IR A-6 (rev 11/27/18) Page 1 of 11
DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
IR A-6
CONSTRUCTION CHANGE DOCUMENT SUBMITTAL AND
APPROVAL PROCESS
Disciplines: All
History:
Revised 11/27/18
Revised 11/21/12
Revised 11/15/06
Revised 12/16/16
Revised in its entirety 11/01/12
Issued 09/01/99
Revised 07/08/14
Revised 11/16/09
Revised 02/14/14
Revised 09/18/07
Division of the State Architect (DSA) documents referenced within this publication are available
on the DSA Forms or DSA Publications
webpages.
PURPOSE: This Interpretation of Regulation (IR) provides clarification of specific Code
requirements relating to
construction changes that must be submitted to DSA and defines the
construction change document process.
DEFINITIONS: The following definitions apply to terms used in this document:
Approved Construction Documents – The Structural, Access or Fire & Life Safety related
portions of the plans, specifications, addenda, deferred approvals, revisions, and construction
change documents duly approved by DSA.
Change – Revisions, deletions, additions, and substitutions to approved construction
documents.
Change Order – A document defining construction changes that result in changes to the
contract.
Clarification – A statement from the architect or engineer in general responsible charge of the
project that clarifies (but does not change) the requirements of the approved construction
documents.
Contract – A written agreement for construction, alteration, repair or other construction
activities associated with facilities regulated by DSA.
Construction Change – Changes to the approved construction documents after a contract for
the work has been awarded.
Construction Change Document (CCD) – The documentation of construction changes.
Design Professional in General Responsible Charge – The architect or engineer in general
responsible charge of the project as listed on Line 23 of form DSA 1: Application for Approval of
Plans and Specifications.
Drawing – An illustration on paper or electronic medium.
Field Change Document (FCD) – A document defining construction changes but, unlike
change orders, does not require approval of the school board nor an accounting of construction
cost changes.
Interpretation – A statement from the architect or engineer in general responsible charge of the
project that interprets (but does not change) the requirements of the approved construction
documents.
Responsible Design Professional – The architect or engineer in general responsible charge
of the project, as listed on Line 23 of form DSA 1, or architects or engineers with delegated
responsibility for portions of the project as listed on Line 24a-24d or 25 of form DSA 1.
DSA IR A-6
CONSTRUCTION CHANGE DOCUMENT SUBMITTAL AND APPROVAL PROCESS
IR A-6 (rev 11/27/18) Page 2 of 11
DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
1. SUBMITTAL REQUIREMENTS FOR CONSTRUCTION CHANGES: After a contract for
the work has been let, changes to the approved construction documents shall be made by
means of a CCD.
It is the responsibility of the design professional in general responsible charge to determine if
changes affect the Structural, Access or Fire & Life Safety portions of the project. (See Section 4
below about the statement on the verified report.)
The design professional in general responsible charge shall prepare the CCD and is responsible
for code and process compliance.
The following define requirements for submittal of a CCD to DSA.
1.1 Changes to or affecting the Structural, Access Compliance or Fire & Life Safety
portions of the project:
• These changes shall be classified as CCD Category A.
• A CCD Category A is required to be submitted to and approved by DSA prior to
commencement of the affected work.
• A CCD Category A must be submitted to DSA using form DSA 140: Application for
Approval of Construction Change Document - CCD Category A/B depicted in
Appendix A of this IR and available on the DSA forms page. Submittal process
requirements are defined in Section 2 of this IR and must be followed.
1.2 Changes NOT affecting the Structural Safety, Access Compliance or Fire & Life
Safety portions of the project:
• These changes shall be classified as CCD Category B.
• CCD Category B are not required to be submitted to DSA unless specifically required,
in writing, by DSA. However, a design professional, at their discretion, may choose to
submit a CCD Category B. (Refer to Section 3 for fees charged.)
• If DSA requires any CCD Category B to be submitted, then they shall be submitted to
DSA, similar to CCD A, using form DSA 140.
• If DSA requires a CCD Category B to be submitted, then DSA will review for
concurrence that it does not contain changes to or affect the Structural, Access or
Fire & Life Safety portions of the project. If necessary, and at its sole discretion, DSA
will reassign the CCD to Category A.
• If DSA concurs the document is a category B document, an approval stamp will be
applied to the document.
1.3 Change Orders: Change Orders are not required to be submitted to DSA. The CCD
process replaces the need to submit Change Orders (except as noted in Section 7).
Changes to the construction cost are reported to DSA using form DSA 168: Statement of
Final Actual Project Cost at the conclusion of the project.
2. SUBMITTAL PROCESS: Submittal of CCDs must conform to the following requirements:
2.1 Must be submitted by the design professional in general responsible charge.
2.2 Must be submitted to DSA using form DSA 140.
2.3 Each CCD submittal must use a separate DSA CCD form.
2.4 The DSA CCD form must be filled out completely, including identification of the CCD
DSA IR A-6
CONSTRUCTION CHANGE DOCUMENT SUBMITTAL AND APPROVAL PROCESS
IR A-6 (rev 11/27/18) Page 3 of 11
DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
Category A or B, leaving no fields blank. For Category B CCDs, indicate whether the
submission is voluntary or DSA required. When DSA provides written direction
compelling submission of a CCD Category B, attach a copy of the DSA written notification
compelling submission.
2.5 Each CCD must be uniquely numbered. The numbering may be numeric or alpha-
numeric.
• If the submitted CCD is returned by DSA not approved, the CCD number used in the
original submittal must remain the same for any subsequent re-submittals.
• If a submitted CCD Category B is returned by DSA not approved, the CCD number
used in the original submittal must remain the same when re-submitting as a CCD
Category A.
2.6 Proposed changes must be described clearly and completely.
2.8 All drawings, and, when applicable, the first page or index of specifications and
calculations associated with the proposed change must be stamped, signed, and indicate
date of signing by the responsible design professional as an attachment to form DSA
140.
2.9 Reference to the specific portions of the drawings or specifications that are being
changed must be included.
2.10 Changes to any testing or inspection requirements associated with the proposed change
must be clearly described with a revised form DSA 103: List of Structural Tests and
Special Inspections.
2.11 Each page in the CCD, including the pages in each attachment, shall be clearly and
uniquely numbered. All drawings attached to describe the changes shall be clearly
numbered, labeled, and referenced.
2.12 When drawings containing DSA approval stamps are revised and reissued as part of the
CCD, all of the following requirements must be met:
• Images of all DSA approval stamps must be removed from the drawing (or crossed
out) prior to making any changes to the drawings.
• Each change shall be clouded and identified on the drawing.
• All drawings must be re-stamped and re-signed by the responsible design
professional. The date of signing shall be provided.
2.13 CCD Submittal to DSA
2.13.A Projects submitted to DSA prior to October 1, 2018: DSA Box or Bluebeam studio
may be utilized for CCD submittals as directed by the DSA Regional Office. If DSAbox
is
utilized for CCD submittals, each CCD shall be submitted as a single document and
include form DSA 140 as the first page. In some cases, large size drawings associated
with CCDs may need to be submitted as a hard copy to the appropriate DSA regional
office. The design professional should contact the DSA regional office to determine file
size limitations and submittal guidelines, and review DSAbox instructions in the
DSAbox
External Library, Module 2.13. If Bluebeam studio is utilized for CCD submittals, see DSA
PR18-04: Electronic Plan Review for Design Professionals of Record for submittal
procedures.
2.13.B Projects submitted to DSA on or after October 1, 2018: Bluebeam Studio will be
utilized for CCD submittals. See DSA PR18-04 for submittal proceedures
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CONSTRUCTION CHANGE DOCUMENT SUBMITTAL AND APPROVAL PROCESS
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
3. REVIEW AND APPROVAL/CONCURRENCE BY DSA:
• DSA will charge fees in accordance with IR A-30 for all Category A CCDs submitted
to DSA for approval. Category B CCDs voluntarily submitted by the design
professional to DSA will be charged fees for review and concurrence. Category B
CCDs required by a DSA representative to be submitted will not cause charged fees if
DSA concurs the CCD is Category B.
3.1 CCD Category A:
• DSA reviews CCD Category A for minimum compliance with the codes regulating the
Structural, Access and Fire & Life Safety portions of the project.
• If not approved by DSA, then the CCD is returned to the design professional in
general responsible charge for corrections. DSA will return the document for
corrections with a form DSA 140 attached indicating the status of the review and
update eTracker accordingly. After corrections are made then the CCD is re-
submitted (must include the DSA comments and a copy of the form DSA 140 from the
previous unapproved submittal) following the submittal process outlined in Section 2
of this IR
• If approved by DSA, then DSA places the approved CCD in DSAbox as described in
DSAbox External Library, Module 2.13 (see Section 4 for requirements for distribution
by the design professional in general responsible charge).
3.2 CCD Category B:
• DSA reviews CCD Category B to provide concurrence that the changes do not affect
the Structural, Access or Fire & Life Safety portions of the project.
• DSA approval of CCD Category B is not approval for code compliance, but is
concurrence that the documents do not change the Structural, Access and/or Fire &
Life Safety portions of the project.
• If not approved by DSA, then the CCD is returned to the design professional in
general responsible charge for corrections. After corrections are made, then the CCD
is re-submitted using CCD Category A form DSA 140 (must include the DSA
comments and a copy of the form DSA 140 from the previous unapproved submittal)
following the submittal process outlined in Section 2 of this IR. The remaining review
process will follow that for CCD Category A described in Section 3.1 of this IR.
• If approved by DSA, then DSA places the approved CCD in DSAbox as described in
DSAbox External Library, Module 2.13 (see Section 4 for requirements for distribution
by the design professional in general responsible charge).
4. DUTIES OF DESIGN PROFESSIONAL IN GENERAL RESPONSIBLE CHARGE
4.1 Distribution of CCD Category A Documents: The design professional in general
responsible charge shall provide the contractor and project inspector with DSA approved
CCD Category A prior to commencement of work shown thereon.
4.2 CCD Category A Statement in Final Verified Report: The final verified report (form
DSA 6-AE) from the design professional in general responsible charge must include a
statement that all changes to or affecting the Structural Safety, Access Compliance or
Fire & Life Safety portions of the project have been approved by DSA. The intent for all
projects is that this final verified report be dated after the approval of those CCDs.
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
5. DUTIES OF THE PROJECT INSPECTOR WITH RESPECT TO CCDs: The project
inspector shall follow the CCD Category A record-keeping and monitoring requirements, issuing
deviation notices when appropriate, as specified in IR A-8: Project Inspector and Assistant
Inspector Duties and Performance.
6. MONITORING OF CHANGES BY DSA: If DSA determines that changes to the plans or
specifications appear to require DSA approval (changes affecting the Structural Safety, Access
Compliance or Fire & Life Safety portions of the project), DSA shall notify the design professional
in responsible charge and require the changes to be submitted for review and approval by DSA
or require evidence the changes are CCD Category B.
7. TRANSITION: The following provides direction for submittal of construction change
documents (Change Orders, (Field Change Document) FCDs or CCDs) for projects in various
stages of completion of construction. All projects for which construction commences on or after
January 2, 2013 are required to use the CCD process described in this IR.
7.1 Projects for which, prior to November 1, 2012, construction is essentially complete,
having been issued a DSA 90-day letter or “closed uncertified” by DSA: Projects in
this category may have an issue of “unresolved change orders” or “unresolved FCDs.”
The status of these could be:
• Change orders or FCDs have been submitted to DSA and are pending review or
unapproved.
• Change orders or FCDs have not been submitted to DSA.
To resolve this issue, use the following options:
Change Orders:
Option #1: Submit/resubmit the change orders and obtain DSA approval. The cost
information in the change order need not be included.
Option #2: If any or all of the “unresolved change orders” are changes that do not
affect the Structural Safety, Access Compliance, or Fire & Life Safety components or
portions of the project, then, in lieu of the change orders, form DSA 310: Alternate
Certification Statement of Content for Change Orders, Addenda and Revisions may
be submitted. The specific change orders must be listed, by number, on the form.
FCDs:
Option #1: If the FCD has been previously submitted to DSA, then resubmit the FCD
and obtain DSA approval.
Option #2: For changes that affect the Structural Safety, Access Compliance, or Fire
& Life Safety portions of the project, but have not resulted in a change order, and
have not been previously submitted as an FCD, then submit as a CCD Type A.
7.2 Projects for which construction commenced prior to January 2, 2013 and do not
fall into the category defined in Section 7.1:
• For change orders or FCDs that have been submitted to DSA, see options listed
in section 7.1.
• From November 1, 2012 to January 1, 2013: If previously unsubmitted change
orders or FCDs are submitted, DSA staff will assign them as CCD Category A,
assign the change order/FCD number as the CCD number, and process them
accordingly.
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
• On or after January 2, 2013: the CCD process must be followed for all new,
previously unsubmitted construction changes. If previously unsubmitted change
orders or FCDs are submitted, DSA staff will return them as rejected, not
approved and require them to be resubmitted as CCD.
REFERENCES:
California Code of Regulations (CCR) Title 24
Part1: California Administrative Code, Sections 4-215, 4-233, 4-338 and 4-341
California Health and Safety Code, Sections 16011, 16013 and 16015
California Education Code, Sections 17280 and 81130
This IR is intended for use by DSA staff and by design professionals to promote statewide consistency for review and
approval of plans and specifications as well as construction oversight of projects within the jurisdiction of DSA, which
includes State of California public schools (K‒12), community colleges and state-owned or state-leased essential
services buildings. This IR indicates an acceptable method for achieving compliance with applicable codes and
regulations, although other methods proposed by design professionals may be considered by DSA.
This IR is subject to revision at any time. Please check DSA’s website for currently effective IRs. Only IRs listed on the
webpage at www.dgs.ca.gov/dsa/publications
at the time of project application submittal to DSA are considered
applicable.
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
Appendix A - Sample CCD Category A
DSA IR A-6
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
Appendix A - Sample CCD Category A (continued)
DSA IR A-6
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
Appendix A - Sample CCD Category A (continued)
DSA IR A-6
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
Appendix B - Sample CCD Category B
DSA IR A-6
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
Appendix B - Sample CCD Category B (continued)
