Codes, compliance and architect Norman Wang’s specialized insight

Beginning in July 2019, the ICC Off-Site and Modular Construction Consensus Committee (IS-OSMC), which was appointed by the International Code Council Board of Directors, began work on standards for off-site and modular construction. The committee developed the ICC/MBI 1200-2021 Standard for Off-site Construction: Planning, Design, Fabrication and Assembly and the ICC/MBI 1205-2021 Standard for Off-site Construction: Inspection and Regulatory Compliance. Those standards were approved on June 28, 2021, by the committee and then received ANSI approval as American National Standards on July 19, 2021. The following profile is one of several focusing on the value of these standards in supporting the off-site and modular construction best practices in building code departments across the country.

Maryland has a long history of modular construction that began in the mid-1970s. Since those early days, the state has adopted a statewide regulatory program for industrialized (modular) construction to support its ever-growing demand. Maryland’s Industrialized/Modular Buildings Program team is responsible for hundreds of plan reviews for modular structures every year.

Over the years, Norman Wang, licensed architect, current director of the Maryland Building Codes Administration, and former manager of the Industrialized/Modular Buildings Program, has some clear thoughts on off-site construction, codes and compliance challenges based on lessons learned over the years.

Those experiences made Wang an especially good choice for participation in the International Code Council’s Off-Site and Modular Construction Consensus Committee (IS-OSMC) that developed the ICC/MBI 1200-2021 Standard for Off-site Construction: Planning, Design, Fabrication and Assembly and the ICC/MBI 1205-2021 Standard for Off-site Construction: Inspection and Regulatory Compliance.

When asked about his history with off-site and modular construction, Wang noted, “As program manager for our state’s modular building program, I have seen some inconsistencies in regulations. That made me wonder what other states are doing and if a nationwide standard for modular building is available. Soon after, I saw that ICC was forming the standards committee. This was a great opportunity to share Maryland’s program and learn about other states’ requirements related to modular building, so we can all continuously improve.”

Plan perspectives

One of the critical elements of the ICC/MBI 1205-2021 Standard for Off-site Construction: Inspection and Regulatory Compliance is the requirement for plan reviews, either in-house or through third-party agencies. It’s a condition that all four committee members from state programs (Maryland, Michigan, Texas and Virginia) agreed on.

Maryland currently only requires one in-plant inspection, at any phase, of every modular building component during construction by a third-party agency. “I learned while serving on the ICC Off-Site Construction Committee that some states require two or more inspections during the same construction process in plants, which I believe is a better way to help ensure the quality of the completed modular buildings.”

During the committee meetings, Wang, like the other state representatives, shared Maryland’s requirements for plan reviews as well as third-party plant inspections. Currently, Maryland has 10 approved third-party agencies supporting its program.

“We rely extensively on these third-party inspectors, though, per our regulation, we are also allowed to send an inspector from the state,” he noted. Though he highly recommends reviewing third-party inspection results.

“Despite using third-party agencies for plan reviews, our staff also reviews 100 percent of our plans because they’re not always as detailed as we expect,” Wang explained. “Our review focuses largely on critical areas such as fire and life safety, accessibility, and means of egress and even structural design.”

Appreciating interconnections

One of the biggest takeaways from his work on the committee, according to Wang, was the chance to build relationships with other state administrators, industry associations and builders.

“I had a chance to get to know more players in the industry across the scope of the modular construction space, which I believe is important to the continuous improvement of codes and administration. It’s always good to know who to contact if questions or issues arise,” he added.

One overarching point that Wang reinforces when talking about modular building codes is the importance of having a licensed architect involved in the design phase of modular buildings.

“There is a role for more architects to be involved in the planning and design process of more complex projects. The architect can help identify complex code requirements and supervise the preparation of design documents, which in a way, addresses a common issue that no registered architect is on a third-party agency’s staff,” he said. “An architect is trained to see the interconnections between structural components; mechanical, electrical and plumbing; fire and life safety systems; and to ensure that these designs meet the code. It’s particularly important on complex projects.”

He believes that the involvement of a licensed architect directly in the design would dramatically improve the problems that he regularly sees on plans and during inspections.

Wang concluded, “For manufacturers, the benefit of an architect on staff would be faster government approval because the design documents will be more likely to address all code requirements, especially in complex projects.”