Permitting and Review

The California State University is required to construct and maintain its facilities in compliance with a broad range of codes and regulations. Determining permit need and permit issuance is coordinated at the campus level by the appointed Campus Deputy Building Official (CDBO) (.xls) under the direction of the CSU Systemwide Building Official. Office of the Chancellor, Capital Planning, Design and Construction (CPDC) acts as a systemwide resource regarding code compliance and policy requirements.

CSU Authority

Education Code 66606 grants the CSU full power and responsibility in the construction and development of its capital program. Education Code Section 89031​ grants the CSU the ability to establish rules and regulations for the governing and maintenance of the buildings and grounds of the California State University.  

Health & Safety Code 18934.5​ requires the CSU to follow the provisions of the California Building Standards Code, California Code of Regulations (CCR) Title 24 as adopted by Building Standards Commission (BSC) and identified in the matrix adoption tables.  Adoptions of provisions of the code by other agencies increase the overall enforcement responsibilities of the CSU.  

In addition to the BSC-adopted code sections, the CSU has procedurally adopted Chapter 1, Division II of the current edition of the CCR Title 24, Part 2, of the California Building Standards Code (CBSC), also known as the California Building Code (CBC).

Within the Office of the Chancellor, the Office of Fire Safety (OFS) is authorized to enforce all fire and panic safety provisions in the California Code of Regulations (CCR), as adopted by the Office of the State Fire Marshal (OSFM).   Health and Safety Code sections 13108 and 13146 invest the OSFM with the responsibility for enforcement of fire and panic safety provisions extending to the following areas: 

  1. ​Plan review and approval, permitting and subsequent construction inspections of all new construction, remodel, renovation, and tenant improvement projects on/in state-owned, -leased, or -operated properties. (CCR Title 24)
  2. Inspection of existing state-owned, -leased or -operated properties for compliance with all applicable fire and panic safety regulations. (CCR Title 19)​
  3. Investigation of origin and cause of fires/explosions in state-owned, -leased, or -operated facilities (CCR Title 19)​

The Memorandum of Understanding (MOU) between the CSU and the OSFM will incrementally grant OFS personnel responsibility to exercise enforcement for items #1 and #2 above on behalf of the OSFM and in accordance with CSU policies.  OFS personnel are not intended to be authorized to perform fire origin and cause activities on CSU properties. ​(MOUMOU Attachment A​)

CSU Systemwide Buil​​ding Official

​​Section of the CBC empo​​wers the CSU to appoint a building official who is responsible for enforcement of the provisions of the code.  

According to the State University Administrative Manual, code enforcement shall be under the direct administrative and operational control of a building official.  

Jack E Andersen​ is the Systemwide Chief Building Official for the CSU with responsibility of enforcement of the California Code of Regulations, Title 24 on CSU owned or occupied properties.

Campus Deputy Building Official (CDBO)

Per campus delegation, each campus shall appoint a Campus Deputy Building Official (CDBO) who is responsible for campus-specific administrative and operational control, including coordination of permit issuance. The CDBO shall report to a campus-designated office as well as to the CSU Systemwide Building Official as it relates to the compliance with code.  Each CBDO is considered a deputy to the CSU Systemwide Building Official per provisions of CBC section 103.3.  

The designated CDBO shall issue a written construction/demolition authorization for each project and maintain a record of all authorizations. The written authorization shall be issued only after confirmation of all required approvals, including those required by Office of State Fire Marshal and Division of the State Architect have been obtained.

​CSU Director of Fire Safety

Morgana Yahnke is the Director of Fire Safety for the CSU with responsibility for oversight of enforcement of fire and panic safety provisions of the California Code of Regulations as adopted by the OSFM. CPDC Org Chart


Shared Authority with Other Authorized Agencies

The CSU is required to coordinate its building official authority with various other state and federal agencies in certain aspects, most notably with Office of the State Fire Marshal​ on fire and panic safety issues, including exiting, and with the Division of the State Architect on access compliance issues. 

Other authorized agencies have specific approval authority that may apply depending upon the characteristics of an individual CSU project. Notable examples include local county health department approval for pools and food service operations and the Division of Occupational Safety and Health (Cal/OSHA) Elevator Unit for elevator approvals.

Enforcement of provisions of the code as adopted by other authorized agencies is the co-responsibility of the other agency; however, CSU has procedurally empowered the CSU Systemwide Building Official and the CDBO to enforce the other agencies code provisions.  Such procedural action shall not alleviate a project from compliance with submission, permitting, or inspection processes of the other authorized agencies.  

With the exception of the provisions of the code as adopted by the Building Standards Commission (BSC), Building Standards Comission-CALGreen (BSC-CG), and Division of State Architect-Access Compliance (DSA-AC) through exceptions granted to administrative authorities; CSU has not been given sole authority to accept alternate materials, design and methods of construction and equipment on behalf of a separate authorized agency or reduce the requirements of the code as adopted by the separate authorized agency.    

CSU projects shall enforce the provisions of the code as adopted by BSC, BSC-CG, OSFM, DSA-AC when provisions are applicable to a project.  

Intent of the California Building Standards Code

Building code establishes the minimum requirements to safeguard the public health, safety and general welfare through:

  • Structural strength
  • Means of egress facilities
  • Access to persons with disabilities
  • Sanitation
  • Adequate lighting and ventilation and energy conservation
  • Safety to life and property from fire and other hazards attributed to the built environment
  • Providing safety to emergency responders during emergency operations

Work Requiring Permit Approval

All CSU demolition, construction, and renovation work requires formal, written building official and/or CDBO approval and permit prior to:

  • Construction, enlargement, alteration, repair, move, demolition, or change of the occupancy of a building or structure,
  • Erection, installation, enlargement, alteration, repair, removal, conversion, or replacement of any electrical, gas, mechanical or plumbing system, the installation of which is regulated by the code/erection, construction, reconstruction, installation, alteration, or moving of any building or structure,
  • or to cause any such work to be performed

Changes, alteration and repairs of a minor nature not affecting structural features, egress, sanitation, fire safety, or accessibility do not require a permit as assessed by the CSU Systemwide Building Official and/or CDBO on a case-by-case basis. Larger repair and maintenance operations may be given blanket approvals on an annual cycle. You can coordinate both through the CDBO.

Other work exempt from the permitting process is described in Scope and Administration sections of California Code of Regulations Title 24, refer to Section 105 of the 2019 CBC.  It is at the discr​etion of the CSU Systemwide Building Official and/or CDBO to require a CSU permit with cause for work that is exempt from permit if the work is considered at risk of violation of the provisions of the code or calls for special considerations. 

Components of the Project Review 

1.  Plan Review

Building code review applies to all CSU construction and renovation work as well as maintenance operations

Building code approval for all CSU projects may be performed directly by the Campus Deputy Building Official or, on their behalf, by any of the authorized plan check firms under systemwide agreements. The plan check firms provide only an opinion and recommendation as to code compliance or not. The CDBO is responsible to make the official determination for code approval.

Refer to Master Enabling Agreements to find authorized plan check firms.

2.   Review of Access Compliance

All CSU construction requires review of access compliance unless the construction meets the General Exceptions section of Chapter 11B of the California Building Standards Code. 

All CSU construction intended for use by the public with any reasonable availability to or use by persons with disabilities, constructed in whole or in part by the use of state funds, requires access compliance review and certification by California Department of General Services, Division of the State Architect (DSA), per requirements of California Government Code Sections 4451, 4453 and 4454. 

CSU Executive Order 1111 does, however, allow for self-review of projects by the Campus Deputy Building Official if the project is below the major capital threshold.

Additionally, the CSU Systemwide Building Official may authorize an Approval to Proceed to Bid/Construct in advance of a completed DSA review if:

  1. A detailed request is made by the Campus Deputy Building Official
  2. DSA submittal was in a timely manner
  3. An appropriate schedule buffer was included in the project schedule
  4. A CSU Access Compliance review was performed and
  5. The plans to be bid contain all the corrections from the CSU access review ​

Such approvals are given on the condition that the Campus Deputy Building Official confirm that the completeness of the work is consistent with the documents that the DSA eventually approves, including without limit whatever rework is necessary.

Other Projects Exempt from Division of the State Architect Review:

  • Non-Public Areas: Projects that have no reasonable availability to or usage by persons with disabilities are exempt. Such projects might include mechanical systems installations and upgrades, rooftop solar arrays in non-public areas, utility tunnels, etc.
  • Infrastructure Project: Civil infrastructure construction activities that do not impact the path of travel (existing) or accessible routes (new projects) may be excluded from DSA review.  However, replacement of street sections, curbs, walkways, etc.; building infrastructure projects that revise publicly accessible switches and controls; and fire alarm upgrades that include signaling devices, all require an access review.
  • Maintenance Work: Normal maintenance, re-roofing, painting or wallpapering, asbestos removal or changes to mechanical and electrical systems, unless they affect the accessibility of the facility, are exempt. Work that includes placement of switches, controls and outlets require a need for access review.  Special attention should be paid to carpet replacements as it relates to accessibility and access complinace.​   

The Campus Deputy Building Official is the front-line campus resource to evaluate accessibly compliance approaches. 

Refer to the Systemwide Plan Check Review & Preliminary Code Assessment Review Master Enabling Agreements for plan check review including, accessibility compliance review of projects.  

For more information, refer to the DSA Plan Check Submittal Processes.  

3.  Review of Fire and Panic Safety

Plan Review for fire and panic safety compliance is currently required for all CSU major capital and limited minor capital construction and renovation work.

The OFS is currently authorized to enforce fire and panic safety regulations, as adopted by the OSFM, on all CSU projects/properties. Plans for all major capital projects must be submitted to OFS for review and approval prior to being submitted to the OSFM. Most minor capital projects will be submitted directly to OSFM for review and approval. Detailed information on the document requirements and submittal procedure can be found in the following OFS policies and procedures: OFS policy FSPL21-C001 Required OFS Design Review and Concurrence Points, OFS Procedure FSPR21-C001 Plan Review Submittal Procedure​ and the OFS Construction Documents Submittal Checklist​.

​Per the authority granted by California Health and Safety Code, Section 13146​, the OSFM is currently required to review/approve fire and panic safety provisions for all CSU construction and renovation projects. Projects that are not on CSU property but will be occupied and used for state function, including classrooms or CSU employee office spaces, are also subject to the CSU permitting process inclusive of the fire and panic safety review. 

The OSFM approval includes a plan review/approval, followed by OSFM field construction inspections, concluding with issuance of a OSFM Certificate of Occupancy.

There are some construction activities that may be started prior to the OSFM approval of construction documents. The guidelines for this process can be found in the CPDC Bulletin 20-005: Project Types for SFM Delegation Work in Advance of Final SFM Approval.

​4.  ​ Seismic Peer Review

A seismic assessment is required for all projects as per Board of Trustees' policy.

For Major Capital Projects, a seismic peer review is required by the specific CSU Seismic Review Board Member or his/her designee assigned to each campus.

Minor Capital Projects may be submitted for peer review or may be reviewed and approved administratively by the campus at the discretion of the Campus Deputy Building Official. This is discussed more fully in Section 3.7 of the CSU Seismic Policy, Peer Review for Small Projects.  Note that CSU Seismic Requirements do not wave the need the project  assessment requirements.

 Seismic Peer Reviewers are assigned to specific campuses of the CSU. Listing of the assignments can be found in the Campus Peer Reviewer Assignments​.

5.   Mechanical Systems Review (MSR) Plan

A Mechanical Systems Review (MSR) is required for all major capital projects, both state and non-state funded within the CSU system.

Campuses may select any Mechanical Review Board (MRB) member to perform the project MSR. While the MSR is provided as an advisory to the campus, MSR letters of concurrence are required during the schematic and the construction document phases of the design. 

To gain full benefit of this review, campuses are encouraged to consider the campus-selected MRB reviewer as an extension of their staff.

Refer to Master Enabling Agreements to find authorized MSR firms.​