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RE; Plan check submittals and shop drawings

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If I may indulge myself by taking one more swing at this issue:

Bill says, <I believe DSA recognizes ... the SER ... stamping and signing
drawings and engineering produced by others is in direct conflict with the
California B&P code .... At one time, to solve this problem, DSA published a
...directive ... from which a stamp can be made and the SER can place this
stamp on the drawings. ... It would be nice if DSA could offer this document
... [for the] ... SEAOC website.>

Absent an official response from DSA (which I agree with Bill would be nice,
but which I don't expect to get in any timely fashion) I called a friend of
mine who is a senior structural engineer there to refresh my memory on this
issue.  As I understand what he told me, I wasn't exactly wrong, but Bill is
at least sort of correct.

DSA has an INTERNAL form of a certification (not generally released to the
public) which may be used by the SER in Karim's position.  My friend at DSA
faxed me a copy of the current version (issued 09/01/98, superceding a
version dated 03/24/97, which show this is still an evolving issue).  The
full text of the document is reproduced below.  If SEAINT wants to put this
on its website I don't see why they shouldn't, so long as it is clear that
it came to me through unofficial channels.


>> (For Performance Specification Items)

>> These drawings and/or specifications and/or calculations for
>> the items listed below have been prepared by other design
>> professionals or consultants who are licensed and/or authorized
>> to prepare such drawings in this state.  These documents have
>> been examined by me for design intent and have been found
>> to meet the appropriate requirements of Title 24, California Code
>> of Regulations and the project specifications prepared by me.

>> The items listed below are acceptable for incorporation into
>> the construction of this project for which I am the individual
>> designated to be in general responsible charge (or for which
>> I have been delegated responsibility for this portion of the work.)

>> List items reviewed and accepted.  (For drawings, a list of all
>> accepted drawings are to be attached.)>

That is the full text, which is followed by labeled spaces for, "Signature
of the Architect/Engineer", "Name, Title, Affiliation", "Date", "License
Number", and "Expiration Date".

My friend says it is not clear exactly when or how this form is to be used
or whether it requires the architect/engineer's seal and signature.  He
believes some of these issues are left to the judgment of the individual DSA
plan check engineer.  The intent would however appear to be to allow the
reviewer to make this certification in a separate document submitted to DSA
as evidence of his or her review and acceptance of documents prepared (and
presumably signed and stamped) by another professional.  The reviewer would
put NO stamp or seal on the documents themselves.

A word of caution.  My friend reports that back in early 1980's,  DSA's
predecessor, OSA-SSD, obtained a letter from BORPELS with a written opinion
which it believed supported its then policy of requiring the SER for a
school or hospital sign and seal drawings representing components of the
structural system designed by other professional engineers.  As I understand
it, although DSA understands that many professionals BELIEVE that there is
an issue and recognizes that this created difficulties with ENFORCEMENT of a
policy requiring SER signature, its position remains that these engineers
are INCORRECT.  While DSA plancheckers may be PERMITTED to accept a
statement of acceptance, policy may ALSO permit them to require SER seal and
signature in instances where they believe it necessary or appropriate.  My
friend said he would try and look into this further and to try and find a
copy of the BORPELS letter.  I will report to the group if he gets

Since Karim's job is not a school, he does not have to deal with DSA.  Jim
(an architect -- who let him in?) notes that under the UBC, Karim is, <not
required to "seal" the deferred submittal.>  He suggests that if the
governing authority insists, Karim should, <request to talk with the
Building Official (boss).>

IMHO, Jim is ducking the issue, which is one of professional responsibility
and the role we as structural designers want to play in the construction
process.  I believe DSA has a point which both our profession and the public
would be best served by our acknowledging.

Charles notes that, <UBC sec does not require the reviewing EOR to
sign and seal the "notation" forwarded to the building official that
indicates completion of review and a finding of general conformance.>  He
also says, however, <I believe the EOR's approval ... [should be regarded
under the PE Act as] ... an engineering report ... [of] ... a judgment ...
on engineering by others .... [Under this interpretation, while] ... the EOR
may not substitute his or her signature and seal for that of the engineer
exercising responsible charge ... [he or she] ... may ADD his [or her] own,
pursuant to "reporting" ... approval.>

If we want our cake (professional responsibility and respect), we can't eat
it too.  I think Charles is correct in interpreting the review notation (or
DSA certification) as a report.  In this regard I distinguish the report
(certification) of a design review (which I believe requires the exercise of
engineering judgment with regard to the interpretation of design assumptions
and scope) from the acceptance of a shop drawing submittal (which properly
consists only in verification of consistency with engineering design
drawings previously signed and stamped by the reviewer, does NOT require the
exercise of engineering judgment and IMHO is therefore NOT an engineering
report).  The P.E. Act  and acknowledgment of professional responsibility
REQUIRES us to sign and stamp our engineering reports, so we should sign and
stamp our "notations" or certifications of design reviews but need not sign
and stamp shop drawings.

As discussed in my previous post, the EOR's responsibility for the overall
structural design of the project is an important unifying link.  For most
projects of significant size, practicality dictates that some components of
the structural system will be designed by others.  I believe it is the duty
of the EOR in such instances to build into his or her contract documents an
submittal and review requirement and to review the other professional's
design for compatibility of assumptions and verification of scope REGARDLESS

Harold, says, <I agree that there is an implied responsibility of the EOR
for the entire project, but I still would not seal a manufacturer's
drawings.  I believe that this would imply a degree of detail design
responsibility that does not exist.>

Bill seems to agree, going further to say, <[Do] ... not use your engineer
stamp on any drawing or calculation that you (or your office) did not
prepare. ... It is O.K. to use your shop drawing stamp or some other "review
for general conformance" stamp ....>

Jim also suggests that, <a "shop drawing" review/acceptance type stamp with
company name & person's name ...> may resolve the issue.

Karim seems to agree, saying, <I too, feel more comfortable with using the
shop drawing review stamps, but ... have no problem with doing ... what ...
Charles ... [suggests].>

I have a fundamental problem with the approach Bill and Jim suggest.  Shop
drawing stamps are for shop drawings, and the truss drawings Karim is being
asked to stamp ARE NOT SHOP DRAWINGS.  The Kansas City Hyatt walkway
collapse showed that use of the shop drawing submission process as a way to
obtain EOR approval for modifying (or "finishing") a design can kill people.
Because of that disaster, most such stamps today specifically describe the
purpose of a shop drawing (to interpret rather than change a design) and
would if read closely be MEANINGLESS on a document (e.g., Mr. Tiedgen's
truss drawings) which describes a design which is not the reviewer's.  IMHO,
using a shop drawing stamp does NOT properly address the EOR's overall
responsibility for the structural design.

So what to do?  What we have done is made up a design drawing review stamp,
quite different from our shop drawing stamp, to serve a purpose similar to
the DSA certification.  Although I guess it will horrify Bill to imagine it,
there is a space INSIDE our design review stamp for the reviewing design
professional (the EOR) to affix his or her professional seal and signature.
Text explains that such seal and signature is evidence of the EOR's
acceptance of responsibility for REVIEW for compatibility and scope but NOT
for the design of the component(s) represented (I do not think the DSA form
above is sufficiently clear on this -- our stamp is much more explicit and
has been accepted by DSA reviewers).

Essentially, when I use our design review stamp I put my "report" of review
right on the document, which IMHO is better than the separate DSA
certification, which cannot easily address the risk that the document
reviewed might be improperly modified and issued in a later version under
the same certification.  Significantly with respect to Bill's concerns, our
stamp also notes that our review and acceptance shall be void and have no
meaning if the copy of the document to which it is affixed does not bear the
original seal and signature of the appropriately licensed design
professional responsible for the design of the component(s) it represents.

Despite Bill's concerns, I remain of the opinion that this approach best
fulfills my professional responsibilities without exposing me to unnecessary
or inappropriate liability.  I use the same approach on ALL projects
regardless of code authority.  The stamp we use has been approved by our E&O
insurer (they don't like it, preferring that we never take responsibility
for anything, but they live with it).  I would be interested in the opinions
of others.

Thanks for listening and my apologies for yet another too long message.

Drew Norman, S.E.
Drew A. Norman and Associates