not alone, and that other types of construction have similar additional requirements.

Is all of this really necessary? I concede that there are special situations that require special treatment, but it's hard to believe there are enough special circumstances to justify the mountain of code books we must deal with. While it is somewhat understandable that we have codes for specific conditions, there is no excuse for conflicts between different codes.

Several years ago, I was told that one part of one local code required an elevator room to have sprinklers, while part of another code prohibited sprinklers in elevator rooms. I have been told that that contradiction had been eliminated, but only after it had existed for many years.

A few years ago, one state had unique requirements for grab bars. Were there things about the residents of that state that prevented them from using the same grab bars used in other states? Some states have lower limits for VOCs than others. Do VOCs stop at state borders? If VOCs are hazardous, doesn't it make sense to limit them everywhere?

If we want to fix construction, clear, consistent, non-conflicting codes would be a good start.

In a future article, we'll look at a couple of examples of problems with code requirements and conflicts. If you have examples, please send them to me, or post them as a comment to this article. 

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