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Inspector Calls Inspection Inadequate
I expect The City of Austin and other cities that are county seats have amended their codes to require more than just three inspections. If the county seats require say 5, 10, 20 inspections each at different stages, then in the county outside that county seat it seems the same multiple layers of inspections will apply also if the amendments apply. Finally how do the RCC requirements and the Texas Department of Licensing and Regulation TDLR that regulates the licenses for electricians and mechanical contractors also the Texas Board of Plumbing Examiners that regulators the plumbers and the Adopted Plumbing Codes Uniform Plumbing Code and the International Plumbing Code line up with the Texas Residential Construction Commission? When there is a conflict in code requirements, which prevails?
To Kelly Kennedy, TRCC project Manager on Sunset Advisory Commission:
As an inspector of new residential and commercial construction and also as a licensed real estate inspector with 30 years of professional inspection experience, I would like to comment on TRCC adoption of Chapter 307, Sections 307.1 -307.7 relating to inspections in areas without municipal inspections.
The requirements for the three inspections including the foundation, stage, framing stage and final stage are not adequate and do not come close to meeting what a prudent and reasonable inspection program that is administered by a municipal building inspection department and or certified building official would require.
The first stage of most on site residential building inspections would include a layout inspection and or plumbing rough inspection on the drainage waste and vent lines that are to be placed under the foundation system. The layout part of the inspection checks to verify that the foundation forms are correctly placed on the lot and that they do not encroach into any building set back, drainage easement or utility easement and that the state required erosion barriers to control runoff pollution are in place.
The plumbing rough inspection verifies that the sanitary drainage waste and vent system is properly bedded and sloped to drain (min. fall 1/4 inch/foot) has properly installed fittings per code, checks for damaged or nonapproved pipes and fitting and that the drainage system does not leak.
The plumbing system below the house foundation system is a critical and absolutely essential system that must be correctly installed. There is no possible way to verify this without a proper inspection made prior to the backfilling and concealment of the plumbing system to verify that the drainage system will function as intended or even meet code.
By starting with only a foundation inspection there is no way to verify that the drainage waste and~the vent system is correct or that the system will work. Improperly installed plumbing below a foundation can leak and adversely affect the foundation system, pollute the soil below or near the foundation, waste water resources, cause secondary damage inside the structure and or be a serious health safety issue.
The water supply lines that are installed below the foundation must also be installed to very proper installation including correct sizing, verification the water lines installed are actually approved for potable water systems, verifications that there are no joints in water 'lines below the slab (unless allowed by code), that the water lines are protected from damage, and that the water supply lines do not leak.
The required foundation inspection does not detail any requirement for plumbing inspection or electrical inspection. There is no requirement listed to verify proper electrical bonding such as a UFER ground or conduits in the slab.
Qualifications for Engineers and Architects Questionable:
While the TRCC allows the architect, engineer or persons under the direct supervision of the engineer or architect to make a foundation inspection or frame group inspection it does not require that these parties know anything or hold any certifications on inspecting plumbing, electrical or mechanical systems.
By allowing the engineer or architect to do foundation stage and framing stage inspections, does the commission expect that these licensed professionals also know the requirements in the IRC, NEC, IPC, 'UPC, IMC and other applicable codes? If the engineer, architect or their designated employees also have the same certifications from the International Code Council, then they could be reasonably expected to do a proper inspection.
Many of the engineers, and architects I work with do not inspect for code compliance or plumbing, mechanical, electrical, framing and building because of liability reasons and because of the fact that they do not have the training. What the engineers do know is why and how to design a structure to exact standards that meet the concrete code, steel code and wood construction codes for engineered designs.
This is I think a general comment and there are probably some engineers and architects that also have all or more of the required inspection certification.
The framing group inspection requirements do not address plumbing, inspection, for water, sanitary sewer, drainage system, gas lines. Was this intentionally left out of the required inspection procedure?
The framing inspection requirements and final inspection requirements do not address the need to verify compliance to the energy code, which is part of the International Residential Code.
The framing inspection requirements do state that the inspection be made prior to installation of insulation and sheetrock but they do not require inspection to verify proper installation of the weather resistive barriers that are required by code to be installed prior to exterior cladding systems such as siding, brick, stone or stucco. No inspector could be expected to inspect for proper installation of structural sheathing, proper installation of window and door flashing, proper installation of windows, doors and weather resistive barriers if the siding, masonry or stucco is already completed prior to the frame inspection.
The TRCC has not addressed adequately the requirement for compliance with IRC and amendments as adopted by the county seat. In the case of Travis County, for example, Austin has adopted the 2006 IRC and has amended its code to include a more rigorous energy conservation requirement. In addition for amendments for energy conservation and handicap access are under consideration. Granted these amendments may cause the builder and thereby the owner a grater first cost but the energy conservation cost usually has a pay back.
I expect The City of Austin and other cities that are county seats have amended their codes to require more than just three inspections. If the county seats require say 5, 10, 20 inspections each at different stages, then in the county outside that county seat it seems the same multiple layers of inspections will apply also if the amendments apply.
Finally how do the RCC requirements and the Texas Department of Licensing and Regulation TDLR that regulates the licenses for electricians and mechanical contractors also the Texas Board of Plumbing Examiners that regulators the plumbers and the Adopted Plumbing Codes Uniform Plumbing Code and the International Plumbing Code line up with the Texas Residential Construction Commission? When there is a conflict in code requirements, which prevails? Do the unlicensed builders have a greater voice and more power over the TDLR and State Board of Plumbing Examiners that regulate their licensed professionals? It appears to me that there is a tremendous amount of professional experience that will be lost by not getting the input with the TDLR and State Board of Plumbing Examiners involved with the Texas Residential Construction Commission.
Thank you for reviewing my comments. This was as brief a set of my comments as I could complete and do not represent everything I would like to say, but time does not permit. I am available to discuss any of these items of other questions you may have.
Michael A. Young
President and Owner,
McComis Inspections, Inc.
Austin, Texas
http://www.sunset.state.tx.us/81streports/trcc/responses/102.pdf
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