Attachment J.6- P100 2024 Final.pdf

P100

P100

FACILITIES STANDARDS

FOR THE PUBLIC BUILDINGS SERVICE

May 2024

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Figure 1(Cover): U.S. Courthouse San Antonio, TX

Figure 2: U.S. Courthouse Interior San Antonio, TX

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TABLE OF CONTENTS

Contents P100

Table Of Contents Introduction to P100 Updating P100

CHAPTER 1 • GENERAL REQUIREMENTS

1.1 Purpose of the Facilities Standards

1.2 Application of P100

1.3 Federal Laws, Regulations, and Standards

1.4 Nationally Recognized Codes and Standards

1.5 State and Local Codes

1.6 Program-Specific Guides and Standards

1.7 Safety and Health Risk Reduction

1.8 General Procedures

1.9 Sustainability

1.10 Resilience

CHAPTER 2 • COMMUNITY PLANNING AND LANDSCAPE DESIGN

2.1 Community Planning Performance Table

2.2 Community Planning Performance Attributes

2.3 Community Planning, Design, and Site Requirements

2.4 Landscape Performance Table

2.5 Landscape Requirements

CHAPTER 3 • ARCHITECTURE AND INTERIOR DESIGN

3.1 Enclosure Performance Table

3.2 Enclosure Performance Attributes

3.3 Enclosure Requirements

3.4 General Architecture

3.5 Interior Construction Performance Table

3.6 Interior Construction Performance Attributes

3.7 Interior Finishes Performance Table

3.8 Interior Finishes Performance Attributes

3.9 Interior Requirements

3.10 Workplace Requirements

CHAPTER 4 • STRUCTURAL AND CIVIL ENGINEERING

4.1 Structural Performance Table

4.2 Structural Performance Attributes

4.3 Structural Requirements

4.4 Physical Security Performance Table

4.5 Physical Security Performance Requirements

4.6 Civil Performance Table

4.7 Civil Performance Attributes

4.8 Prescriptive Civil Requirements

4.9 Geologic Hazard Report

CHAPTER 5 • MECHANICAL ENGINEERING

5.1 Mechanical Performance Table

5.2 Mechanical Performance Attributes

5.3 Mechanical Prescriptive Requirements

5.4 Plumbing

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5.5 Operability and Maintainability

5.6 Alterations in Existing Buildings

CHAPTER 6 • ELECTRICAL ENGINEERING

6.1 Lighting Performance Requirements

6.2 Lighting Performance Attributes

6.3 Lighting Prescriptive Requirements

6.4 Electrical Performance Requirements

6.5 Prescriptive Electrical Engineering Requirements

CHAPTER 7 • FIRE PROTECTION

7.1 Goals and Objectives

7.2 References

7.3 Fire Safety During Projects

7.4 Means of Egress

7.5 Interior Finishes

7.6 Fire Alarm and Emergency Communication Systems

7.7 Water Supply for Fire Protection

7.8 Automatic Sprinkler and Standpipe Systems

7.9 Non-Water-Based Fire Extinguishing Systems

7.10 Elevator Systems

7.11 Special Fire Protection Requirements

7.12 Required Design Guides and Manuals

7.13 Historic Structures

7.14 Mass Notification Systems

7.15 Carbon Monoxide Detection

7.16 Performance-Based Design

7.17 Commissioning Fire Protection and Life Safety Systems

7.18 Integrated Fire Protection and Life Safety System Testing

CHAPTER 8 • DESIGN STANDARDS FOR SPECIALTY SPACES

8.1 U.S. Courts

8.2 LPOE (Future)

8.3 Mailrooms

8.4 Indoor Firing Ranges

8.5 Electric Vehicle Supply Equipment (EVSE)

APPENDIX

A.1 General Submission Requirements A.2 Performance Matrix A.3 Definitions A.4 Submittal Matrix A.5 Surveys and Geotechnical Reports A.6 Life Cycle Cost Analysis Requirements B.1 References B.2 Acronyms and Abbreviations C.1 Summary of Changes from the 2022 Addendum

CREDITS

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INTRODUCTION TO P100

Through its Public Buildings Service (PBS), the U.S. General Services Administration (GSA) contracts for the design, construction, and operation of federal civilian buildings. PBS provides workspace primarily with courthouses, land ports of entry, and federal office buildings. It ranks among the largest holders of real estate in the United States.

The Facilities Standards for the Public Buildings Service (P100) establishes mandatory standards and criteria for its owned inventory and lease construction facilities that the Government intends to own or has an option to purchase. P100 applies to many project types and sizes across the country and its users span the entire spectrum of building professional disciplines. P100 informs and regulates decisions made throughout a project's life. This document contains both performance-based standards and prescriptive requirements to be used in the programming, design, and construction of GSA buildings.

UPDATING P100

P100 is on a three-year update schedule which closely aligns with other codes and standards.

Addendums may be issued in the interim to reflect new legislation, executive orders, or significant updates. A GSA Steering Committee is responsible for updating requirements and working with industry on new developments. The latest updates, guidance, and training are available at www.gsa.gov/p100.

Change proposals are accepted through this form. Proposals will be reviewed for the next update or addendum. Questions about P100 or the update process can be directed to p100@gsa.gov.

Figure 3: Jonas Federal Building and U.S. Courthouse Charlotte, NC http://www.gsa.gov/p100 http://www.gsa.gov/p100 https://docs.google.com/forms/d/e/1FAIpQLSezIqJZ3iT7s-LgmT49SwbQWYj_lPk-g-p8VNoBPHI9Q-m33g/viewform?usp=sf_link

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CHAPTER 1 • GENERAL REQUIREMENTS

GENERAL REQUIREMENTS

Figure 4: Jonas Federal Building and U.S. Courthouse Interior Charlotte, NC

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The design team must review and show compliance with the building program and performance at each stage of the project, as required in Appendix A. This ensures that the requirements of the program, P100, and relevant codes and standards have been met and to guard against unplanned expansion of the program because of design and engineering choices.

All prospectus-level projects are required to follow the Design Excellence Policies and Procedures

1.1 PURPOSE OF THE FACILITIES STANDARDS

P100 is a mandatory standard. It is not a guideline, textbook, handbook, training manual, nor substitute for technical competence. P100 represents the current state of practice in designing facilities to meet GSA’s commitments, maximize the efficiency of business processes, and comply with the requirements of law.

P100 must be used in conjunction with the governing standards referenced in this document, as well as the building program for each project. If conflicts exist between the facilities standards and a specific program or project requirements, contact the PBS Office of Architecture and Engineering for resolution.

Since 2014, P100 has moved to more performance-based requirements. A large portion of the standard now specifies levels of performance, allowing a project team and GSA's other professional partners to identify and implement the best strategies to meet those goals.

Design Excellence Policies and Procedures identifies the Regional Project Management Team (RPMT) as the primary contact for design and construction projects. The RPMT is made up of the regional project manager, the contracting officer, and the regional chief architect. The RPMT have many responsibilities related to the implementation of P100 and are referenced throughout for resolutions and access to certain information.

In general, four levels of performance are defined throughout P100 in matrices. It is the RPMT’s responsibility to use the P100 Performance Matrix to document the “baseline” performance for their project. Different building types may have a higher starting threshold, and the Matrix attempts to identify these cases, but the program specific guides listed in P100 provide the final requirements. Each project may implement any combination of performance levels to prioritize opportunities that stem from climate, site, program, mandates, and other conditions. Performance goals must be validated at various phases of design with Design Excellence and through construction with total building commissioning.

Links to documents, websites, and other information are provided throughout P100 for convenience. It is the design team’s responsibility to use the correct reference or information at the time of project solicitation.

1.2 APPLICATION OF P100

Once issued, P100 is required and must be listed in the initial contract for a project advertised after the issuance date. A new P100 is not retroactive to contracts that are already underway or to existing facilities, equipment, structures, or installations that have no projects.

http://www.gsa.gov/designexcellence http://www.gsa.gov/p100

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P100 applies regardless of the funding source. Thus, P100 applies equally to projects funded through BA51 New Construction, BA54 Minor Repairs and Alterations, and BA55 Major Repairs and Alterations, BA61 Operating Funds (including work performed under operations and maintenance contracts), BA63 Energy Rebates, BA64 Historic Preservation, as well as customer-funded projects through BA80 Reimbursable Work Authorization and privately financed projects such as an Energy Savings Performance Contract. This document also applies to certain BA53 lease construction facilities.

1.2.1 REPAIRS AND ALTERATIONS

A repair is to restore an item to good working order or safe condition, to fix, or to improve a damaged condition. An alteration is any work that adds, removes, or replaces items to the building, systems, or equipment. Compliance with P100 is required for repairs including “in kind” and alterations to the extent the work is identified in the approved and funded project scope of work. A waiver is required for any deviations from P100.

Abandonment-in-place of unused elements is not permitted within the scoped work area of a repair or alteration. Further removal may be required by code.

1.2.2 LEASE CONSTRUCTION

Lease construction is new construction of a facility for Government use required by GSA’s formal Request for Lease Proposals (RLP).

P100 must be included where GSA's formal Request for Lease Proposal (RLP) has an option for GSA to purchase the building at a future date. The requirements of P100 will be included in the RLP on a case-by-case basis, in consultation with the Chief Architect. Exclusion of P100 from lease construction facilities where GSA's formal RLP has an option for GSA to purchase the building requires Chief Architect written approval. In addition to the GSA-adopted nationally recognized codes and requirements, state and local government codes apply. If a conflict exists between applicable state and local government codes and the GSA requirements, the developer must identify these conflicts in writing and request a resolution from the GSA contracting officer.

1.2.3 TENANT IMPROVEMENTS

Tenant Improvements (TI) are the customized alterations GSA makes to configure the space for the needs of the tenant.

The GSA PBS Pricing Desk Guide (PDG) defines the policies used by PBS to price real estate and related services to federal customer agencies.

PDG sets policy for the entire PBS owned and leased portfolio, provides pricing direction for both cases and special circumstances. It is designed to guide PBS employees in the performance of their work and serve as a resource for Customer Agencies seeking a more thorough understanding of the PBS Pricing Policy and its application.

Utilize the latest PDG edition at the time of project solicitation. Coordinate Tenant Improvement alterations and renovations with the PBS P-120 cost and schedule management requirements.

1.2.4 DEVIATIONS FROM P100

https://www.gsa.gov/real-estate/real-estate-services/rental-policy-and-procedures/pricing-policy

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1.2.4.1 WAIVERS

Deviations from P100 require an approved waiver except as noted below. Project teams seeking relief from requirements must establish the technical hardships that make compliance impossible.

Alternatively, requests for waivers may demonstrate that non-compliance is life cycle cost beneficial.

Budget and/or time constraints are not technical hardships and will not be considered as they do not ensure the life cycle cost benefits of GSA's real estate investments. Waivers must be requested in writing by the regional commissioner or designee and approved by the Office of Architecture and Engineering before the final concept submission is presented. The following deviations utilize other processes:

• Waivers for addressing the requirements in Chapter 7, Fire Protection, are not permitted. However, alternative, and equivalent compliance requests for deviations from the requirements in Chapter 7 require an approved alternative and/or equivalent compliance solution in accordance with the requirements in Chapter 1 Alternative and Equivalent Compliance. Such requests for alternative and/or equivalent compliance must also include a concurrence signature from the regional Fire Protection Program Office and follow a similar approval process as the waiver process.

• Waivers or modifications from the Architectural Barriers Act Accessibility Standard (ABAAS) must be approved by the Commissioner of PBS. The ABAAS process is explained in the "National Accessibility Program—Standards, Policies and Procedures"

• Metric Waivers—See GSA Metric Order, GSA Metric Program, for guidance.

1.2.4.2 ALTERNATIVE AND EQUIVALENT COMPLIANCE

GSA encourages the development of new and innovative building systems. The provisions of this document are not intended to prohibit the use of alternative systems, methods, or devices not specifically addressed by P100. The use of alternative systems, methods, or devices is permitted to meet the intent of the prescribed requirements in P100 were approved as being equivalent. All technical documentation for alternatives must be submitted and approved by the regional program office prior to final concept submission. Proposed alternatives must be equivalent or superior to P100 requirements concerning quality, cost, strength, effectiveness, fire resistance, durability, efficiency, and safety. All proposed alternatives must be accomplished within the project budget and schedule. The approved alternative will be recognized as being an equivalent design solution and compliant with P100. The use of an alternative and equivalent compliance method is not to be considered a waiver.

1.2.4.3 NEWER VERSIONS OF P100

Project teams may choose to apply a newer version of P100 to ongoing projects. If the design team determines benefits to the project from the newer version, they must document potential changes for the appropriate sections of P100 to submit to the RPMT. If approved, a copy of the documentation must be submitted to the central office P100 Waiver Program Manager.

1.3 FEDERAL LAWS, REGULATIONS, AND STANDARDS

The following are federal laws, regulations, and standards applicable to all projects.

1.3.1 PUBLIC BUILDINGS AMENDMENTS OF 1988

https://www.gsa.gov/system/files/National_Accessibility_Program_Standards_Policies_and_Procedures_2-1.pdf https://www.gsa.gov/system/files/National_Accessibility_Program_Standards_Policies_and_Procedures_2-1.pdf https://www.gsa.gov/directives-library/gsa-metric-program-1

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The Public Buildings Amendments of 1988, 40 USC §3312, require that each building constructed or altered by GSA, or any other federal agency must, to the maximum extent feasible, comply with one of the nationally recognized model building codes and with other applicable nationally recognized codes.

These projects must consider local zoning laws and other local requirements. It also provides for state and local government consultation, review, and inspection and requires the agency to give due consideration to state and local government recommendations.

1.3.2 ENVIRONMENTAL PROTECTION

In addition to building-specific codes, GSA projects must comply with applicable federal, state, and local environmental, energy efficiency, and greenhouse gas emission laws, regulations, and executive orders if more stringent than P100. Project teams are advised to collaborate with the GSA regional environmental coordinator and the Office of Architecture and Engineering for assistance during the design process.

Among the key mandates is the National Environmental Policy Act (NEPA). NEPA requires that federal agencies consider and document the environmental impacts of proposed actions as part of their decision process. Although NEPA activity often takes place prior to design start, it is vital that project teams are aware of any assertions or commitments GSA made during the NEPA process, to ensure that these are adhered to during design. Depending on the outcome of the NEPA process, relevant commitments, or assertions as to the scope, strategy or scale of the project may be found in a Finding of No Significant Impact (FONSI), a Record of Decision (ROD), or even a Categorical Exclusion (CATEX). The project team must be aware of these legally binding commitments and must address them, as appropriate, in the project design.

1.3.3 ENERGY AND SUSTAINABLE DESIGN

Legislation directed toward energy efficiency and sustainability continues to increase.

Laws, regulations, and Executive Orders affecting the design and operation of federal buildings include:

• EO 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability

• EO 14008 Tackling the Climate Crises at Home and Abroad

• EO 13990 Protecting Public Health and the Environment and Restoring Science to Tackle the Climate

Crisis

• Energy Act of 2020

• Energy Independence and Security Act of 2007 (EISA 2007)

• Energy Policy Act of 2005 (EPAct 2005)

• Guiding Principles for Sustainable Federal Buildings (Guiding Principles)

• Resource Conservation and Recovery Act of 1976 (RCRA)

1.3.3.1 ENERGY REBATES (BA63)

Project teams must pursue utility rebate and incentive programs and any government grant or incentive programs at the local, state, and federal level. Project teams are encouraged to contact the local utility as early in the design process as possible to determine if the project qualifies for a financial incentive or rebate, as local utilities often offer “custom” or unadvertised rebates. Rebate checks must be submitted to GSA.

https://www.sustainability.gov/pdfs/guiding_principles_for_sustainable_federal_buildings.pdf

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Examples of projects that are typically eligible for rebates or incentives include the following:

• Building envelope improvements (windows, roofing, doors, weather stripping)

• HVAC upgrades and new installations (boilers, chillers, VFDs, tune ups, controls, etc.)

• Lighting retrofits (LED upgrades, controls, etc.)

• Appliance purchases (cafeteria equipment, water heaters, etc.)

1.3.4 HISTORIC PRESERVATION

The National Historic Preservation Act (NHPA) of 1966 mandates that federal agencies use historic properties to the greatest extent possible and strive to rehabilitate them in a manner that preserves their architectural character, in accordance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties (36 CFR §67).

Further, projects impacting historic properties must comply with NHPA’s Section 106 process. This process often results in GSA making legal commitments to execute the project in a certain way. In most cases, the Section 106 consultation process, and any resulting agreement documents, should be completed prior to the issuance of a FONSI or a ROD. As with NEPA, the project team must be aware of these commitments and must address them in the project design documents. Project teams must consult with GSA’s Regional Historic Preservation Officer for assistance.

1.3.5 THE ARCHITECTURAL BARRIERS ACT ACCESSIBILITY STANDARD

(ABAAS)

GSA policy is to make all federal buildings accessible without the use of special facilities for persons with disabilities. The intent of this policy is to use standard building products set at prescribed heights and with prescribed maneuvering clearances to allow easy access by disabled employees and visitors. Building elements designated specifically for use by persons with disabilities should be kept to a minimum.

ABAAS is mandatory for all GSA projects. If local accessibility standards exist, the design team must follow the most stringent requirements between the local standards and ABAAS.

The criteria of this standard must be considered a minimum in providing access for persons with disabilities. Dimensions that are not stated as “maximum” or “minimum” are absolute. All dimensions are subject to conventional industry tolerances except where the requirement is stated as a range with specific minimum and maximum end points. The accessibility requirements of the I-codes can only be used if more stringent than ABAAS.

1.3.5.1 ACCESSIBLE PUBLIC ENTRANCES

All public entrances provided in accordance with Paragraph F206.4.1 (Public Entrances) of the ABAAS must have at least one entrance door complying with Section 404.3 (Automatic and Power-Assisted Doors and Gates) of the ABAAS. Where an accessible public entrance has a vestibule with exterior and interior entrance doors, at least one exterior door and one interior door must comply with Section 404.3.

1.3.6 OCCUPATIONAL SAFETY AND HEALTH REGULATIONS

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The Department of Labor Occupational Safety and Health Administration (OSHA) does not directly regulate facility design; however, the construction, operation, and occupation of facilities must comply with OSHA regulations. The design team must ensure that facilities can be constructed in a manner compliant with 29 CFR §1926; the design must anticipate facility operations and maintenance and ensure they can be performed in compliance with 29 CFR §1910; and must not subject building occupants to conditions in violation of 29 CFR §1910.

1.3.7 RANDOLPH-SHEPPARD ACT

The Randolph-Sheppard Act provides qualified blind persons the opportunity to operate businesses on federal, state, or other property. The design team must coordinate design with the vending facility operators to meet the needs of vendors covered by the act.

1.3.8 BUY AMERICAN ACT

Only domestic construction materials must be specified in construction contracts performed in the United States except when a waiver to the Buy American Act is granted or per the requirements in

FAR 25.2.

1.3.9 FACILITY DEFINITIONS

1.3.9.1 ESSENTIAL FACILITIES

The International Building Code (IBC) has defined essential facilities as “Any building and other structure that are intended to remain operational in the event of extreme environmental loading from flood, wind, snow or earthquake". Buildings and other structures designated as essential facilities include but are not limited to: Group I-2 occupancies that have surgery or emergency treatment facilities, aviation control towers, or fire and police stations.

1.3.9.2 CRITICAL ACTION FACILITIES

The Department of Homeland Security Federal Emergency Management Agency has defined a facility as "Critical Action” when even a slight chance of flooding is too great. If critical action structures must be located within a 1-percent-annual-chance (also known as the 100-year), 0.2-percent-annual-chance (500-year) or the Federal Flood Risk Management Standard (FFRMS) floodplain (i.e., there are no practicable alternatives), critical infrastructure must be elevated above the applicable floodplain elevation. Critical actions include, but are not limited to:

• storage of irreplaceable records

• the production, use, or storage of highly volatile, flammable, explosive, toxic, or water-reactive materials

• hospitals and nursing homes, and housing for the elderly, which are likely to contain occupants who may not be sufficiently mobile to avoid the loss of life or injury during flood and storm events.

The critical action designation is established under the decision-making process outlined in the accompanying Desk Guide for GSA Order PBS 1095.8A, Floodplain Management. The U.S. Courts has determined that all new court houses are critical action facilities. Refer to Chapter 4, Flood Resistant Design Requirements.

https://www.gsa.gov/directives-library/floodplain-management-1

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1.3.9.3 MISSION CRITICAL FACILITIES

The tenant will determine this designation during project development. A mission critical facility contains any operation that, if electrical supply is interrupted, will cause a negative impact on business activities, ranging from losing revenue to jeopardizing legal conformity, and loss of life. Examples may include data centers, hospitals, laboratories, public safety centers, court houses, land ports of entry, research facilities, law enforcement, and critical file and payroll centers. See Chapter 1, Resilience, Chapter 3, Enclosure, Chapter 5, Wildfire Smoke Mode, and Chapter 6, Primary Distribution for requirements.

The Federal Data Center Enhancement Act notes a "growing need for Federal agencies to use data centers and cloud applications that meet high standards for cybersecurity, resiliency, and availability".

The minimum requirements applicable to data centers will be documented and published by the IT Modernization Division (GSA). Please contact dccoi@gsa.gov for more information.

1.3.10 PROHIBITION OF FORCED OR CHILD LABOR

The Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), the Uyghur Forced Labor Prevention Act and FAR clauses prohibit products created with forced or child labor.

It is the design team's responsibility to specify products that do not use such labor. Utilize tools from Design for Freedom, Cradle to Cradle, B-Corp, SA8000 and others to select materials that comply with law.

1.4 NATIONALLY RECOGNIZED CODES AND STANDARDS

For all design and construction work that GSA performs on federal buildings, or those functions under GSA’s construction authority, GSA has adopted the technical requirements of the nationally recognized codes and standards referred to in this subsection. The technical requirements of these codes and standards are supplemented by mandates of federal laws and Executive Orders, as well as GSA and other federal agency criteria. The latest published edition of these codes and standards, in effect at the time of project solicitation, must be used throughout design and construction of the project.

All new work not identified in P100 is required to meet or exceed the applicable national codes and standards adopted by GSA. If a major portion of the building or an entire building component is being renovated, which affects/impacts multiple codes, the specific codes must be evaluated to determine if the building or component must be brought into compliance with those codes. Any questions or concerns must be discussed with the RPMT.

1.4.1 CONFLICTS BETWEEN CODES OR STANDARDS AND GSA

REQUIREMENTS

To ensure flexibility, GSA’s policy is to make maximum use of equivalency clauses in the required codes and standards. If a conflict exists between GSA requirements and the GSA-adopted codes or standards, the GSA requirements take precedence. All such conflicts must be brought to the attention of the RPMT as appropriate for resolution.

1.4.2 ICC INTERNATIONAL CODES

https://www.gsa.gov/technology/government-it-initiatives/it-modernization https://www.gsa.gov/technology/government-it-initiatives/it-modernization

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GSA has adopted the technical requirements of the International Codes, or I-Codes published by the International Code Council (ICC). The International Green Construction Code (IgCC) is required as referenced in specific sections of P100. Exceptions to the I-Codes are noted below. Follow link to the ICC I-Codes.

1.4.3 NFPA LIFE SAFETY CODE

GSA has adopted the technical egress requirements of the National Fire Protection Association (NFPA), Life Safety Code (NFPA 101), in lieu of the technical egress requirements of the IBC. Follow link to The Life Safety Code.

1.4.4 NFPA NATIONAL ELECTRICAL CODE

GSA has adopted the technical electrical requirements of the NFPA, National Electrical Code (NFPA 70).

Follow link to the National Electrical Code.

1.4.5 NATIONAL STANDARDS

Organizations writing voluntary national standards, including NFPA; the American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE); the Sheet Metal and Air Conditioning Contractors’ National Association (SMACNA); the National Roofing Contractor Association (NRCA); the Institute of Electrical and Electronics Engineers (IEEE); and the American Society of Mechanical Engineers (ASME), publish standards on health, safety, welfare, and security that are recognized by GSA in various chapters of P100. Consistent with GSA’s long-standing policy to comply with nationally recognized standards to the extent practicable, these standards must be used as indicated in P100. The latest edition of the nationally recognized standards herein, in effect at the time of project solicitation, must be used during design and construction.

1.4.6 WILDLAND URBAN INTERFACE

Each building must comply with the latest edition of the International Wildland-Urban Interface Code (IWUIC), promulgated by the International Code Council, if the building is at moderate or greater wildfire risk as defined in the IWIUC, using the USDA “The 2010 Wildland-Urban Interface of the Conterminous United States” map.

1.4.7 INTERAGENCY SECURITY COMMITTEE RISK MANAGEMENT PROCESS

FOR FEDERAL FACILITIES

The Risk Management Process for Federal Facilities: An Interagency Security Committee Standard (ISC) (current edition) defines the criteria and processes that those responsible for a facility's security use in determining its security level. This standard provides an integrated, single source of physical security countermeasures and guidance on countermeasure customization for all nonmilitary federal facilities.

The ISC standard incorporates several appendices (For Official Use Only - FOUO) that are not repeated here. Refer to the ISC standard for more information.

The Facility Security Committee (FSC), consisting of representatives of all federal tenants in the facility, the security organization (for example: Federal Protective Service (FPS) for General Services Administration (GSA) owned and operated facilities), and the owning or leasing department or agency, determines the Facility Security Level (FSL) for the facility.

http://www.iccsafe.org/ http://www.iccsafe.org/ http://www.nfpa.org/ http://www.nfpa.org/ http://www.nfpa.org/ https://www.cisa.gov/sites/default/files/2022-11/The%20Risk%20Management%20Process%20-%202021%20Edition_2.pdf https://www.cisa.gov/sites/default/files/2022-11/The%20Risk%20Management%20Process%20-%202021%20Edition_2.pdf

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In general, the FSC is responsible for addressing the facility-specific security issues addressed in the facility security assessment and approving the implementation of security criterion (aka countermeasures) and practices recommended by the security organization. The implementation may be a combination of operational and physical security measures based on the FSL, and the level of protection (LOP) that is deemed both appropriate and achievable. Physical security countermeasures may include architectural, interior design, landscape design, structural, mechanical, and electrical design requirements as part of the security criterion listed in the table below.

Table 1.1 Physical Security Countermeasures

Discipline Security Criterion may include but may not be limited to:

(Note: Where discipline specific security requirements are specified and/or guidance is available, the individual P100 technical chapters provide this information)

Structural Blast Resistance - Windows Blast Resistance - Facade and Structure Blast Resistance - Progressive Collapse Blast Resistance - Under-Building Parking Burglary Resistance of Windows Walls and Non-Window Openings Windows in Critical Areas - Ballistic Protection Blast Resistance - Interior Public Spaces Blast Resistance - Mail Screening and Receiving Location Interior Windows

Mechanical Protection of Air Intakes Isolated Ventilation Systems HVAC Control CBR Detection Technology Biological Filtration - General Building Biological Filtration - Lobbies and Mailrooms Chemical Filtration Security of Ventilation Equipment and Controls Location of Utilities and Feeders Protection of Water Supply

Electrical Site Lighting Vehicle Screening lighting Location of Utilities and Feeders Separation of Emergency and Normal Power Distribution Emergency Generator Protection

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Discipline Security Criterion may include but may not be limited to:

(Note: Where discipline specific security requirements are specified and/or guidance is available, the individual P100 technical chapters provide this information)

Architecture and Interior Design Identification as Federal Facility Pedestrian Access to Site Vehicle Access Points Restricted Areas or Significant Areas and Assets Signage - Sensitive Areas Control of Parking Vehicle Access to Controlled Parking Vehicle Screening Pedestrian Access to Controlled Parking Areas Hazardous Materials Storage Receptacle and Container Placement Location of Utilities and Feeders Emergency Generator Protection Regulatory Signage Lobby Queuing Entrance Co-location Perimeter Doors & Door Locks Employee Convenience Doors Emergency Exit Doors Space Planning Access to Nonpublic Areas Security of Critical Areas Building Systems and Roof Access Publicly Accessible Restrooms Publicly Accessible Retail and Mixed-Use Space

Landscape Architecture Landscape Design Site Layout Perimeter Security

Facility Security Level Determinations and Levels of Protection (LOP) must be determined by the FSC for all new construction, renovation and major modernization projects during the requirements definition process and approved security criterion incorporated into the program of requirements. The baseline for GSA buildings is to meet the ISC Risk Management Process (current edition) and Appendices for the given Facility Security Level (FSL). See the PBS, Office of Project Delivery Project Management Guide (PM Guide) for information on Security Requirements, links to the ISC standards and guidance for developing the project program of requirements.

1.4.8 ASHRAE 90.1

The U.S. Department of Energy (DOE)’s final rule on Federal agencies’ use of ANSI/ASHRAE/IES Standard

90.1 is published at 10 CFR §433.

• GSA has determined that new building projects, must use the latest performance standard §433.100 and performance level determination as listed in §433.101, at the time of project solicitation, regardless of the start (effective) date listed by DOE.

• GSA has determined that all existing building projects must use the latest energy efficiency performance standard as listed in §433.100 (a)(5)(i) at the time of project solicitation, regardless of the start (effective) date listed by DOE.

https://www.ecfr.gov/current/title-10/chapter-II/subchapter-D/part-433

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1.5 STATE AND LOCAL CODES

Facilities built on federal property are exempt from state and local building codes. GSA recognizes that the national building codes are typically the foundation of state and local building codes, and that state and local codes represent important regional interests and conditions. In keeping with federal law (incl.

the Public Buildings Amendments of 1988 and the Federal Urban Land Use Act of 1949), it is GSA’s policy to comply with state and local building, energy, green, and construction codes to the maximum extent practicable if more stringent than P100 requirements. However, GSA has the final authority to accept or reject any recommendation from state and/or local government officials.

1.5.1 STATE AND LOCAL GOVERNMENT CONSULTATION AND REVIEW

The Public Buildings Amendments of 1988, 40 USC §3312, direct that GSA must consider all design requirements (except procedural requirements) of state or local governments, which would apply if it were not a building constructed by a federal agency before construction or alteration. This includes zoning as well as laws related to landscape, open space, building massing and orientation, and aesthetic considerations. To meet these requirements, GSA will consult in a timely manner with appropriate local officials in preparing plans for the building.

The RPMT must provide the appropriate state and/or local government officials the opportunity to review the project for compatibility with local planning, design objectives, and zoning compliance. Local reviews must occur early in project development so that the design can easily respond to appropriate recommendations. These reviews include, but are not limited to, the review of drawings and specifications, making recommendations for compliance with local regulations, compatibility with local planning goals, and alignment with first responder requirements. In most cases, collaboration with local officials required to meet these standards will be in addition to, and not a substitute for, NEPA consultation with local officials. The RPMT must inform state and local government officials that GSA and its contractors are not allowed to pay any fee for any actions taken by the state and/or local government officials in connection with local reviews or inspections. GSA will review all recommendations made by state and local government officials. Each recommendation will be carefully considered based on adequacy, cost, and nationally accepted practice. GSA has the final authority to accept or reject any recommendation from state and/or local government officials. The RPMT will maintain a record of all recommendations and comments from state and local government officials for the duration of the project.

The above requirements are also directed by the Federal Urban Land Use Act of 1949 (40 USC §901-905) and Executive Order 12072.

1.5.2 ZONING AND RELATED ISSUES

As noted elsewhere, federal law directs that GSA projects, to the greatest extent practicable, be consistent with the zoning, land-use practices, and development objectives of the local government.

Further, GSA projects that impact the public realm must be executed only after due consideration of all requirements (other than procedural requirements) of zoning laws; laws relating to landscaping, open space, building orientation and massing, historic preservation, aesthetic qualities of a building; and other similar laws of state or local government which would apply to the project if it were not a building constructed or altered by a federal agency.

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An exception to state and local codes requirements noted above are local regulations on the design of systems that have a direct impact on off-site terrain or infrastructure. GSA will incorporate these requirements into the project if more stringent than P100. These systems include, but are not limited to, fire protection services, storm water runoff, erosion control, sanitary sewers and storm drains, water, gas, electrical power, communications, emergency vehicle access, roads, and bridges.

Although federal law gives GSA latitude to determine what design strategies are practicable on each project, compliance with the letter and intent of these laws demands that project teams comply with the collaborative design requirements outlined in this document.

A P100 waiver would be required for designs that deviate from compliance with local zoning, design, and development objectives.

Finally, the project team must offer local officials a timely opportunity to review and comment on the GSA project plans for compatibility with local plans, zoning, and design guidelines. Local review must be done in coordination with the project design schedule. If local officials choose not to review the design concept, the RPMT must document this in the project file.

1.5.3 DESIGN REVIEW FOR CODE COMPLIANCE

The RPMT must provide the appropriate state and/or local government officials the opportunity to review the design for building code compliance. The RPMT will officially forward design submissions to the appropriate local officials.

1.5.4 CONSTRUCTION INSPECTIONS

If state and local government officials elect to perform code compliance construction inspections, the RPMT must include provisions in both the design team and the construction contract for coordination of the work with local officials. State and local government officials do not have the authority to reject, accept, or make changes to the work, and their inspections are done only to assist GSA in achieving code compliance.

1.6 PROGRAM-SPECIFIC GUIDES AND STANDARDS

In addition to P100, GSA and its customer agencies use several specific guides and standards that address program requirements. Use of these guides is mandatory. In case of conflicts between P100 and a specific building guide, the more stringent requirement will take precedence. If conflicts exist between the facilities standards and specific program and project requirements, contact the Office of Architecture and Engineering for clarification. Refer to the GSA Pricing Desk Guide for guidance on Tenant Improvements.

1.6.1 FEDERAL COURTHOUSES

The Office of Architecture and Engineering provides guidance on all levels of development of courthouse projects, including Congress, OMB, the Administrative Office of the United States Courts, and GSA serves as a liaison for all courthouse projects. See the RPMT for access and detailed descriptions of the publications listed below and their application:

• Capital Security Program Handbook

• U.S. Courts Design Guide https://www.gsa.gov/cdnstatic/Pricing%20Desk%20Guide%205th%20Edition%20November%2016,%202019_0.pdf

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• U.S. Marshals Service Requirements and Specifications for Special Purpose and Support Space, Volumes 1-3, Publication 64

1.6.2 LAND PORTS OF ENTRY

GSA provides guidance on the management of the border station program, including strategic planning, budgeting, benchmarking, and design guidance. For more information:

• United States Land Port of Entry Design Standard, see RPMT for access

1.6.3 CHILD CARE CENTERS

Requirements for child care centers must be incorporated early in the design and planning process. The references below provide guidance on such topics as site design, emergency evacuation, food services, safety, security, mechanical, electrical, and plumbing:

• Child Care Center Design Guide (PBS-P140)

• Accreditation Criteria and Procedures of the National Association for the Education of Young

Children (NAEYC)

• Interagency Security Committee Appendix C: Child Care Level of Protection Template (FOUO)

1.6.4 HISTORIC PRESERVATION

Performance requirements for projects affecting historic properties must be incorporated into qualification requirements, project scopes of work, and construction contracts. Project teams undertaking feasibility studies, repairs, alterations, or new construction within or adjoining historic properties must include a historical architect, architectural conservator, or preservation specialist, as applicable, who meets U.S. Department of Interior Professional Qualification Standards and GSA Qualification Requirements.

Projects affecting historic properties, including landscape modifications and infrastructure work involving ground disturbance, must follow the Secretary of the Interior’s Standards for the Treatment of Historic Properties in accordance with GSA ADM 1020.3 Procedures for Historic Properties, as directed by GSA’s Regional Historic Preservation Office. The performance level to be met within the standards will be determined by the historical architect or preservation specialist, who must be integrally involved in the design and analysis of all alternatives affecting restoration or rehabilitation zones as defined in the Building Preservation Plan (BPP) or Historic Structure Report (HSR). The minimum standard treatment is rehabilitation with viable design alternatives that avoid adverse effects on historic spaces and materials.

Each study and design submission must include a Section 106 Compliance Report documenting the development and analysis of preservation design alternatives in photographs, detail drawings, and project descriptions explaining how the recommended solutions address preservation issues raised by the project. Designs must follow applicable GSA Technical Guidelines and requirements for historic buildings in P100.

Contract documents for repair, cleaning, restoration, or alteration of historic building materials must include GSA technical competency requirements for work requiring specialized skills required to meet preservation standards.

https://www.wbdg.org/ffc/gsa/criteria/pbs-140 https://www.naeyc.org/accreditation/early-learning/process https://www.naeyc.org/accreditation/early-learning/process https://www.doi.gov/pam/asset-management/historic-preservation/PQS https://www.gsa.gov/real-estate/historic-preservation/historic-preservation-policy-tools/preservation-tools-resources/proof-of-competency-other-documentation https://www.gsa.gov/real-estate/historic-preservation/historic-preservation-policy-tools/preservation-tools-resources/proof-of-competency-other-documentation https://www.nps.gov/tps/standards.htm https://www.nps.gov/tps/standards.htm https://www.gsa.gov/directives-library/procedures-for-historic-properties https://www.gsa.gov/system/files/106Compliancereportshortform.doc https://www.gsa.gov/real-estate/historic-preservation/historic-preservation-policy-tools/preservation-tools-resources/technical-guidelines https://www.gsa.gov/real-estate/historic-preservation/historic-preservation-policy-tools/preservation-tools-resources/proof-of-competency-other-documentation

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1.6.5 FIRST IMPRESSIONS

The First Impressions program extends the vision of Design Excellence into public lobbies of federal buildings. These are the areas that shape a visitor’s “first impression” of the Federal Government. Lobby security is a critical part of these public spaces, and visitors should be able to seamlessly navigate these areas without delay or confusion. The goal is to provide guidance for creating world-class lobbies. Five action points form the foundation of the First Impressions program. These action points are applicable across projects of all scopes and funding levels.

• Reduce Clutter—A place for everything and everything in its place.

• Consolidate Functions—Cluster amenities by function, creating centrally located business centers.

• Unify Signage—A unified signage system is critical to access.

• Streamline Security—Security should not be intrusive or intimidating.

• Transform your image—The result of integrating architectural, graphic, security, and signage design.

See the First Impressions Program Guide for more information.

1.6.6 SMART BUILDINGS

GSA leads the Government in owning and operating smart buildings. Utilizing the latest technology, building systems, and programs such as GSAlink, GSA can optimize energy usage and operations. There are several Smart Building guidance documents including, but not limited to, the GSA Smart Building Program Guide, the GSA Smart Building Implementation Guide, and the GSA Data Normalization for Building Automation Systems. Please reference the GSA Smart Buildings Program Guide for guidance on developing Smart Building projects and selecting smart building attributes. The GSA Smart Buildings Implementation Guide must be referenced for guidance in specifying the smart building attributes. The GSA Data Normalization for Building Automation Systems document must be utilized for GSA standard data point naming conventions and tagging within building systems.

All these guides can be found through the RPMT at Public Buildings Service Technology Guidance InSite.

1.6.7 DESIGN GUIDE FOR OPERATIONAL EXCELLENCE

The Operational Excellence program aims to ensure the long-term durability, maintainability, and efficiency of new or renovated facilities and that operation and maintenance costs are considered as part of Design Excellence. Operational Excellence goals and objectives include:

• Eliminating or minimizing negative impacts to the building’s long-term durability, maintainability, efficiency, and utility consumption.

• Considering building spaces and systems in terms of their accessibility, durability, reliability, maintainability, and cleanability.

• Ensuring services contracts staff, including operations and maintenance, janitorial, elevator/escalator maintenance, landscape maintenance, and snow removal can safely and efficiently perform their functions.

• Taking advantage of opportunities to reduce or minimize periodic maintenance operations.

https://www.gsa.gov/real-estate/design-and-construction-overview/design-excellence-program

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• Consulting with Property Management regarding maintenance and operations implications, as well as service-enhancing and labor-reducing features that are explored and evaluated as design alternatives.

• Providing adequate training after commissioning for mechanical, electrical, plumbing, building automation, lighting control, and fire protection systems as appropriate to relevant staff.

Use of the Design Guide for Operational Excellence is required.

1.6.8 OTHER GUIDES AND STANDARDS

• GSA National Business Space Assignment Policy

• PBS P-120, Public Buildings Service Cost and Schedule Management Policy (P-120)

• Metric Design Guide (see GSA Metric Order, GSA Metric Program, for guidance)

• GSA Order on Controlled Unclassified Information

• GSA Commissioning Guide

1.7 SAFETY AND HEALTH RISK REDUCTION

Most facility safety and health risks are adequately controlled through adherence to current building codes and regulations. However, codes and regulations only provide a minimum standard of care and generally do not address unique designs or optimize safety and health risks over the facility life cycle. It should also be noted that building codes tend to focus on facility design with an emphasis on structural and fire safety issues while safety and health regulations (such as those promulgated by OSHA) are primarily employee or operationally oriented and usually do not regulate building design. Therefore, GSA requires designers take a systems approach to facility safety and health risk management to eliminate or mitigate facility life-cycle risks.

1.7.1 LOSS CATEGORIES

The following categories, potential exposures and losses must be considered:

• Occupants. Facility designs must consider the intended or potential occupancy and be designed to prevent or minimize…