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What’s in a (Your) Name? Codes, Certs and IECC!


Now Is Your Opportunity to Comment

Participate in the discussion that governs your profession! Get in touch with your AHJs. Ask them to support naming revisions in IECC hearings –

Commissioning codes are on the brink of linking up with certification. For the first time, beginning July 1, 2016, the Washington State Energy Code will identify those qualified to provide commissioning services as “Certified Commissioning Professionals.” The code was also modified to cite the accredited organization (and standard by which the organization is accredited) that certifies the provider.

That’s only the beginning.

The International Code Council will be meeting in Louisville, Kentucky from April 17-27 to conduct 2016 Committee Action Hearings on “Group B-I Codes”, including the International Energy Conservation Code (IECC). Download the proposed changes.

Proposed revisions to IECC are numerous and many include changes related to commissioning. Several proposed changes directly affect your title and role as a provider – two different proposed definitions of commissioning providers and two different sections that replace “the registered design professional” and “approved agency”. One proposes replacing with “certified commissioning professional” (preferred) and the other proposes replacing with “qualified commissioning authority”.

Naming Proposal No. 1

Proposed Addition to Section C-202 (Definitions): “CERTIFIED COMMISSIONING PROFESSIONAL An individual who is certified by an ANSI/ISO/IEC 17024 accredited organization.”

The BCxA recommends this definition because it is clear and succinct, does not require a commissioning provider to be a licensed professional engineer, and is based on the ISO 17024-2012 accredited certification.

Related Proposed Revision to Section C408.2, which deletes the current naming convention and replaces all with “certified commissioning professional: “… Prior to the final mechanical and plumbing inspections, the registered design certified commissioning professional or approved agency shall provide evidence of mechanical systems commissioning and completion in accordance with the provisions of this section.” This proposed naming replacement is identified throughout the IECC where related to commissioning.

Naming Proposal No. 2

Proposed Addition to Section C-202 (Definitions): “QUALIFIED COMMISSIONING AUTHORITY The individual or agency identified by the owner or owner’s agent that serves as an objective and independent advocate for the owner and is responsible for the execution of the commissioning process. The individual or agency serving as the qualified commissioning authority has a building commissioning certificate from an accredited agency, or has not less than two years experience in commissioning of projects of a similar scale and complexity and is a professional engineer licensed by the State.”

The BCxA does not recommend this definition because it (a) does not define who the accredited agency is or to what standard such as the ISO 17024 standard and (b) doesn’t replace the word authority. See our blog post, Is A ‘Provider’ Equivalent to An ‘Authority’?, for more information.

Related Proposed Revision to Section C408.2, which deletes the current naming convention and replaces all with “qualified commissioning authority”: “…Prior to the final mechanical and plumbing inspections, the registered design professional or approved agency qualified commissioning authority shall provide evidence of mechanical systems commissioning and completion in accordance with the provisions of this section.” Language replacement as above in Proposal No.1.

So, what is in a name today? Whether Authority, Provider, Professional, Certified or Qualified? What are the implications of being an authority, or not? Being certified, or not? Commissioning titles, naming, and certification are hot topics right now.

The scramble for ISO-17024 accreditation is not only a competitive move among organizations that want to certify members to meet DOE requirements and ISO standards. The associated controversy over consistency and quality also serves to divide commissioning providers into political camps, and fosters an erratic approach to the profession that muddles the market and can further undermine the expectations of owners.

The question is, is there a naming convention and differentiation that matters to owners? Code compliance is essential to owners. Certification matters to some providers – it’s better to have one. To prove quality to owners, a certification can help to substantiate proof of performance, along with measurable experience, knowledge, and skill.

Is there a naming convention and differentiation that matters to AHJs? Yes. AHJs are the “authorities”, and commissioning providers are not. Certification matters because code compliance is the ultimate objective of AHJs. A certified commissioning professional can be relied upon to perform due diligence on building projects, assisting AHJs to meet their job requirements.

Let’s say for the sake of discussion that soon international commissioning “supercodes” (combined elements of IECC, IgCC, ASHRAE 189.1, and others) will obtain codes that are resource efficient, sustainable, and metrics-driven. Since codes generally focus on the needs of Authorities Having Jurisdiction (AHJs, e.g., code officials), they will serve expediency rather than define the qualifications necessary to know if the buildings you commission will work, unless stakeholders weigh in on qualification and certification in this round of IECC decisions.

Let’s also say that codes will be adopted and enforced because, if enforced, everyone’s job is at stake. Proof of qualifications will be necessary for those who commission buildings in a code-centric environment. A certification could be construed to fulfill that requirement, in fact it may be bought instead of earned, but not from an ISO-17024 accredited organization. Even so, certification is only one of several pillars for qualification.

What’s in a name today is more than just words. What’s at stake is the meaning of the name: ultimate achievement, recognition, and understanding of commissioning consistency and quality. The consistent application of a quality-focused process and industry-validated specific task documentation already exists:

  • The 2015-revised Better Building Workforce Guidelines include newly defined professional criteria defining “Building Commissioning Professionals.” The Job Task Analysis (JTA) and certification eligibility scheme were created and vetted by subject matter experts and received a public review for use in developing certification or certificate programs (https://www.nibs.org/?page=cwcc_resources).
  • The ISO 17024-2012 accredited certification process, along with the JTA, present a level of consistency that can be adopted into code language for IECC, and easily cascade into national and regional code systems.

If you are a commissioning provider or a building owner, you will want some input on quality and consistency of codes that affect your work every day, right?

Having accredited commissioning certification through ISO standards, and with certified commissioning professionals owning the work, will finally begin to address both the consistency and quality issues at stake for building owners and commissioning providers. Take action, help make it so by making your voice heard! Read more about IECC’s current commercial code revisions under consideration and make a difference by sending in your comments.

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