Commissioning: A Federal Agency's Perspective
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Commissioning: A Federal Agency's Perspective
How the U.S. General Services Administration has embraced the commissioning process

By David Frable | Fire Protection Engineering


"Commissioning", aka "Cx," is probably one of the most used words and acronyms being incorporated into commercial building construction projects today. For example, an Internet search for the term "commissioning" yields over 13 million responses. In addition, organizations such as the American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE), National Institute of Building Sciences (NIBS), U.S. Department of Energy (DOE), U.S. Green Building Council, American Institute of Architects (AIA), and U.S. General Services Administration (GSA) all have embraced "commissioning" to one degree or another.

Traditionally, the term "commissioning" in commercial building construction projects has referred to the process by which the building heating, ventilation and air conditioning (HVAC) systems were tested and balanced prior to the system being accepted by the building owner. However, today's use of the term "commissioning" now recognizes the integrated nature of all building systems' performance and not just HVAC system performance. In addition, commissioning is now required for any project that is considered for Leadership in Energy and Environmental Design (LEED) certification or Green Globes certification.


Although there are numerous definitions for commissioning, GSA has defined "commissioning" based on the definition of the National Conference on Building Commissioning (NCBC):


"Systematic process of assuring by verification and documentation, from the design phase to a minimum of one year after construction, that all facility systems perform interactively in accordance with the design documentation and intent, and in accordance with the owner's operational needs, including improved training of building operation personnel."1

In layman's terms, commissioning is a quality assurance and control process that provides the necessary documentation to the building owner that verifies the systems installed will perform as intended in accordance with the project's requirements. The process also ensures that the owner's personnel will be thoroughly trained in both the routine and emergency operation of all the building systems.



GSA's Public Buildings Service (PBS) is the landlord of the civilian government for over 400 federal agencies, bureaus and commissions. GSA houses in excess of 1 million federal employees in approximately 1,500 government-owned and 8,100 leased assets in approximately 2,100 communities throughout the United States, six U.S. territories and the District of Columbia; and has an on-going planning, design and construction program to meet the needs of federal agencies.


One of GSA's responsibilities is to provide federal agencies with efficient, safe, secure and sustainable commercial space. Integrating total building commissioning into GSA's construction project delivery process provides one way for GSA to meet and exceed customer expectations. Total building commissioning also provides a means for meeting the intent and requirements contained within GSA's design criteria document, the GSA Facilities Standards for the Public Buildings Service2 (PBS-P100).


The PBS-P100 establishes design standards and criteria for all new buildings, major and minor alterations, and renovations in GSA's historic building inventory. PBS-P100 also includes a chapter specifically dedicated to fire protection and life safety, which contains an outline of the procedures, methods and documentation that is required for fire protection and life safety systems during each phase of the commissioning process.

As building systems become more complex and integrated, a deficiency in one or more system components may result in substandard operation and performance among other building system components. Therefore, reducing the number of deficiencies can result in a variety of benefits such as reduction in operating costs, improved energy efficiency, improved occupant safety, improved comfort and health, and increased maintainability of systems.


In April 2005, GSA published The Building Commissioning Guide1 (Guide) to provide project managers, construction managers and consultants with a vehicle to navigate through GSA's commissioning process. According to PBS-P100, all new construction and major modernization projects are required to utilize the total building commissioning practices. The overall objective of GSA's commissioning process is to provide documented confirmation that a building fulfills the functional and performance requirements within PBS-P100.


The Guide also describes general information regarding each phase of the commissioning process as well as examples of the roles and responsibilities of each stakeholder on the project team to support the overall commissioning of a project.



GSA's commissioning process consists of four phases: planning, design, construction and post construction.


Therefore, it is necessary for the commissioning process to establish and document the project requirements which specify the criteria for each building system function, performance and maintainability; and to also verify and document compliance with these criteria throughout each phase of a project. In addition, the commissioning process will provide complete operation and maintenance manuals and training on the operation of each building system, so building operators can ensure their building will continue to operate as intended.



The planning phase lays the groundwork for the commissioning process. It is the critical phase where GSA's project requirements are developed in order to establish and document the owner's project requirements and criteria for the building system's function, performance and maintainability. The major steps of the planning phase include:

  • Identifying the commissioning team
  • Developing GSA's project requirements with all stakeholders
  • Developing the preliminary commissioning scope
  • Developing the preliminary commissioning plan
  • Establishing the initial budget for commissioning activities
The Guide states:1

The first step of the planning phase is to identify the make up of the commissioning team. The exact size and number of members of the commissioning team will vary in size depending on project type, size and complexity. Generally, the team will consist of:
  • GSA project manager
  • GSA operating personnel
  • GSA technical experts (i.e., structural, mechanical, fire protection, electrical, etc.)
  • Federal tenant agency representative(s)
  • Architect/Engineer
  • Commissioning Agent - also referred to as Commissioning Authority
  • Construction Manager
  • Construction contractor and subcontractors


The design phase is where the project design team creates the construction documents in accordance with the owner's projects requirements for items such as energy efficiency, sustainability, indoor environmental quality, fire protection and life safety, etc.1 The design phase is also the commissioning team's opportunity to assure that building systems, as designed, will function according to user expectations. During this phase, specific tests and procedures need to be developed and incorporated into the contract documents to verify the performance of systems and assemblies. The major steps within the design phase include:

  • Incorporating commissioning into Architect/Engineer (A/E) and Construction Manager (CM) scope of services
  • Retaining the services of a Commissioning Agent (CxA)
  • Reviewing the owner's project requirements and basis of design
  • Reviewing concept designs, design documents and construction documents
  • Updating the commissioning plan
  • Developing/updating the LEED checklist
  • Developing the commissioning specifications, which include written system test procedures and operator training requirements

It should be noted that, based on past experience, "maintainability" of building system components is sometimes overlooked by design team architects/ engineers. For example, maintaining lighting units, smoke detectors, fire sprinklers, exhaust fans, etc., installed at the ceiling level of an atrium may be difficult to access and thus hamper necessary preventive maintenance. Developing solutions to address "maintainability" issues at the post-construction phase can become very costly for the building owner. Therefore, it is essential that the CxA and design team address "maintainability" issues during this phase of the commissioning process.



The construction phase is the phase most associated with commissioning. However, if the previous phases and activities have not been implemented prior to this phase, it could adversely impact the entire commissioning process.


During the construction phase, the commissioning team should work to verify that systems operate in a manner that will achieve the owner's project requirements.1 The two overarching goals of the construction phase are to assure the level of quality desired and to assure the requirements of the contracts are met by completing installation, functional performance testing and training to ensure documented system performance in accordance with the owner's project requirements. Functional performance testing and documentation during this phase will also serve as an important benchmark and baseline for future re-commissioning of the facility. The major steps of the construction phase include:

  • Reviewing submittal documents which include coordination drawings, redlined as-built drawings, product data and key operations data submittals, system manuals, operation and maintenance manuals, and training programs
  • Developing and using construction checklists
  • Overseeing and documenting functional performance testing of building systems
  • Holding commissioning team meetings and report progress
  • Conducting O&M staff training
The functional performance tests are the heart of the commissioning process and they are also the most difficult and time consuming. System troubleshooting is a critical function of the CxA. As inspecting and testing proceed, despite the team's best efforts, the CxA will find a number of items that do not appear to work as intended. A certain amount of system retesting will be performed by the CxA because of system deficiencies during the initial testing. In order to assure success, the GSA PM shall allow some time in the schedule and money in the budget for retesting. The GSA PM shall be apprised that issues resolution and associated financial implications are a common point of contention between parties.1

Another area of concern involves the training of the owner's representatives and O&M staff regarding a building's fire protection and life safety systems. The owner's operations and maintenance staff must be properly trained to understand the operation of all fire protection and life safety equipment, systems, operational sequences and how they are integrated with other building systems. For example, the O&M staff may be assigned to operate the building's fire alarm emergency communication system to broadcast emergency information to the building occupants. However, if the O&M staff is unfamiliar with the operation of the fire alarm emergency communication system and that the system has the capability to broadcast messages either throughout the building or only selected floors within the building, misdirected information could be disseminated without the knowledge of the O&M staff.



The objective of the post-construction phase is to maintain building performance throughout the useful life of the building or systems. The active involvement of the CxA and the commissioning team during initial facility operations is an integral aspect of the commissioning process. The major steps of the post-construction phase include:

  • Resolving outstanding issues
  • Performing deferred and seasonal testing
  • Re-inspecting and reviewing system performance prior to the end of the warranty period
  • Completing the final commissioning report
  • Performing a post-occupancy review with the appropriate stakeholders
  • Developing a plan for re-commissioning the building or systems throughout their life cycles

It should be noted that due to project timing, not all building systems can be tested to verify they will operate and function properly during all seasonal weather conditions prior to completing the construction phase. For example, an exit stair pressurization system in a 42-story commercial office building should be tested to verify that it will operate and function as designed during both winter and summer. For this reason, commissioning plans should include seasonal testing provisions to allow for testing of certain equipment under all possible conditions. In these cases, the commissioning team should document these types of issues such that all deferred testing is scheduled and completed. In addition, requirements for deferred and seasonal testing must be clearly defined in the contract documents as it will require contractor personnel to return to the site after the project is completed.



GSA currently has a national commissioning contract in place that consists of three small business consultants and four unlimited size consultants. All the firms have professional expertise in fire protection engineering. GSA has approximately 200 active commissioning projects ongoing throughout the United States.



GSA fire protection engineers have always played a vital role in ensuring that all projects have their fire protection and life safety systems reviewed, designed, constructed, tested, and maintained in accordance with PBS-P100 as well as national codes and standards. In addition, they are also responsible for issuing certificates of occupancy for GSA projects. Prior to issuing a certificate of occupancy, all outstanding significant fire and life safety deficiencies that have been documented during construction or operations must be corrected to afford a reasonable degree of safety to the building occupants from fire risks and similar emergencies.


GSA fire protection engineers will also verify the functional performance and integrated testing of 100 percent of the fire protection and life safety system components, including their interconnections and associated interaction with other building systems (e.g., elevator shunt trip, door hold-open devices, smoke control systems, egress door security locking arrangements, etc.) to ensure they operate in accordance with the design and code requirements. This is because fire protection and life safety systems can sometimes operate equipment that is not a direct component of the fire protection and life safety system. However, other building systems that are commissioned may not require integrated testing - such as building lighting system motion detectors - yet only require functional testing verification of 10-20 percent of the components.



The fire protection and life safety chapter in the next edition of PBS-P100 will likely have a revised section on commissioning fire protection and life safety systems. This new section may include a requirement that the commissioning team must also retain the services for a fire commissioning agent (FCxA).The new section would state that the FCxA also be separate, both by contract and by employment, from the A/E design team, and also acknowledge that the skill sets of the FCxA are different than the skill sets of the CxA; just as the skill sets necessary to perform the commissioning activities for the HVAC systems are different than the commissioning activities associated with the fire protection and life safety systems. In addition, the FCxA would be responsible to perform all the applicable fire protection and life safety commissioning activities.


Lastly, it should be noted that the National Fire Protection Association (NFPA) has embarked on a new project for developing a standard that addresses the commissioning process for fire protection and life safety systems. The NFPA 3, Technical Committee on Commissioning Fire Protection Systems, is responsible for documents pertaining to commissioning activities for fire protection systems. GSA is one of many organizations serving on this technical committee.


David Frable is with the U.S. General Services Administration.



  1. The Building Commissioning Guide, United States General Services Administration, Public Building Service, Washington, DC: 2005.
  2. Facilities Standards for the Public Buildings Service, PBS-P100. United States General Services Administration, Public Building Service, Washington, DC: 2005.

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