Is A ‘Provider’ Equivalent to An ‘Authority’?

For years, the building industry has debated use of the word “authority” to describe professionals who conduct building commissioning. Most recently (again), discussion surrounds the legal use of “authority” to describe professionals who are not officially authorized through state licensure to be equal to the “Authority Having Jurisdiction” (AHJ) in a building project.

Right now federal, state and local codes are being revised to include commissioning as a necessary service in building projects. In order to advocate for all who practice commissioning as a profession, the Building Commissioning Association’s (BCxA) Board of Directors decided to propose a change at the national level which would avoid future argument over the title.

As regulators move toward tighter local, state and federal codes for commissioning, the designation of “commissioning authority” is perceived as inaccurate in terms of responsibility within the built environment, and is likely to be increasingly unacceptable to regulatory authorities.

The BCxA proposed to ASHRAE that the term, “commissioning authority” be deleted and substituted with the term, “commissioning provider” in all instances where it appears in ASHRAE Standard 202-2013, Commissioning Process for Buildings and Systems (“the Standard”). This will pre-empt future confusion and issues, is inclusive of all who provide commissioning services, and clarifies the position and activities of entities that provide commissioning services.

The BCxA agrees that the use of the term “commissioning authority” implies that a commissioning provider, who may or may not hold valid state professional licensure, may be in a position of authority over the activities of licensed professionals or may be equal to the AHJ on a given project. Commissioning providers who serve in the capacity of consultants to owners and/or project teams do not have official “authority” in these cases despite their important and necessary presence in the delivery of performing buildings.

The proposal has now been approved by the ASHRAE Standard 202-2013 Committee and is in preparation for public review. When approved, the current definition – “Commissioning Authority (CxA): an entity identified by the owner who leads, plans, schedules and coordinates the Commissioning Team to implement the Commissioning Process,” and all other instances of the term located throughout the Standard, will be changed to “Commissioning Provider”.

  1. David L Lewis

    In today’s era of carefully needing to use proper words to define aspects of our professions, the word authority does cause concern, and rightfully so, of many folks. Owners have “authority” over their projects, the AHJ has “authority” to step in and review the design and construction to help insure the building will not create health and safety problems.

    While a commissioning person “is” an “authority” on commissioning, in the construction world the word authority carries a different meaning. Review Webster’s definition.

    Provider is a great word – a commissioning provider – says exactly what the commissioning firm and their staff bring to a project. Yes a CxP can advise on items related to code, but that is not our prime business.

    NEBB also uses the term provider for their commissioning folks, they use “CP”.

    We all can help clear up confusion in the construction industry by using CxP in our documents and this will mesh well with the rest of the construction folks on the building site.

    Just commenting here, but I do support CxP in name (and practice).

  2. Mark Walter

    It’s important to keep in mind that there exists an increasing tendency by some customers to hire their own Commissioning Authority or Owner’s Cx Representative to oversee various Commissioning Providers. School districts, universities and large enterprises are examples of entities that have this higher-level, non-provider need. To be clear, this is a role established to help ensure consistent commissioning quality is being provided by a set of individual Commissioning Providers. In this context, the term CxA is often used to distinguish this person/entity from the CxP (the team doing the actual commissioning activities). While the BCxA is doubtless aware of this trend, a suitable term is nonetheless needed that makes this distinction.

  3. Bob Landell

    I see Cx Providers as Cx Agents and independent testing specialists who could be directly contracted by the owner, or sub-contracted by mechanical, electrical and controls contractors. I would prefer the term Cx Consultant to replace Cx Authority.

  4. Diana Bjornskov

    ASHRAE Guideline 0 with 2019 revisions will be published later this year. The term “authority” is being replaced with “provider” throughout the document.

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