Alternate Means and Methods Review Process

A few months ago, while on social media, I landed on a page for a building inspector in Florida who declined to approve a weather-resistant membrane during a re-roof inspection. The inspector mentioned that the product used was not the one approved on the plans. However, he did suggest that the individuals involved could request an alternate review consideration. The comments in his post consisted of people in construction telling him he’s being ridiculous and that the product is equivalent to what is on the plans. It was clear, this was merely their opinion, lacking any evidence to support it when questioned by the inspector, myself, and other industry professionals who better comprehend the reasons behind the disapproval of this installation. Our commitment to scrutinizing the minutest aspects and intricacies is integral to how this process works and design and construction industry professionals really need to grasp the underlying principles that guide our decision-making process.

Chapter 1 in all codes published by ICC and IAPMO includes the administrative provisions, which, in my view, are often misunderstood by individuals who are not familiar with the code profession. Codes and standards play an unseen but vital role in our daily lives as they offer precise guidance on how to tackle various challenges associated with constructing, expanding, or renovating buildings. It is essential to have uniform and consistent procedures in place when carrying out tasks with codes for various reasons. However, there are times when it might not be feasible or desirable to strictly follow them. This article is going to explain the alternate methods and means review (AMMR) process and the intent of AMMR’s.

This specific article is geared more towards applicants and designers because, based on my experience in various roles, they frequently encounter challenges in grasping necessary steps prior to submitting an AMMR or determining if it is even the appropriate course of action. They often find it difficult to determine what information to include in AMMRs, which is a result of the urgent need for a decision (unexpected situations in the field) as well as the lack of "code" education in architectural school and adequate guidance post-graduation. This article is not about criticizing them; the AIA (American Institute of Architects) and some experienced architects in the Seattle area share the same viewpoint I do - I'll do a future article on this.

Below, is what the international residential code indicates for alternate means and method submittals to a building department or building official.

"The provisions of this code are not intended to prevent the installation of any material or to prohibit any design or method of construction not specifically prescribed by this code. The building official shall have the authority to approve an alternative material, design or method of construction upon application of the owner or the owner’s authorized agent. The building official shall first find that the proposed design is satisfactory and complies with the intent of the provisions of this code, and that the material, method or work offered is, for the purpose intended, not less than the equivalent of that prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety. Compliance with the specific performance-based provisions of the International Codes shall be an alternative to the specific requirements of this code. Where the alternative material, design or method of construction is not approved, the building official shall respond in writing, stating the reasons why the alternative was not approved"

What this is explaining is that we are not closed to hearing and considering other ways of doing things that may involve use of new technologies and even different approaches. Here are the important step-by-step components to understand about the AMMR process.

First-

Before proceeding, have you already explored the prescriptive approach? The prescriptive code is the first place to look then pivot from there. An excellent illustration of this can be seen with required venting for plumbing fixtures and air admittance valves (AAV’s), where there is a strong desire from plumbers to use AAV’s. The issue is these are permitted by the model IPC and IRC plumbing provisions, but only in certain situations. The UPC model, in contrast, prohibits these prescriptively. Therefore, if you live in a region that follows the IPC or plumbing regulations from the IRC, you may have an easier time integrating AAVs into a venting system. Conversely, if you are in an area that has adopted the UPC, you might encounter challenges when trying to use them

Second -

It is crucial to dedicate ample time to thoroughly delve into and assess the alternative you are considering. Conducting a thorough examination and evaluation to determine whether this is the right course of action is an important process that should not be neglected or dismissed. Furthermore, it is worthwhile to contemplate how the alternative aligns with the recommendations of the prescribed code. Does the alternate bear any resemblance to the prescribed code, or is the comparison more akin to comparing apples to firetrucks rather than apples to apples?

Third -

It is advisable to contact the jurisdiction to obtain information regarding the procedure for evaluating AMMR's. Inquire about the necessary documentation and details that need to be provided in order for your request to be considered; this could include manufacturer specifications, installation guidelines, listings and other testing reports. Additionally, it would be beneficial to inquire about the estimated duration for the review process, which may span over several weeks.

Fourth, and probably the most important part of this entire article -

Is it equivalent or better than what prescribed code requires and how has this been proven? Quite simply, if what you’re going to propose to the building department does not have any analysis or literature that demonstrates equivalency to the codes then you’re better off not even submitting it. I mean, we can’t deny the submittals as they are added costs, but this will likely be a waste your time and our time by submitting something where dots aren’t connected. I have seen submittals where an applicant just didn’t want to follow the code and they were hoping that we were going to budge on alternates not applicable to the situation and we didn’t approve them. It was a waste of everybody’s time. They ended up following what the code prescribed; after submitting the information, waiting for the review of the information, and paying additional fees for this review. This doesn’t necessarily stop an entire project, but it definitely does end up stalling or stopping areas of a project where the AMMR is being considered.

Fifth -

this is not a guaranteed approval. You’re submitting this for consideration, but it can be denied if it is proven through analysis by the building department that the steps to follow for submittal (i.e. proving there is an equivalency to prescribed codes) have not been met.

Adequate preparation and dedicating time to an AMMR proposal are crucial aspects that cannot be overstated. It is important to avoid reaching out to the AHJ for pre-approval or screening of the AMMR's suitability, as this is not the standard procedure. The approval of an AMMR is contingent upon the information provided for evaluation. Let us collaborate to aid our communities by steering clear of shortcuts that could potentially hinder the review process that has been diligently established to serve all customers effectively and equitably.

I’m fairly confident that if you follow what I’ve explained above and consider each step carefully then if there is an alternate method that you would like to use or need to use it will hopefully be easier for you. Again, just remember that this is a process of consideration and not a process of guaranteed approval. It can be denied and added fees will still need to be paid for this added service.