BY BABU VARGHESE, PE, SI, CGC, CCC, FBPE Chair (2020)
The certification requirements for the Special Inspector of Threshold Buildings (SI) have gone through a rigorous rule-making process. Though the requirements for the SI certification were not changed, a new class of certification was introduced called SI (Limited). This was necessitated due to the demands of various building departments requiring SI certification for concrete-restoration work on threshold buildings, which left many engineers who had decades of experience suddenly out of work.
The definition of threshold buildings as defined by Section 553.71(12), Florida Statutes, remains the same. The statute defines threshold building as “any building which is greater than three stories or 50 feet in height, or which has an assembly occupancy classification as defined in the Florida Building Code which exceeds 5,000 square feet in area and an occupant content of greater than 500 persons.” The addition of a new type of certification simply pertains to limiting inspections to restoration of a threshold building.
The Board is glad to craft Rule 61G15-35.0021, Florida Administrative Code, allowing a SI (Limited) certification to perform inspections on the alteration, restoration, repair, and rehabilitation of threshold buildings. However, those with the limited certification are not permitted to do the inspections on new construction of threshold buildings.
Before the rule was adopted by the Board, it went through the entire rule-making process, moving through the FBPE Rules Committee, Joint Administrative Procedures Committee (JAPC), and a public meeting that included participation from professional associations and other interested parties.
The genesis of this problem was when the Florida Building Commission issued declaratory statement DS2014-061 about four years back, indicating that an existing threshold building undergoing concrete restoration or other repairs required threshold inspection. Since then, building officials across Florida, especially in South Florida, started requiring threshold inspections for all kinds of repair work involving threshold buildings.
Several engineers complained to the Board that this requirement by building officials caused them to lose their livelihoods. Many others applied for the Special Inspector certification. Though the Board sympathized with these engineers, the Board was in fact helpless in solving this problem for the past four years due to the following reasons: The statute did not allow for a new category of Special Inspectors who only perform inspections of restoration work, nor could the Board lower the standards required for the Special Inspector’s certification, which is an important aspect of construction to ensure life safety.
The 2019 House Bill 827, by amending Section 553.79, F.S., by requiring the enforcing agency to require substantial work performed on all new and existing threshold buildings, regardless of whether work done as new construction, repair, or restoration, be subject to inspections by a Special Inspector. In order to implement this statutory change, the Board has created a new class of certification called Special Inspectors of Threshold buildings (Limited), also referred to as Threshold Inspectors (Limited) or SI (Limited). The Threshold Inspector (Limited) can only perform inspections on the restoration or repair of threshold buildings and is not permitted to inspect new construction of threshold buildings.
The qualifying criteria for SI (Limited) is somewhat identical to SI except that the experience garnered from design and inspection of component design, such as pre-stressed or post-tensioned concrete, balconies, exterior walls, etc., will be acceptable for SI (Limited). The SI (Limited) certification can be upgraded to SI, once the qualifying experience is met and a new application with that experience is filed. Upon approval of the SI certification, the old SI (Limited) certification will be voided.
The Special Inspector applications have been revised substantially to address a few of the shortcomings the Board has noticed over the years. In the past, the applicants have been self-certifying their experience. Though the Special Inspector of record’s name may have been on the form, that person may not have seen or been aware of the applicant making the claim. This might have led to embellishments, such as claiming excessive time and other non-verifiable events. The new application for both SI and SI (Limited) requires the Engineer of Record or a colleague (in the event the applicant is the Engineer of Record) and the SI of record to certify each experience form. This new procedure falls more in line with the current PE application process, where the employment is verified by a supervisor.
The new application also has an expanded section that lays out the criteria that qualifies the building as a threshold type. The different items in this section paint a visual image of the building, allowing the reviewer to have a feel for the size of the building and the time claimed for design or inspection experience.
Pitfalls in completing the application
The most common issues that applicants make, which prevent them from getting the approval or it being delayed or denied, are an incomplete application, missing supporting documentation, or failure to follow the instructions on the application.
Though the instructions on each page of the SI experience form stress that experience is recognized (either for design or inspection) only when that experience involves “all components” of the building, many applicants still try to claim the experience when just one component, such as post-tension floor design, is involved. But for SI (Limited), experience in just one aspect of any of the component design of a threshold building is acceptable.
Another common mistake that applicants make is to have overlapping experience. It is normal for an engineer to work on two projects during a month. But it is not acceptable to claim experience of one month for each project. This is called “double dipping.” Use judgement to allocate time appropriately to each project. After all, we are counting months of experience and not days.
A spreadsheet called the “experience calculator” is provided on the FBPE website along with the application form, because of the persistent problems we have seen in this area. The applicant is encouraged to use the experience calculator, which will highlight the overlapping months of experience, so that the applicant can identify any problems prior to submitting the application.
Misidentifying the threshold building is another mistake. For example, incorrectly claiming experience on a one-story, million-square-feet, furniture showroom, which may have an occupant load of 500. This is not a threshold building since it does not have assembly classification. No experience will be credited for the design or inspection experience for either of the certification applications.
The Board hopes that the two pathways of certification, which were not available in the past, will help applicants obtain the appropriate certification according to their expertise.
Babu Varghese, PE, SI, CGC, CCC, is the president and principal engineer of Abtech Engineering Inc., a multi-disciplinary engineering firm, which he founded in 1988, in Fort Lauderdale. He has served on the Board since 2015, and was its vice chair in 2019.