Unapproved Product Substitution and Missing Records
During a records review on a 10-story building, the inspector finds that the approved submittal lists a gypsum-based SFRM with a density of 15 pcf and a required thickness of 1 in. on columns for a 2-hour rating. The field crew has installed a cementitious SFRM with an ICC-ES evaluation report showing a 2-hour rating at 7/8 in. and 14 pcf. No RFI or change order was issued. Batch tickets are missing for floors 2 through 4, and the daily reports for those floors say only 'SFRM applied.' Thickness readings exist only for columns on floors 2 and 3. The contractor says the substituted product is 'equivalent' and wants the inspector to sign off. The inspector must decide whether the substitution can be accepted, what verification is needed, and how to report the findings.
1. Can the inspector accept the cementitious product as an equivalent substitution? Why or why not?
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No, not on the contractor's statement alone. An ICC-ES evaluation report shows that the product has been evaluated for certain fire-resistance designs, but it does not approve a substitution on this project. The approved submittal, the fire-resistance design, and the code official's acceptance are project-specific. The proposed product has a different density and a different required thickness, so the inspector cannot assume the assembly is equivalent without a written approval from the registered design professional and the code official. The contractor should submit an RFI or change order with the evaluation report, the specific assembly, and the proposed thickness and density. Until that approval exists, the installed product is an unapproved material, and the inspector should not sign off the work.
2. What records must be reconstructed or verified for floors 2 through 4?
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The inspector should require batch tickets or product labels that identify the actual material and batch used, applicator daily logs showing areas and dates of application, substrate preparation records, environmental readings, and thickness and density test results. Adhesion/cohesion test records should also be checked if the project specification requires them. The missing daily reports must be reconstructed from the applicator's records, delivery tickets, and the inspector's own field notes where possible. Thickness coverage must be extended beyond columns on floors 2 and 3 so that beams, girders, and deck areas are represented. The inspector should verify that the records match the material actually installed, not merely the material that was approved on paper.
3. How should the inspector report the missing records and unapproved product?
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The inspector should issue a written nonconformance report identifying the unapproved product, the missing batch tickets, the inadequate daily reports, and the incomplete thickness records. The report should state the applicable code or specification requirement and the corrective action needed: project-specific approval for the substitution, reconstruction of records, and additional field verification. The inspector should notify the contractor, owner, and code official as required by the project's special inspection procedures. Sign-off should be withheld until the product is approved and the records demonstrate that the installed material meets the approved design. If the product cannot be approved, the report should identify the affected areas for removal and replacement. The final inspection report should summarize the findings and the resolution, not just note that records were later provided.