Commercial Building Inspections – To be or not to be an engineer
There seems to be some confusion among home inspectors as to the credentials required to perform commercial building inspections, more commonly known as Property Condition Assessments (PCAs).
It is a natural progression for home inspectors to expand and diversify their business by including PCAs as they gain more experience. Naturally, it helps to understand the rules of the game.
Over 30 of the states have instituted licensing for home inspectors. There are specific requirements for becoming licensed in each state.
No credential required for PCA
However, there is currently no required credential for performing PCAs. The one exception is the State of Georgia, which, through its Engineering Board, decided that performing PCAs requires the specialized knowledge of a Professional Engineer. We will talk more about this later.
There are several reasons there is no credential required, including:
1. The ‘profession’ of performing PCAs is still relatively young. While there are many companies that have been performing PCAs for many years, it is akin to the home inspection industry in the late 1970s and early 1980s, when people were aware that it was a good idea to have some review done on a house before they bought it, but did not recognize this service as a profession.
2. Traditionally, PCAs have been performed by larger engineering companies and architectural firms. Companies that use engineering and architecture firms for the design of buildings would naturally engage the services of the same professionals for evaluating existing buildings they were purchasing. An alternate route would be using the contractors who service or repair a building to assess it when it was being purchased.
However, the number of people who perform PCAs is growing.
3. There are fewer complaints relating to PCAs. Commercial property buyers and investors are making business decisions and are far less emotional than homebuyers. Therefore, there has been less lobbying for accreditation of those who perform PCAs.
State of Georgia exception
The decision by the state of Georgia’s Engineering Board regarding PCAs is worth reviewing. According to the
minutes from the May 17, 2005, board meeting, a concern was raised regarding a company offering home inspectors training to become commercial inspectors. It was the consensus of the board that the inspection of commercial buildings is practicing engineering.
Subsequently, the minutes of the June 2, 2005, meeting of the board include a board policy that states, “Providing Property Condition Assessment (PCA) inspection reports or any other reports concerning the conditions, adequacy, safe or unsafe conditions, compliance with plans/or codes of any commercial structure valued at more than $100,000 for a client is considered by this Board the practice of Engineering as defined in Georgia Law section 43-15-2 and persons not registered as Professional Engineers in the State of Georgia shall be prohibited from performing or offering to perform such
services.”
What constitutes Professional Engineering
Fortunately for the board, at this meeting one of its members had the foresight to propose a friendly amendment to remove the phrase “valued more than $100,000.”
Obviously, the value of the building is not a criterion for determining if an engineer is required to review the structure and safety aspects. If one were to review Georgia State Law 43-15-2, under sub-section 11, there is the following definition of the practice of Professional Engineering:
“The practice of the art and sciences, known as Engineering, by which mechanical properties of matter are made useful to man in structures and machines and shall include any professional service, such as consultation, investigation, evaluation, planning, designing, or responsible supervision of construction or operation, in connection with any public or private utilities, structures, buildings, machines, equipment, processes, works, or projects, wherein the public welfare or the safeguarding of life, health, or property is concerned or involved when such professional service requires the application of Engineering principles and data and training in the application of mathematical and physical sciences.”
The key part, I believe is, “…when such professional service requires the application of Engineering principles and data and training in the application of mathematical…”. When someone performs a PCA, he or she does do not apply engineering principles. For example, if a deflected steel beam was observed, the report should identify this deficiency and include a recommended course of action. The recommended course of action would likely include further review by a structural engineer. If an engineer did the PCA, he or she may be able to calculate the load and recommend exactly what was necessary to remediate the beam. This would be applying engineering principles and would be going beyond the scope of the PCA.
There is a big difference between performing a PCA for a potential purchaser of a building and reviewing the structural integrity of a building after a hurricane or earthquake, for example, to determine if the structure is safe to occupy. In the latter case, a Professional Engineer is required. In the former, a Professional Engineer is not required.
Engineers required for home inspections?
Using the rationale of the Georgia State Engineering Board, all home inspectors would also have to be Professional Engineers. Further, all field inspectors for municipalities who do inspections during the construction of new buildings would also have to be Professional Engineers. Obviously, this is not the case.
ASTM Standard E2018-01
In the ASTM Standard, E-2018-01, Section 6.7, is the
following:
“Not a professional Architecture or Engineering service — it is not the intent of this guide that by conducting the walkthrough survey or reviewing the Property Condition Assessment Report (PCR) that the consultant, the field observer or the report reviewer is practicing Architecture or Engineering. Furthermore, it is not the intent of this guide that either the report reviewer or the field observer, if they are an Architect or an Engineer, must either sign or seal the report as an instrument of professional service or identify this signature as being that of an Architect or an Engineer.”
I would agree with the sentiment of Section 6.7 in the ASTM Standard. We do not design or calculate. We look for evidence of non-performance in the systems and structures we review. We are not required to comment on the cause of the deficiency noted, and we do recommend further evaluation (possibly by a Professional Engineer) when more in-depth review is required.
Specialist required for PCA
One could argue that it sometimes requires specialized knowledge to identify non-performance during a PCA. I
agree. That is why inspectors, as generalists, must sometimes engage specialists to assist them during the PCA. The occurrrence of a specialist assisting the field observer is also identified in the ASTM Standard. I maintain that in the PCA business, it is important to “know what you don’t know” so you can engage specialists, as required.
Other states
After reviewing the Web sites of the state Engineering Boards for the states of New York, California and Texas, I cannot find a similar statement regarding the requirement for a Professional Engineer. It is interesting to note that on the New York state Web site, the following appears in the frequently asked questions section:
When would I use of the services of a Professional Engineer?
Answer: You might employ a P.E. to:
– evaluate the structural integrity, electrical and or mechanical systems of a house prior to purchase or renovations;
– design a new house or addition;
– design the water and sewage systems, storm drainage facilities and/or road layouts of a housing development or other tract of land.
Professional Engineers also design commercial, industrial and transportation facilities; municipal facilities such as water and wastewater treatment plants; and dams and bridges, among other things.
When must I employ a licensed P.E.?
Answer: Generally, you will need the services of a licensed design professional, such as a P.E. any time you need the approval of a government agency or official for a construction project; these officials can only accept Engineering Plans signed and stamped with the seal of a P.E. Check with that official to determine what you are required to submit. You will also need a P.E. when the complexity of the design of the project requires the skills of a Professional Engineer or when the services fall within the legal definition of Professional Engineering.
Based on the above, you might need to be a P.E. to do a home inspection! And you must be a P.E. if you need the approval of a government agency. When we perform a PCA for the purchaser of a commercial building, there is no approval of from a government agency required; we are also not performing code compliances inspections.
What can we conclude from this? The profession of home inspections is well established in North America and in most cases, is more strictly regulated than PCAs. As there are considerably fewer commercial building inspections done, and likely because Professional Engineers have historically been involved doing PCAs on larger buildings, there probably have been fewer complaints. Our view is that you are less likely to receive complaints about a PCA for the reasons discussed earlier. Our conclusion is that you do not have to be a Professional Engineer to perform Property Condition Assessments.
Should there be a required credential for a person who performs PCAs? Perhaps. Is that credential a Professional Engineer’s License? I don’t think so.
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