Virgina (and most states) allows Certified Interior Designers to prepare construction documents for permit for interior construction.  Certified Interior Designers are, by statute,  professionals.  Certified Interior Designers, by regulation, have seals and are required to stamp construction documents.  There are many practicing Certified Interior Designers that prepare interior construction documents as a part of the full service of Interior Design offered to the public.

The proposed definition of Registered Design Professional recognizes only Architects and Professional Engineers. The council developing the International Building Code conducted hundreds of meeting all over the country and decided to accepted a broad definition of Registered Design Professional and did not limit it to Licensed Architect and Professional Engineer for this very reason.

I have practiced commercial Interior Design for over 30 years.  I prepare construction documents for permit for many localities in Virginia.  It is already very confusing to clerks and inspectors at the permit counter.  Typically, they may turn the drawings away.  Then I have to call back to explain that we are allowed to submit these drawings as these are not structural documents and do not involve a change of use. Then they are accepted, reviewed and approved for construction.

Certified Landscape Architects also submit drawings for permit.  They too are excluded from the narrow definition.  This is our livelyhood and we offer these services as a part of our full design services to the public.  This narrow definition may limit the work we now provide to Architects and Engineers.  This will not only restrict trade and limit the choices for the public but also put many Certified Interior Designers out of business.   

Thank you for your consideration. I would be glad to meet and discuss this further.   

Barbara G. Goodwin, Certified Interior Designer # 0412-000001                                        

804-752-2523

 

 

The proposed text of the revised statewide building code includes on page 64, a definition of a "registered design professional" You'll find this in section 13 VAC 5-62-250. The Department of Housing and Community Development has, in writing this definition, chosen not to follow the International Building Code, but instead to go back to text that is similar to what is included in the existing code. I am writing to disagree with this decision. Certified Interior Designers are recognized by Virginia and 25 other states as construction design team professionals who are regulated by the state. While our drawings are limited to non-loadbearing walls and features, they are nevertheless used by contractors for remodel work on a regular basis. Architects, building owners and developers also use the expertise of interior designer for decorative details, lighting and space planning. Like other regulants of the Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers and Landscape Architects (APELSCIDLA), we must seal our drawings when submitted for permits. Therefore, the Department of Housing and Community Development should use the definition of a "registered design professional" that was included in the original text of the International Building Code, or the similar one recommended to you by the Virginia APELSCIDLA Board rather than the definition included in the proposed Code. This definition is more inclusive, recognizing all the various members of a construction design team. It would be applicable to Landscape Architects as well as to Certified Interior Designers. Like Certified Interior Designers, they also submit drawings for permit within their area of expertise and should not be excluded by a narrow definition that recognizes only architects and engineers. Finally, as to the current text,it makes no sense to use the term "engineer" if what the Department is trying to do is to include only professions that are specifically trained in structural elements of the building since there are several different types of "engineers", some of whom have limited knowledge of building construction. We do not need the definition in the building code to protect our citizens from people who would practice outside their areas of expertise. We have other laws to do that. Please reconsider this definition. Thank you.

The proposed VUSBC includes the deletion of Section 707.14.1.  This section outlines requirements for the separatin and rating of elevator lobbies when the corridors are required to be rated.  The section also clarifies that a minimum of one exit is required from an elevator lobby.

Persons I spoke with that worked on this section recalled that the primary discussions with why the section was to be deleted dealt with not wanting to be more stringent than the current VUSBC.  Basically, not feeling that the elevator lobby separation was necessary.  They did not recall discussions regarding the single exit clarification.

I propose that the last sentence in Section 707.14.1 be retained to provide clarification that a minimum of one exit be povided from elevator lobbies.