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08 Submittal Review Comments

Why: Purpose

Submittal review is an important part of the commissioning process to verify the owner's project requirements.  The reason is that at this point in the project the subcontractor has the ability to deviate from the equipment basis of design.  With this ability, comes a need for diligence by the commissioning agent to verify that deviations still meet the owner's project requirements.  If not, the commissioning agent needs to reject the submittal as not compliant.
 
Catching equipment or materials that are not compliant with the design or owner's project requirements at this phase minimize costs associated with the following:
  • Removal of the equipment or material in question
  • Purchasing new equipment
  • Delays 
    • Lead time for new equipment
    • Installation
    • Affected subcontracted work
    • Inspections/ Testing
  • Repairing other affected scopes of work

Submittal review demands a licensed professional engineer to be in responsible charge when executed as part of the commissioning process.  With the potential for deviation from the design, an engineer is essential to evaluate the submitted equipment, material and information and verify it is equivalent to the basis of design and what system level effects may occur.  While the design engineer of record is ultimately responsible, the commissioning agent is an advocate for the owner and must be capable of an engineering expertise review and evaluate at a system level and not just the equipment level.

What: Included Information

 Submittal review comments should clearly indicate the deviation or descrepancy by including at a minimum:
  • Comment serial number for easier reference
  • Submittal review date
  • Submittal reference number
  • Document containing requirement
    • Specification number
    • Drawing number
    • Owner's Project Requirent
  • Requirement description
    • Direct excerpt of text from specification
    • Drawing reference with requirements listed
    • Excerpt from relevant code or standard
    • Any other direct quote of the requirement in question
  • A summary of the submitted equipment/ materials properties that appear to be non compliant
    • Note the properties in a similar fashion to the requirements for direct comparison
  • Any additional notes or comments to assist in determining extent of the deviation
As an option, the comments can include a place for the engineer of record to "Accept" or "Reject" the commissioning agent's individual comment as well as area to note why or why not. As the engineer of record, the design is ultimately their responsibility and they can decide to accept deviations from their basis of design as submitted by the subcontractor.  For instance, if the subcontractor meets the intent of the design but submits different equipment, the engineer of record may approve it.  However, if at any time the commissioing agent feels the submitted item does not meet the owner's project requirements or that it is a hazard to health or safety, they must elevate the issue for resolution.
 
The basic idea is to provide a comment that requires no additional resources or research to understand the non-compliance, deviation, or descrepancy in question.

When: Project Phase/ Task Timing

 Submittal review comments will occure during the beginning of the construction phase prior to the purchasing, fabrication or installation of the equipment being submitted.  Towards the end of the construction phase, data and information for the systems manuals and training will be submitted for review as well.

How: Development Sources

Submittal review comments are derived from comparing submitted equipment, materials, or information to the following project documents:
  • Owner's Project Requirements
  • Specifications
  • Drawings
  • Submittals
  • Requests for Information
  • Change Orders
  • Codes
  • Standards
  • General sound engineering or construction practices

Who: Team Members Involved

 The submittal  and review process can involve the following commissioning team members:
  • Commissioning Agent
  • Architect/ Engineering Team
  • Contractor/ Construction Manager
  • Subcontractor
  • Vendors
  • Manufacturers 
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