Information on Revisions
Resource Material

Effective September 1, 2010, the Letters of Assurance in the BC Building Code were amended by Ministerial Order. The Letters of Assurance previously in place, including all relevant provisions in the BC Building Code (BCBC), are to be used for all projects involving a building permit application submitted before September 1, 2010. Building and Safety Standards Branch Information Bulletin No B10-03 provides an overview of the changes.

APEGBC, the Architectural Institute of BC (AIBC), the Building Officials Association of BC (BOABC) and various municipalities were included in the stakeholder consultation leading up to the amendment. Information on the proposed revisions to the Letters of Assurance including relevant changes to the BCBC was issued for public review last summer and APEGBC coordinated the submission of a detailed response through the APEGBC Building Codes Committee. A technical committee appointed by government and comprising representatives from the associations originally involved in the creation of the Letters of Assurance was then asked to draft the proposed changes. The revisions support the feedback received in response to the consultations carried out during the Modernization Strategy initiated by the BC Government in 2006 to improve the effectiveness of the building regulatory system. 

The key aspects of the revisions are summarized as follows:

1. “Registered Professional” Changed to “Registered Professional of Record”
   This change clarifies the roles and accountabilities of individuals who sign Letters of Assurance. For APEGBC this includes professional engineers and limited licensees granted the appropriate scope of practice. It was always intended that one professional sign a Letter of Assurance for each discipline. This change in wording resulted in a number of small changes throughout the Building Code. In many situations there will be additional professionals supporting the Registered Professional of Record. These supporting registered professionals (SRP) do not sign Letters of Assurance, and their role is detailed below.


2. A Single Schedule B
   To increase the efficiency of the process for Letters of Assurance, the Schedules B-1 and B-2 have been merged into a single Schedule B. This change does not alter the fundamental content of the current Schedules.


3. Part 10 (Energy and Water Efficiency) Provisions Added to the Letters of Assurance
   The Letters of Assurance have been altered to specifically reference Part 10 provisions under their respective disciplines. Since professionals are already responsible for including these provisions, this change supports this existing responsibility.


4. Expansion of the Application of Letters of Assurance in Part 9 Buildings
   Letters of Assurance do not currently apply to Part 9 buildings, except in the case of structural components that fall within the scope of Part 4, or Part 9 buildings constructed with a common egress system that requires the use of firewalls. This change expands this scope to include:

• Geotechnical components that are beyond the scope of Part 9 in Division B, and
• Sprinkler systems that are designed to NFPA 13 and standpipe and hose systems designed to NFPA 14.

The APEGBC Building Codes Committee supported each of the above four initiatives.

The change of “Registered Professional” to “Registered Professional of Record” addresses a long standing concern caused by the submission of multiple Letters of Assurance by different Registered Professionals for one discipline involving one project.  Such submissions resulted in confusion being created amongst engineers, architects, contractors, developers and authorities having jurisdiction (municipal building departments) regarding who was responsible for what aspects of the works.  With this proposed change, typically, only one Letter of Assurance is to be provided to the authority having jurisdiction for each of the eight disciplines identified on Schedule B.  The Registered Professional providing the Letters of Assurance for each discipline is the Registered Professional of Record (RPR).

An RPR should only undertake responsibility for the design and field review of items identified in the Letters of Assurance within that discipline based on their competency.  As such, an RPR, or owner, may require supplementary supporting engineering involvement for a particular item, component or sub-component, of a particular discipline.  In instances where supporting engineering services are required, it is recommended that appropriate assurance be obtained by the relevant RPR from a Supporting Registered Professional (SRP).  The SRP could be engaged by the RPR; the owner; a contractor, sub-trade or supplier providing the supporting design and or field review services.  Upon receipt of such assurance from the SRP that a particular item, component, or sub-component within the items of a specific discipline identified on Schedule B complies, in all material respect with the applicable requirements of the Code, the RPR can complete and submit the Letter of Assurance for his or her discipline.

Model Schedules S-B and S-C have been developed as part of a joint collaboration by APEGBC and AIBC so that a common document is available for use by all Registered Professionals (professional engineers, licensees and architects).  Model Schedules S-B and S-C are recommended as the mechanism for the RPR to receive assurance from the SRP providing supporting engineering or architectural services.

APEGBC first introduced the concept of the SRP with the inclusion of Schedule S in the APEGBC Bulletin K:  Letters of Assurance and Due Diligence in 2005.  With the implementation of the above referenced changes to the Letters of Assurance, AIBC and APEGBC have worked together in developing Model Schedules S-B and S-C which are jointly supported by APEGBC and AIBC.

Finally the Guide to the Letters of Assurance in the BCBC has been revised with input from APEGBC, AIBC, BOABC, the Building Safety and Standards Branch, and various municipalities.  This Guide was revised so it is consistent with the revisions made to the Letters of Assurance and to facilitate the appropriate and consistent use and application of the BCBC Letters of Assurance.  It provides guidance on:

• The scope and intent of the BCBC Letters of Assurance
• Roles and responsibilities with respect to Letters of Assurance
• When and how Letters of Assurance should be completed.

APEGBC is working on delivering a seminar this fall that will provide training on these changes to the Letters of Assurance and the associated documents that have been prepared in response to the changes.In order to maximize the seminar’s value and impact, APEGBC will be working with AIBC, BOABC, the Building and Safety Standards Branch and representatives from various authorities having jurisdiction in its development and delivery.  Information will be made available to professional engineers and licensees once the details of the seminar have been finalized.

It is APEGBC’s understanding that the City of Vancouver will be looking at making similar revisions to their Letters of Assurance in 2011.

The following is a summary of the resource materials that have been proposed to assist you in the understanding and implementation of the changes to the Letters of Assurance.