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Post date: Nov 18, 2013 5:2:55 PM
Alliance for Regulatory Coordination
Summary of Member Meeting
Meeting Date: October 18, 2013
Location: Associated Builders and Contractors (ABC) of Wisconsin, Madison, Wisconsin
The meeting was convened at 9:05 a.m. by Bob DuPont, of Regulatory Guidance and Design, LLC. Attendees introduced themselves and identified the organization they were representing.
Sharing of recent developments
DuPont reported that Representative Tom Larson’s office continues to work on remedial legislation on electrical licensing and inspection with a goal of having such legislation passed in time to modify statewide electrical licensing set to go into effect on April 1, 2014. Likely to be addressed is a license exemption for certain electrical work performed in existing manufacturing facilities, and inspection of such work.
John Mielke reported that drafting of a bill that would establish a min/max state commercial building code is underway. He said that he believes the current bill draft reflects a written agreement among interested parties that was developed earlier. John said he would be happy to continue working on improving the bill draft to address concerns. He said Senator Moulton prefers to have a bill that people can support.
Saying that the current bill draft is 500 miles apart from Senate Bill 32, Mielke explained that the current draft contains the following provisions: grandfathering of existing municipal ordinances related to fire detection, prevention or suppression; expanding authority for municipal review of variance requests by second class cities through delegation from the DSPS; establishment of an advisory commercial building code council; recognition of municipal ordinances that establish property maintenance codes; and a requirement that inspections performed to determine compliance with the state building code be performed by persons certified by the DSPS.
Presentation on the ISO Building Code Effectiveness Grading Schedule (BCEGS®)
Ralph Dorio, of ISO, provided some background information about the ISO and the BCEGS program. ISO serves the property/casualty insurance industry. ISO is a member of the Verisk Insurance Solutions group at Verisk Analytics (NASDAQ:VRSK).
The BCEGS program started in 1995 with the idea of identifying the types of building code programs that will result in greater likelihood of buildings surviving a disaster. The program was designed to apply to communities, but two states, Wisconsin and Indiana have state-run plan review operations so their BCEGS scores apply to the local communities served by those states. ISO BCEGS audits began in Wisconsin during 1998.
The BCEGS audit can result in a maximum of 100 points being earned. Code upkeep is worth eight points, with that score becoming a factor which is applied to scores earned in other portions of the audit. As a result, code upkeep has a relatively large impact in the overall score for a community.
ISO is considering making an adjustment in the scoring methodology to reduce the scoring impact related to code upkeep and increase the scoring impact related to training and code enforcement. Currently there are a maximum of 13 points awarded for staff training and 12 points available for certification of staff. These numbers apply separately to plan reviewers and inspectors.
The BCEGS audit has three parts, each with its own maximum score as follows: administration of codes, worth 54 points; plan review, worth 23 points, and inspection-enforcement, worth 23 points.
For training and certification of staff, ISO uses benchmarks set by the International Code Council (ICC).
Ralph said that there is a grace period of one year in cases where the lack of training is the only factor that would cause a community score to regress. If such a community provides the requisite training within that one year timeframe, ISO will include that training before applying a new score for that community.
In response to a question about fire sprinklers, Ralph said that a community may regress in their score due to not adopting a building code which requires fire sprinklers.
In response to a question about possible impacts on FEMA reimbursements to communities due to the fact that the Wisconsin Uniform Dwelling Code (UDC) is older than six years, Ralph said that FEMA may give less money if your code is older than six years.
In response to a question about possible impacts because the Wisconsin UDC does not address seismic hazards generally considered applicable to Wisconsin, Ralph said that ISO and the insurance industry knows that there are no seismic provisions in the UDC.
In response to a question about how BCEGS scores are affected by the fact that the federal government is using 12 year old NFPA life safety codes for regulating health care facilities across the country, Ralph said that may be more of a problem for the facility or community than for the insurance industry because most such health care facilities are self insured.
Ralph said, for communities in general, the negative effect of having a statewide code that is over six years old is significant because that negative effect is too great for communities to negate with efforts in other areas such as training, certification or staffing levels. He said that having a six year code update cycle can result in adopted codes being eight or nine years old due to the lag time of up to two years to complete the adoption process and then factoring in time for staff training.
Regarding staffing levels, Ralph explained that staffing levels are a major driver of BCEGS scores for plan review and inspection-enforcement programs of communities. For plan review programs the ISO expects the following average production per FTE plan review position.
For commercial buildings – one building review per work day with an average of 220 reviews per year.
For residential buildings (one or two-family) – two buildings reviewed per work day with an average of 440 reviews per year.
For inspection of commercial buildings ISO is looking for an average of 10 inspections per work day for each FTE, resulting in an annual average of 2200 inspections per FTE.
Ralph explained that various sub-system inspections, such as for plumbing, electrical or fire sprinklers, are included in the ISO expectations. He said the national average for communities in the BCEGS program is 8.5 commercial building inspections per day per FTE position, and that one inspection trip covering three such sub-systems equals three inspections.
A question was asked about having a way to model the effects of various potential staffing or programmatic changes so communities could see how such changes would likely affect their BCEGS scores. Ralph said that there is no such modeling program available for such use, but communities can contact their regional ISO BCEGS field representative to gain a better understanding of how staffing or other programmatic changes may affect their scores. He said that communities can request detailed reports from ISO regarding their BCEGS score so they can better understand their score.
Ralph said that the scores are factored into the rate-setting tables used by insurance agents when they calculate insurance costs for a particular customer. Insurance agents may not be aware of the impact of BCEGS scores because they do not deal directly with that data.
Ralph said that the ISO recommends three levels of loss cost discounts to insurance companies in Wisconsin. Those discounts relate to the BCEGS scoring scale as follows.
Nola Lebrecht said that BCEGS scores also impact building owners in flood prone communities because the Federal Emergency Management Agency Community Rating System, FEMA-CRS, utilizes ISO BCEGS scores in the CRS community rating formula. That formula can result in flood insurance rate discounts of up to 45% for building owners in communities that participate in the FEMA-CRS program.
A question was raised about how the relationship between the Wisconsin Uniform Dwelling Code and the International Residential Code may impact the BCEGS scores for communities in Wisconsin. Ralph said that ISO looks primarily at code provisions dealing with wind bracing, structural load paths and fire sprinkler systems when comparing the UDC to the IRC.
On a comparative note, Ralph said that ISO is aware of the fact that the Wisconsin Commercial Building Code does not adopt the inspection provisions of the International Building Code offered by the International Code Council.
DuPont asked if individual buildings could be recorded as being constructed to a particular code edition. He said the question relates to the idea from the Wisconsin Code Officials Alliance for legislation that would allow a building owner and municipality to enter into an agreement for a particular building to be constructed to meet a newer national model code than what the state adopts. Ralph said that individual buildings can be recorded in the ISO database as being built to the newest national model code.
Related to adoption of national model codes, Ralph reiterated that as such code adoptions slip, so will the BCEGS scores of communities throughout the state. Nola added that flood prone communities are often most interested in getting the code adoptions updated to help improve their FEMA -CRS scores.
Ralph raised the topic of additions and renovations for one- and two-family dwellings. He said it appears that the state program for administering the Wisconsin Uniform Dwelling Code is focused on buildings built after 1980, and the lack of code administration to pre-1980 homes can negatively affect the BCEGS score of communities in Wisconsin. Nola added that it also appears that, even for post-1980 homes, many communities do not administer permits or inspections for additions and renovations.
Richard Paur said that, according to section SPS 320.04(2) of the Wisconsin Uniform Dwelling Code, additions and alterations to dwellings originally built since 1980 must comply with the construction standards found in the UDC. DuPont added that the State does not mandate permits and inspections for additions and alterations to post-1980 homes, leaving that policy decision up to municipalities. He noted that Wisconsin UDC seals and fees are only required for new homes.
Ralph and Nola commented that lack of permits and inspections for home additions and alterations has a negative effect on BCEGS scores for those Wisconsin communities not providing such services.
The next meeting of Alliance Members was scheduled for January 10, 2014, from 9:00 to 10:30 a.m. at the offices of ABC, Wisconsin.
Post-meeting note: The next member meeting was later rescheduled to occur on January 8, 2014.
Scott Satula suggested, and others agreed, that the ARC Fire Safety Team should try to meet prior to the next ARC Member Meeting. DuPont said he would attempt to schedule such a meeting.
Ed Ruckriegel suggested, and others agreed, that interested ARC member representatives meet soon to discuss possible remedial legislation regarding carbon monoxide detectors in commercial residential buildings. Du Pont said he would attempt to schedule such a meeting.
The meeting was adjourned at 11:15 a.m.
This summary was prepared by Bob DuPont, Regulatory Guidance and Design, LLC.
It was issued on November 18, 2013.
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