September 8, 2020
My name is Kristine Barker and I am a Certified Interior Designer (CID) in Virginia. I earned a Bachelor of Interior Design from the College of Architecture, Design and Construction at Auburn University (1994) and I have over 26 years practicing in the profession of commercial interior design. I currently hold the position of Interior Design Team Lead at Waller, Todd & Sadler A Woolpert Company in Virginia Beach, VA.
I am strongly opposed to the move to de-certify Certified Interior Designers in Virginia. De-certification of interior designers is apparently seen as a way to reduce barriers to business. However, this could not be further from the truth.
Please let me explain the role of a certified interior designer. To obtain a certification in Virginia one must pass a rigorous national exam known as the National Council for Interior Design Qualification (NCIDQ). This exam tests for knowledge in several areas key to the practice of interior design and primarily focuses on buildings used by the public. In addition to passage of the NCIDQ exam, one must have a 4 or 5 year degree from an accredited design program and have 2 years of professional practice under a certified interior designer or licensed architect. Though anyone in Virginia can call themselves an interior designer, only those with the credentials noted above can use the term certified interior designer (CID). At this time certified interior designers' practice in interiors firms, for government and municipal agencies, on the staff of public universities, for large corporations and hospital systems, and in firms like mine.
An interior designer’s work directly affects the health, safety, and welfare of the public in many ways. Designers are involved in initial programming and building space planning, which requires knowledge of building codes and human behavior. An interior designer is involved in interior architecture, designing casework, selecting lighting and coordinating building engineering systems with interior elements. Designers select interior finishes and furnishings which requires knowledge of fire ratings, interior building codes, and the proper use of materials to negate injuries. Designers must be well versed in building codes, signage and way finding, accessibility requirements (Americans With Disabilities Act – ADA), as well as have an understanding of the effects the materials they select have on indoor air quality and the overall environment.
There are several reasons that I oppose the de-certification of certified interior designers in Virginia. For the purpose of this letter I would like to highlight the issues that most concern me, as they create barriers to business for small firms as well as large businesses.
One of the clients for my firm is the federal government, which includes projects for the Army Corps of Engineers (USACE) and the Naval Facilities Engineering Command (NAVFAC) among other agencies. We respond to many requests for proposals (RFP’s) each year. In all RFP’s where the scope includes interior design services, firms must comply with Unified Facilities Criteria (UFC) 3-120-10 Interior Design, paragraph 2-2 Interior Design Qualifications, which states that the interior designer on the project must “have attained registration or licensure as required by the locality or district where the project occurs”. At this time, on government projects, my Commonwealth of Virginia CID certification is recognized by other jurisdictions and thus, on government projects my CID has been accepted for projects out of state without my having to be certified or registered in those states. There are many firms like mine in Virginia that provide design services to federal entities. To de-regulate certified interior designers removes our CID credentials, thus it would be difficult for our firms to continue competing for these important projects both within Virginia, as well as in other states and internationally.
Larger firm often require that small firms they team with have liability insurance. One concern is that some liability insurance policies often require that those they insure be licensed or certified professionals or certified professional corporations. Without certification, small companies may not be able to find affordable professional liability insurance carriers.
Certified Interior Designers in Virginia have a stamp, which they can affix to drawings they prepare as long as those drawings do not contain load bearing construction items. There are interior design firms that depend on the ability to stamp their own work so that they can obtain building permits on behalf of clients. If certified interior designers are de-certified in Virginia, these firms will be dependent on consulting architects or engineers to stamp their work in order to stay in business and provide interior design services to their clients. This will add costs to their business, as they will now pay for the services of an architect or engineering consultant that they would otherwise not have had to use. The costs for hiring consultants will be passed on to their clients, or quite frankly, these interiors firms will simply go out of business or have to merge with architecture and engineering firms. Without the stamp, a designer cannot obtain a building permit on behalf of a client.
The Division of Engineering & Buildings (DEB, part of the Virginia Department of General Services) for the Commonwealth of Virginia states in the Construction and Professional Services Manual (CPSM) 2020 Edition, Chapter 3, Section 3.2.2.2 Personnel Classifications and Hourly Rates, defines Interior Designer as “A certified interior designer who has the knowledge, skills and experience to provide the interior design services and documents for the project.” The services of the interior designer are further outlined in Chapter 3, Section 3.2.2.7 Interior Design. Elimination of the certification of interior designers will cause those designers to lose the use of their seal, making it difficult to complete for state work without being a consultant to an architecture or engineering firm. This will be a detriment to small businesses, many of which are women owned and minority owned. For interior design only projects this will increase costs to the state. Additionally, the CPSM manual will have to be rewritten if Virginia de-certifies certified interior designers, as the state should not require designer certification when they no longer provide certification, otherwise, in an ironic twist, only designers certified/registered in other states would meet the requirement to perform interior design services for state projects in Virginia.
It distresses me greatly that de-certification of interior designers is once again under consideration. De-certification is seen as a way to eliminate barriers to business, when it actually will create many new barriers and may destroy small businesses (primarily women owned) and place large and small firms in a difficult position when completing for work and promoting and insuring employees. Virginia has certified interior designers since 1990. I find it hard to believe that after 30 years the certification of interior designers is suddenly a barrier to business in Virginia.
I hope you have found this letter enlightening. I invite you to further research the profession of interior design. Before supporting this measure you should understand all the ramifications a change such as de-certification would cause not only to large and small businesses operating within the state, but also to individual designers such as myself, who have established their careers and reputations based on the certifications they have worked so hard to achieve. Please feel free to contact me any time.
Regards,
Kristine S. Barker, CID, NCIDQ
Contact:
757-621-0770 cell phone
757-231-3602 work phone