Project Review Process for Plan Check and Inspection
- Introduction to ADA Coordinator Review: Architectural Access for City Projects
- Who Needs to Comply?
- ADA Coordinators/Contact Information
- Documenting Approval by MOD (or DPW)
- MOD Project Approval Procedure
- The Three Different Phases of Review
- Preliminary Review
- Plan Review
- Field Inspection
- Appeals Process
Introduction to ADA Coordinator Review: Architectural Access for City Projects
The Mayor’s Office on Disability (MOD) is the City’s overall ADA Coordinator, responsible for ensuring that all City programs, services, and facilities are accessible as required under the ADA. MOD provides architectural plan check and field inspection services to ensure that all City-owned or City funded construction projects (City Projects) comply with the architectural access standards in the ADA, whether that work is performed by City staff or private construction contractors working on behalf of the City of San Francisco.
MOD works with the City’s other ADA Coordinators at the Department of Public Works (DPW), the PORT, and the Airport to achieve consistent enforcement of the architectural access provisions in the ADA since public funding triggers compliance with Federal access laws and requirements that are not otherwise found in the California Building Code (CBC). This process was established by the Mayor of San Francisco, through executive order dated June 22, 1998, to ensure that all construction projects undertaken by the City's Departments are accessible to and usable by persons with disabilities.
Who Needs to Comply?
City Projects must be reviewed by either the Mayor’s Office on Disability (MOD) or the DPW Disability Access Coordinator (DPW DAC). DPW DAC reviews projects designed, managed, or built by DPW, and MOD reviews the rest including publicly funded affordable housing. The PORT and the Airport have their own ADA Coordinator reviews for projects under their jurisdiction.
ADA Coordinators/Contact Information
MOD Projects. New Construction or alteration projects conducted by or on behalf of other City and County of San Francisco departments or agencies, and architectural barrier removal projects funded in whole or in part by MOD are to be reviewed by the MOD ADA Coordinator. MOD charges plan check fees for this service and the fee schedule is included on the project intake form (pdf). Jim.Whipple@sfgov.org, (telephone 415- 554-6789, Fax 415-554-6159, TTY 415-6799).
DPW Projects. New construction and alteration projects designed and managed by DPW are reviewed by the DPW ADA Coordinator. Kevin.W.Jensen@sfdpw.org telephone 415-557-4685, fax 558-4519, TTY 558-4088
Port of SF Projects. New construction and alteration projects conducted by or on behalf of the Port of San Francisco are reviewed by the Port's ADA Coordinator, Wendy Proctor, firstname.lastname@example.org, telephone 415-274-0592.
San Francisco Airport. New construction or alteration projects at SFO are reviewed by the Airport ADA Coordinator Jose Garcia, email@example.com, telephone 650-821-5515, fax 650-821-7779.
Documenting Approval by MOD (or DPW)
The ADA Coordinator reviews City Projects before the plans and permits are submitted to the Department of Building Inspection (DBI). The MOD Disability Access Compliance project sign-off form (or DPW equivalent when appropriate) shall be reproduced on the cover sheet of the plans for MOD’s project approval sign-off. For projects that have a sequential review, plans will not be accepted by DBI without prior review documented sign off from the appropriate access compliance agency (MOD or DPW). For projects submitted under a parallel review process, then MOD or DPW must receive the initial plans at the same time as the other permit review agencies, and subsequent revisions must be coordinated. If you have questions about a City Project, or want to know whether MOD or DPW or will be responsible for the accessibility review, or how to obtain forms, please contact MOD at 415 554-6789, MOD@SFGOV.org or review the following detailed MOD Project Approval Procedures.
MOD Project Approval Procedure
MOD has a highly detailed plan review and field inspection process that in many cases exceeds the quality control standards at other agencies such as the Department of Building Inspection. DPW’s process is very similar to MOD’s. This is because the ADA Standards have Civil Rights provisions for non-discrimination as their foundation. There has also been extensive litigation against other Cities and Counties who failed to implement adequate quality control measures. San Francisco has been sued on multiple occasions in the past over allegations of inadequate compliance but the City’s best defense has been the implementation of rigorous quality control procedures by MOD, DPW, the Port, and the Airport.
First time users of MOD services are not always prepared for MOD’s strict requirements. We have found that the best way to manage expectations and to deliver a completed project in a reasonable time frame is by issuing clear information and direction to the architect, owner, and contractor. The following information is a step by step guide to MOD’s project review procedure, and an introduction to MOD’s different forms.
The Three Different Phases of Review
There are three distinct phases of review: preliminary review, plan review, and field inspection for work under construction.
- Preliminary Review
Project Intake Form: Preliminary review of any MOD architectural access project starts with the completion of MOD’s Project Intake Form (word).
This form provides basic information including project address, contacts, description, building occupancy, valuation, and funding source. The funding source is relevant because Federal Funding triggers additional code requirements beyond the minimum set for other publicly funded projects.
The Project Intake Form also contains fee tables (one for new construction, and a second for alterations) and a fee invoice that helps the user calculate the permit fees required for MOD’s review.
Pre-Application Plan Review Meetings: MOD recommends a Pre-Application Plan Review meeting as a Best Practice before you submit permit documents and plans for large or complex projects. This is an opportunity to show MOD staff conceptual drawings, to ask general questions about applicable codes, to discuss the MOD process including current turn around expectations, and to ask specific code questions about conditions that may be unique to your project. Meeting minutes confirming key decisions can then be scanned onto construction drawings.
MOD also participates in pre-application plan review meetings held at the Department of Building Inspection. Such meetings typically include representatives from DBI, Fire, and Planning Departments. This promotes better communication across the different departments and helps to support the permit applicant by delivering clear and consistent guidelines.
Codes and Standards: Prior to developing any plans or scheduling any meetings, MOD recommends that the design and construction team have access to the current edition of the California Building Code (CBC), the 2010 ADA Standards, the Fair Housing Amendments Act Design Manual, the Uniform Federal Accessibility Standard, and other applicable codes. Many of these access standards, with the exception of the CBC, are available on line.
- Plan Review
For sequential plan review, MOD is the first plan review station in the building permit review process. MOD must approve the plans for accessibility before the Department of Building Inspection (DBI) will accept them for permit processing. For parallel permit processing, MOD needs to receive the plans at the same time as the other permit review agencies such as DBI, Planning etc.
Plan Review: Plan review starts when you submit the Project Intake Form, make payment for plan review and field inspection services, and provide one full size set of construction plans.
MOD’s Disability Access Compliance (pdf) project sign off form must be filled out and scanned onto the plans, preferably on the first sheet. For existing buildings only, designers must also fill out and scan a copy of DBI’s Disabled Access Checklist (pdf) onto the plans.
For certain projects that do not require a DBI building permit, like landscape projects, or park improvements, designers may submit landscape drawings, photographs, or other documents describing accessibility.
Plan Comments: MOD provides written plan review comments detailing needed corrections. The comments are sent to the Project Architect and the Project Manager typically via e-mail. As part of the comments, MOD will review any unreasonable hardship requests, provide guidance for technical infeasibility documentation, and make recommendations to DBI.
Plan Corrections: The Project Architect must submit revised plans responsive to plan comments (if corrections are required). When submitting revisions, a summary memo or sheet must accompany the plans and explain which sheet and detail number addresses MOD’s request for corrections. Note: Incomplete plans, plans which lack summaries, or uncorrected plans, will lead to project delays and potentially additional MOD permit fees.
Plan Approval: Once MOD receives final plans and confirms all corrections have been made; MOD will stamp two sets of plans “Approved”. The third set will be retained by MOD. MOD also stamps and signs the building permit application.
- Field Inspection
Start Work Inspection: MOD recommends a Start Work Inspection as a Best Practice. This can occur after the foundations have been poured, but before the framing has advanced very far. The purpose for this inspection is to meet with the architect, contractor, and owner for a discussion about required MOD inspections and recommendations for avoiding common construction errors.
Framing Inspection: A rough frame inspection by MOD is mandatory for most MOD projects. This inspection occurs after plumbing and electrical rough work has been installed and inspected, before the rough frame sign off by the DBI Building Inspector, and before insulation and sheetrock have been installed. MOD looks for grab bar blocking, minimum accessibility clearances around doors and hallways, and the rough in locations for accessible plumbing and electrical fixtures and devices. Any non-complying items found will be documented with either a correction notice or notes on the DBI Job Record Card. When the rough frame work is approved, MOD signs off on the Job Card.
Mock-Up Inspections: MOD recommends mock-up unit inspections as a Best Practice on large projects, especially accessible and affordable housing development. Grab bar blocking locations, door swings, fixture clearances in tight spaces, and adaptable cabinets are typical items reviewed in a mock-up before the project replicates repeating elements.
Pre-Finals and Temporary Certificates of Occupancy (TCO): MOD recommends calling for a pre-final inspection as a Best Practice at least a week or more before the project needs either a Temporary Certificate of Completion or a Final Inspection. Any non-complying items found will be documented with either a correction notice or notes on the DBI Job Record Card. When the TCO is approved by MOD, MOD confirms their approval for the TCO on either the DBI Job Card or DBI’s TCO form. Calling early allows the contractor enough time to make corrections before MOD’s required sign off and approval of a TCO.
Final Inspections and Certificates of Final Completion (CFC): A Final Inspection by MOD is mandatory for all MOD projects. When the Final is approved by MOD, MOD confirms their approval by signing the DBI Job Card. When the scope of work is for a new building or a change in use or occupancy, then the Department of Building Inspection will additionally prepare a Certificate of Final Completion.
The Department of Public Works and the Mayor's Office on Disability are the primary departments responsible for the access review of city-funded projects. On those occasions when architects (or developers) have disagreed with findings of the ADA Coordinator or compliance Officer making a decision, previously there was no formal process to review the decision or have a neutral body respond.The following is the appeal process that has been created.
A. What types of issues may be appealed?
Federal, State, or Local access code interpretations
B. Who may file an appeal?
Project Managers, Project Architects and Project Engineers with the approval of the Bureau Managers, Private architects or developers in contact with the City for projects that MOD reviews.
C. When do I need to appeal?
For site reviews, the appeal should be made as soon as possible, but within 20 business days of receiving the punch list. For plan reviews an appeal should be filed within 30 business days from the receipt of plan comments. No appeal will be accepted after the project has been advertised for bid.
D. How do I file an appeal?
- Submit an appeal in writing.
- Attach a cover letter describing the issue being appealed.
- Include the Project Name, Job Order #, Project Manager's Name & Phone #, and Appellant's Name & Phone #.
- Provide a map of the area as appropriate.
- Provide drawings as appropriate.
- Provide pictures as appropriate.
- Submit the above information/material to the Director of MOD for projects reviewed by MOD and to the Director of DPW for projects reviewed by DPW
E. How will the appeal be handled?
- The Director of Public Works or the Director of MOD will designate a panel of 3 people who will review the information/material.
- The panel will consist of two code experts and one neutral, but knowledgeable party. (The neutral, knowledgeable party is intended to provide a common sense perspective, should the experts disagree.)
- If needed, the panel will meet with the appellant and with the ADA Coordinator.
- The panel will issue their recommendation to the Director.
- The Director will make the final decision.