TIDC - Tennessee Interior Design Coalition

Talking Points

Legal recognition of interior designers and regulation of the practice establishes enforceable standards of minimum competency and ensures that only qualified individuals design interior spaces and represent themselves as having the qualifications to do so.

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 significant 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.

The lack of review and oversight is largely due to the incremental change of interior space content over the life of a building. This incremental change rate may be driven by changes in ownership or tenancy, changes in occupancy or capacity or other changes driven by wear and tear, design considerations and objectives, as well as the reconfiguration of furniture, fixtures and equipment. In any event, changes of this sort occur with infinitely greater frequency than new building construction or significant renovation projects.

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.’

For example, while a significant renovation of an interior space should probably require a building permit in many jurisdictions – and thus a review of the project’s drawings and specifications – that same project space might not be subject to such a review in some jurisdictions or if the renovation included only an update of finishes such as flooring and wall covering and the installation of new open office systems furniture. Although the finishes must still meet certain requirements as mandated by code – flame spread ratings, smoke toxicity requirements, etc. – to prevent potential injury to the building users, no oversight is provided in the project implementation process. Similarly, the location of furnishings, open office systems in particular, significantly impact means of egress and accessibility within an interior space.

The limited number of licensed design professionals when compared to the variety of ways interior space content is selected and procured would suggest that a very large percentage of interior space content is not covered by any kind of regulatory review or by licensed professional oversight in our current design practice environment.

Every decision an interior designer makes affects the health, safety, and welfare of the public. Those decisions include space planning that provides proper means of egress, specifying furniture, fabrics, materials, and finishes that meet or exceed fire codes and toxicity standards, designing spaces that meet accessibility standards, and consider ergonomics, sustainability, clean air issues, lighting, acoustics, and design solutions for those with special needs.

Interior designers are specially trained in interior materials and their properties, including flammability and toxicity, and are uniquely qualified to select interior finishes that meet or exceed local, state and national fire codes. Without professional standards of practice, an unqualified individual could make decisions that put lives at risk.

In a fire, interior materials play a major part in spreading flames and producing toxic gases. Statistics prove that more people die in fires as a result of inhaling toxic fumes and smoke than from flames themselves.

According to the National Fire Protection Association (NFPA), interior furnishings and content is the second most important issue in the protection of life and property during a fire in public assembly spaces. Even more important than building exiting. In public spaces (not including residences, apartments, industrial and storage facilities), over 700 fires per month involve interior content as the first ignition point of the fire, leading to 23 deaths, and 330 injuries, and over $399 million in direct property damage each year. And yet much of the finishes and interior content can be specified by anyone who wishes to call themselves an interior designer. And much of the design work occurs outside the purview of architects, engineers, and building and codes officials.

Even more significant to life safety is the fact that a large percentage of the loss of life and property occurs well outside the area or room of the initial fire. This is primarily due to the rapid spread of flame and toxic smoke to other areas and floors of the building, fed by poor performing interior finishes and content. In fact, in dormitories, sorority and fraternity houses, religious properties and eating and drinking establishments, 100% of the civilian deaths occurred outside the area of the original fire – they died elsewhere on the same floor, on another floor, or even outside the building of the original fire. In public assembly sites (gymnasiums, arenas, theatres, airports, museums, libraries, courtrooms, etc.), one half of the civilian deaths occurred well outside the area of the fire. And nearly 80% of the direct property damage occurs outside the fire origin area as well.

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 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. Qualified interior designers are trained to design safe, maneuverable spaces that meet the special mental and physical needs of seniors.

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. With knowledge of the Americans with Disabilities Act design requirements qualified interior designers make the interiors of public spaces and residences barrier free and are capable of adapting existing environments to be barrier free for persons who are physically challenged.

Legal recognition of interior designers benefits and protects the public in many ways. It provides standards of practice embodied in an enforceable code of ethics, which incorporates professional fiduciary responsibilities and enables a state or jurisdiction to discipline an interior designer. And it allows consumers a means of addressing grievances with interior designers and prevents unethical designers from continuing to practice.

Interior Design practice legislation will also ensure that Tennessee interior designers can remain competitive with interior designers in neighboring states. The ability of interior designers to work on a project across state lines – an important ability in Tennessee’s global economy – depends on establishing a standard scope of practice and professional qualifications for interior designers. If Tennessee’s interior design registration regulations are less stringent than those of other states, designers may lose registration reciprocity with those states and with it, the ability to work in that state without a significant impact to their competitive standing. It is also true that, without appropriate regulations in the state, unqualified interior designers from other states will be free to practice in Tennessee.

By providing a legal definition of the scope of practice, legislation helps consumers differentiate the responsibilities and services of each of the design professions. It allows consumers to choose the appropriate professional that brings the benefit of open competition to the design process.

Professional interior designers are qualified by education, experience and examination to enhance the function, quality, and safety of interior spaces. By providing a legal definition of the scope of practice, this legislation establishes enforceable standards of minimum competency and ensures that only qualified individuals design interior spaces or represent themselves as having the qualifications to do so. The public benefits from knowing that the individuals they entrust with the design of their interior spaces are qualified.

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