Clint’s Controls Corner: Simplifying “Functional Testing” Compliance


Clint's Controls Corner (text only)

As we know, many jurisdictions in this region have now adopted the 2015 version of the IECC. This code has major ramifications to what is required for lighting controls in all commercial construction. The highlights have been discussed in previous Controls Corner articles.

However, there is one requirement that continues to be very difficult for all stakeholders in the construction process. This is the requirement of “Functional Testing” included under section C408 “System Commissioning” in the 2015 IECC. In this section, C408.3 specifically covers lighting controls and the requirements to comply with the code.

As an overview, this section of the Code creates the requirement that the “Registered Design Professional” provide evidence that the lighting control system is operating as intended by the construction documents and manufacturer’s instructions. Specific documentation requirements are included in this section for occupancy sensors, time-switch controls, and daylight responsive controls.

This requirement is very different from the approach of nearly every other building code to date. This requirement is one of the few, if not the only code requirement, that requires the Registered Design Professional to be responsible for, and to certify that a system operates as intended per the construction documents. Building codes typically limit the responsibility of the design professional to system design intent, but this code requirement extends that responsibility to post construction operational functionality. 

This is a shift in thinking for the construction industry in general, and is being met with a great deal of confusion from engineers, contractors and building officials alike. How this requirement is being enforced varies significantly between different jurisdictions. Some jurisdictions that have adopted IECC 2015 are not requesting the documentation at all, and others (Denver being one) will not provide a Certificate of Occupancy until the documentation is received. Some jurisdictions are also allowing commissioning agents that meet specific criteria to provide this documentation – this is called out as acceptable under the mechanical and plumbing functional testing section, but not specifically in the lighting control functional testing section in the code. The policies for how most jurisdictions are handling this requirement are still evolving, which creates a moving target for engineers and contractors trying to complete projects.

In order to avoid surprises on a particular project, it is important to know what the jurisdiction will require at the beginning of the process.  The Registered Design Professional has the responsibility of providing this documentation. Contractors need to stay in front of the requirements as they will feel the pressure if building occupants can’t move in because this requirement has not been met.

To aide in the process, MH Controls provides documentation of system parameters that will be required to meet the Functional Testing requirements for projects in IECC 2015 jurisdictions. This documentation is provided to the contractor, and is intended to be sent to the Registered Design Professional to provide a starting point in meeting this requirement. However, MH Controls is neither the Registered Design Professional or a commissioning agent. In order to avoid a conflict of interest, the documentation needs to be physically validated by the Registered Design Professional who will then submit documentation to the authority having jurisdiction.

This is a challenging issue for current projects. Please don’t hesitate to contact me or any member of the MH Controls team for assistance in how to meet the requirements.

This article was written by Clint Conley, our Lighting Controls Department Manager. Clint can be reached at 720.904.8554 or