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Commissioning Reg’s, Codes & Guides. How Many! (Post 2 Of 3)

Commissioning Reg’s, Codes & Guides. How Many! (Post 2 of 3)

Quality, Consequences and the Construction Industrial Complex (part 78) – All IMHO:

Last week the UK, this week, North America (USA and Canada). Lets revisit some definitions for context:   

Regulations Relevant to Commissioning
Regulation – “A rule or directive made and maintained by an authority having jurisdiction” e.g Building Regulations in the UK or Building Code in North America. Mandatory, legislated rules. You just have to do it, enough said.

Commissioning Code
Code – “A strict convention, etiquette, protocol or value system”. In the context of building design and Commissioning it is a “A strict protocol”. Mandatory based on application and if specified. 

Commissioning Guide
Guide – “A document providing information and advice that helps form an opinion, make a decision or calculation”. In the context of building design and Commissioning it is a “how to” document and not mandatory unless specifically specified as such. 

To summarize Codes are “what must be done” Guides advise “how to do it”. IMHO, a Guide can only be considered mandatory if explicitly called out as such in the specification. 

My research found 31 North American Commissioning codes and guides but no AHJ regulations! (see tables at end of post). USA and Canada both have a Federal governing system i.e. multiple layers of government (AHJ) resulting in:

  • Federal building codes
  • State or provincial building codes & regulations e.g. title 24 in California and the 2010 California Green Building Standards Code
  • Local municipality regulations 

In this multi layered, over governed (yes I am pro, small government) environment I have not managed to find a single AHJ regulation or code that mentions new building Commissioning in North America. If anyone can point me to any, I would be interested to hear from you. Why is this? 

IMHO there is a fundamental difference in approach to building commissioning between the UK and North America. In North America Commissioning is associated with energy conservation and equipment efficiencies where as in the UK and other parts of the world, Commissioning is a systems thinking approach i.e. the sum of the systems parts is what matters. A high tech VAV box is useless if it is not integrated into a VAV system that works seamlessly with the building. The building is the system!

This difference in approach is best captured by the UK definition of Commissioning, “the advancement of a system from a state of static completion to full working order”. Whereas the USA (ASHRAE) definition describes a “quality process” rather than systems approach.

I am not saying the UK approach to Commissioning is better than the North American, I am saying they are culturally, practically and politically different. I am allowed to say this as I am both Canadian and British, so there……. 

My conclusion is that multiple levels of government, plus 31 Commissioning codes and guides, plus an industry wide lack of clarity on what Commissioning is, leads to indifference, poor Commissioning RFP’s and buildings that do not work. Therefore lets define what, IMHO, should be specified for Commissioning on North American projects. 

Specify The People

Specify qualified commissioning professionals and stick to it, do not approve alternatives. Accepting alternatives is a bit like asking for a doctor then accepting a vet.

IMHO, appropriate commissioning professionals who will lead a project must have a minimum of eight years experience and have one of the following qualifications:

  • Professional Engineer with 8 years full time Commissioning experience (Not a design engineer with nothing to do!)
  • Registered Engineering Technician with 8 years full time Commissioning experience  (Not a field rep with nothing to do!)
  • ACG Certified Commissioning Authority with 8 years full time Commissioning experience
  • NEBB Certified BSC Commissioning Professional with 8 years full time Commissioning experience
  • BCA Certified Commissioning Professional CCP with 8 years full time Commissioning experience

Specify the Commissioning Standards – North American Commissioning Specifications for a Generic High Rise, AAA Office Development

Statutory AHJ Commissioning

  • None found for new construction

      Note: Stair case pressurization commissioning is not mandatory unless specified as such. NFPA 3 is “recommended practice”!

  • NYC is, quite rightly, trying to address the existing building stock. 

           Note: New York City Energy Conservation Code (NYCECC) NYC local law 87/09 – Energy Audit and Retro Commissioning 

Design Engineer Specified Testing, Adjusting & Balancing

  • AABC National Standards for Total System Balance 7th Edition 2016
  • NEBB Procedural Standard for TAB 8th Edition 2014

Design Engineer Specified Systems Commissioning

  • ACG Commissioning Guideline 2005
  • NEBB Procedural Standards Whole Building Systems Technical Commissioning 4th Edition 2014
  • ANSI/ASHRAE/IES Standard 202-2013 Commissioning Process for Buildings and Systems
  • HVAC Air Duct Leakage Test Manual ANSI/SMACNA 016-2012
  • ASHRAE Guideline 1.5-2012 Commissioning Process for Smoke Control Systems (Life Safety)
  • NFPA 3 Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Systems 2012 Edition (Life Safety)

             Note: Guides, standards and Manuals above should be considered mandatory compliance documents

Green Building Certification Commissioning 

  • LEED Reference Guide for Building Design and Construction EA Pr1 & EA Cr3

Remember all you building designers, the owner pays for and expects, a building that works and meets its performance targets. Building commissioning provides the testing and evidence for this performance and to be clear, it is the building services design engineers responsibility to specify appropriate commissioning.  

Middle East next week!

Related posts & links:

#38 – Commissioning certifications are being diluted to to almost zero value ( )

#39 – Balderdash, commissioning RFP’s & the benefits of clarity ( )

North American Commissioning Regulations, Codes and Guides

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