Opposition / Position  (Architects & Engineers)

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Legislation will clarify the differences in the services provided by a qualified interior designer versus those of an architect as well as a non-qualified designer. Furthermore, legislation will set guidelines for interaction between all licensed professionals i.e., architects, engineers, interior designers, etc. No one, including architects, may call themselves an interior designer unless they become registered as such in Tennessee.

The scope of services that will fall under the charge of the interior designer will be limited to work within the building shell while adhering to all code and regulatory requirements. The work of an interior designer is limited to non-structural interior elements or components that are not load-bearing and do not require design computations for a building’s structural frame including those related to seismic forces. Common non-structural elements or components include, but are not limited to, ceiling and partition systems. These elements employ normal and typical bracing conventions and are not part of the structural integrity of the building. When an interior designer uses the term “partition”, it means a wall which does not support a vertical load of a building’s structural frame other than its own weight, but may support loads attached to it such as cabinetry, shelving or grab bars, and does not extend further from the floor of an interior area than to the underside of the structural deck above.

Interior design also includes the design and specification of products that are independent of the building structure, i.e. window treatments, furnishings, artwork, flooring, wall coverings, cabinetry and other built-ins, etc. Interior design focuses on meeting the functional needs of the user while incorporating current regulatory standards for accessibility issues, sustainability and life cycle maintenance and cost.

It is not feasible for all design professionals to be experts in all fields, therefore each member of the design tem must have broad-based interdisciplinary knowledge of the work of other professionals. This is true with regard to structural and other building systems. This is true with regard to environmental hazards. Interior designers regularly use intelligent observation, investigative techniques and problem identification in the initial stages of a project and use these skills to play an important role in assembling a team of the appropriate design professionals for the client.

CIDA accreditation standards require that students MUST demonstrate understanding that design solutions affect and are impacted by construction systems and methods, power distribution systems, mechanical systems, energy management, data/telecommunications systems, lighting, ceiling, flooring systems, security systems, acoustics,  and interface of furniture and products with building systems. Similarly, students must demonstrate understanding of the impact of fire and life safety principals on space planning including compartmentalization , movement, detection, and suppression.

The NCIDQ examination, based on current research and associated psychometric data, currently has 9 questions of the 225 written questions which test knowledge and skill in gathering information about site to determine existing conditions, code compliance space use, context and constraints. A total of 82 questions, 36% of the examination, tests knowledge of building systems, codes and regulations, standards and other life safety considerations, review of solutions to ensure compliance with codes and regulations, evaluation of consultant reports, technical information, etc., and verifying their compliance with code and building system requirements, as well as coordination with consultants and review of consultant documents for integration of all systems into the projects. Many of these issues are also tested on the practicum portion of the examination.

In the absence of regulation, the public believes that either 1) regulation is not required because there is little or no risk of harm in the buildings in which we live work and play or 2) that the risk of harm has been mitigated through the licensure of others – mainly architects and engineers – and through the regulatory review for code compliance by building codes and fire officials.

New building construction, as well as building renovation projects, generally involves licensed architects, engineers, and other design professionals including interior designers. The drawings are reviewed by building departments and fire marshals’ offices and the projects are visited periodically during construction to check regulatory compliance. However, the public is largely unaware of the magnitude and frequency of change in interior space content without appropriate review of building and life safety code compliance or the involvement of licensed design professionals. Interior space content – finishes, furniture, fixtures and equipment – is often selected, specified and installed not as a part of or out of sequence with the building construction or renovation review and permitting process but as part of normal space activity such as change in occupancy or growth, expansion or contraction, normal wear and tear, and simple space reconfiguration.

Flame spread, smoke generation and toxicity, accessibility, and egress obstruction, material off-gassing, moisture migration and mold growth, serviceable application of materials, project completion and occupancy delays, unanticipated project ‘extras’ which impact the budget and schedule, sustainable design, etc. are sources or risks of harm which, to an alarming degree, fall through the ‘regulatory review cracks.’

A significant amount of design work occurs legally every day in Tennessee that does not require the review of an architect or building or life safety officials. It is not necessary to obtain a building permit to update many interior finishes, furnishings, and other content – even though those interior finishes and content have a tremendous affect on the protection of life and property in a fire. 

	In the United States there are over 700 fires per month in public buildings in the U.S. where interior finish materials and content were the first items ignited?
	Those 700 fires each month cause 23 civilian deaths, 330 civilian injuries and over $399 million in direct property damage each year.
	The NFPA states that furnishings and content is a critical element in “lessening a life threatening condition.” In assembly occupancies, interior content and furnishings are more important than on-site fire protection such as alarms, sprinklers and fire extinguishers.  More important than exiting, including number and arrangement of exits, occupant load, exit signage, and emergency lighting.

Every decision an interior designer makes in one way or another affects the health, safety, and welfare of the public. It is true that the public needs to understand the need for qualified interior designers but only because it is in the interest of their personal safety and welfare. It goes well beyond a debate between interior designers and interior decorators.

	Fire Safety. In a fire, interior materials play a major part in spreading flames and producing toxic gasses. Statistics prove that more people die in fires as a result of inhaling toxic fumes and smoke than from flames themselves.
	More people die in fires as a result of inhaling toxic fumes and smoke than from flames.   NFPA records over 700 fires each month in public spaces where interior finishes and content were ignited in a fire first. Those fires kill 23 civilians and injures 330 people each year. The cost of these fires is approaching $400 million annually.   NFPA also indicates that interior finishes are critical in the ability for individuals to get out of a burning building safely. In assembly occupancies, the NFPA lists interior finishes and content as the #2 contributor to the safeguarding of life in a fire, ranking it higher than building on-site fire protection (sprinklers, alarms, extinguishers) and building exiting (number/ arrangement of exits, occupant load, exit signage, emergency lighting)."
	Accessibility. With 79 million people over the age of 35, and the number growing daily, there is an increasing need for universal design, i.e. designing interiors and products to be useable by people of all ages and all physical abilities.
	Special Needs of the Elderly. According to the National Safety Council, the leading cause of death in the home is falling. Falls took the lives of 10,700 people in 1998. More than 86% of these people were 65 years old or older. Understanding environmental needs for the aging (both physical and mental) has become a special design imperative for this country. In 2000, people 65 years of age or older represented almost 13% of the population. This number is expected to grow to be 20% of the population by 2030.
	Indoor Air Quality. Typically we spend 90% of our time indoors. Indoor air quality on average is nine times worse than outdoor air quality. Qualified interior designers understand  this when specifying materials, furniture, fabrics and other products that are compliant with air quality standards.
	Ergonomics. Interior designers create ergonomic spaces that relieve body stresses, provide healthy lighting options, and decrease physical discomfort by specifying products that work well with the human body.

The proposed legislation does not seek to take work from interior decorators and others in the decorative services business. In fact, the proposed law clearly defines decorative and other work that may continue as it always has. The proposed bill does not seek to regulate retailers, kitchen and bath designers or other related trades; it seeks solely to protect consumers in large, complicated spaces where life safety issues are critical. In fact, in states where the practice of interior design is regulated similarly to the proposed law in Tennessee, the cost of design services, especially the cost of architectural services, dropped significantly. Where true competition exists, consumers win.

It is important to remember that our training and expertise limits us to the practice of interior design. Just as we are required to collaborate with structural, mechanical and electrical engineers, or specialized technical consultants for particular projects, so are we required to collaborate with architects in the design and detailing of required life safety systems of the total building. These building systems, which include fire-rated separations between interior spaces, fire-rated vertical shafts, fire-rated protection of structural elements, smoke evacuation and compartmentalization, and the preparation of the summary life safety plan, are interdependent systems which affect the performance of the entire structure during a life-safety emergency, not only an interior space.

In addition, many of these assemblies and fire-stopping details require specialized knowledge which is not currently a common component of the interior design career path of education, experience, or examination. This bill seeks to establish a basis for interaction and collaboration with relevant related professions and by differentiating the responsibilities and services of each of the design professions, safeguarding the health and safety of the public.

The educational requirements of the proposed bill, along with the requirements for a diversified and appropriate experience, are consistent with solid, defensible, and regularly updated research about the profession and are in keeping with national and state standards and professional accreditation processes. The accreditation process and the experience program requirements and documentation are comparable to those required for architects, engineers, and other licensed professions in Tennessee.

The continuing education requirements for the proposed bill are precisely the same as those required for architects and engineers licensed in Tennessee.

The NCIDQ examination is the only national interior design exam developed and administered in the United States by an agency that is independent from other interior design organizations and is the only examination that tests for the full body of interior design knowledge and effectively tests competency in all areas of interior design practice. The makeup of the examination is carefully based on psychometric data about the profession. 100% of the examination is directed at public health, safety and welfare.

There is no carte blanche grand-parenting provision in this bill. All interior designers who wish to register under this act must meet the full requirements of the law. For those interior designers who were grand-parented under the original 1991 title act, they have already proven their fitness to practice interior design under the new law and, by the time the new bill goes into effect in July of 2008, will have a minimum of 19 years of professional experience. From 1994 until present, everyone registering under the 1991 title law has had to meet or exceed the high educational, experience, and examination requirements called for in the new bill.

Under the proposed law, architects will be permitted to practice interior design and to refer to those services as interior design services. However, they may not refer to themselves as “interior designers” unless they meet the qualifications and have registered under the new law.  In all likelihood, a registered architect in Tennessee with an accredited architectural degree and appropriate work experience will qualify to take the NCIDQ examination using the non-accredited path, so registration, if desired, is easily achievable.

Click here to download a printable PDF of these positions.