Anyone Using Div 28 For Surveillance Projects? What Is The Problem?

Trying to find where major security systems like video surveillance are buried in new construction bid packages is a difficult task.

Several years ago, the widely adopted CSI MasterFormat structure created "Division 28" expressly for the purpose of gathering up electronic security systems to make it easier for subcontractors to bid, and systems to be updated when base plans changed.

The problem? Hardly anyone in the A&E/Specwriter ranks knows about it, much less uses it.

Now SIA has issued a call to the industry to help change things. In a blast email they have asked for 'volunteers' to help update Div28:

I am curious: do you see security systems routinely listed under Division 28? If not, where?


In 2004, CSI introduced the new 50 division masterspec system to replace the previous 16 division system that had been in use for decades before. We have been using the 28 xx xx section numbers on our security/surveillance specifications since at least 2006.

Regardless of numbering, many architects, engineers and general contractors still consider security/surveillance and other low voltage systems to be a subset of the electrical trades, and their first instinct is to funnel this type of work through the project electrical contractor.

This practice (leaning on electricals for LV work) creates real problems, maybe bigger than is realized.

Usually bid responses are based on a scope of work described in an entire division.

For example, sticking surveillance in Division 26 (Electrical) means anyone responding must also be able/willing/qualified to install everything detailed there, including high-voltage electrical work.

Same when sticking Electronic Access Control in Division 8 (Openings, Doors, Windows). Responses often must be able to furnish everything relating to the package - doors, frames, hinges, exit devices, keys, and so on.

Usually, this means specialty security integrators who furnish a niche of those areas get squeezed out. Presumably, this also means the best qualified folks miss out on bidding the work.

Division 28 tries to fix that problem. Kudos to Michael Silva for recognizing it and using it! Unfortunately, I've had numerous conversations with architects who just shrug their shoulders on this issue.

Way late on this discussion but keep in mind that division 28 also contains fire alarm and other life safety systems so the same line of thought that anybody responding must also be qualified to do this work applies which often is not the case. My firm only specializes in technology and security consulting and often are part of an architects team that includes electrical engineers who are providing the fire alarm/life safety work. Because of this the general division 28 sections conflict with each other, i.e. who is responsible to write 28 00 00 and who sets precedence for the requirements within that section. We keep all of our work within division 27 and we never have conflicts or problems.
Way late on this discussion but keep in mind that division 28 also contains fire alarm and other life safety systems so the same line of thought that anybody responding must also be qualified to do this work applies which often is not the case. My firm only specializes in technology and security consulting and often are part of an architects team that includes electrical engineers who are providing the fire alarm/life safety work. Because of this the general division 28 sections conflict with each other, i.e. who is responsible to write 28 00 00 and who sets precedence for the requirements within that section. We keep all of our work within division 27 and we never have conflicts or problems.

This issue goes far beyond how specifications are numbered and simply renumbering specification sections won't solve the problem.

It's really up to the general contractor to decide who does the work of each specification section, as he assumes legal responsibility for the final outcome of the project. Most owners and architects give the general contractor wide latitude in choosing how he wishes to divide up the work and who he chooses to issue subcontracts to. The thinking is, the more specifically you tell the contactor how to do his job, the less ability you have to hold him responsible for the outcome.

I have lost many a battle with architects and owners trying to control who does the security/surveillance work on a project. In some cases, with the owner's backing, I have been successful, but in many more cases, the general contractor pretty much does as he pleases once he is awarded the contract. I have been fighting this problem for 29 years now and still don't have the answer.

Novice specification writers think that they can insert a laundry list of requirements into a specification ("must be specialty contractor in business for at least 10 years", "must have done at least 15 jobs of a similar type","must be factory certified by ABC and XYZ", must maintain local spare parts inventory", etc.), but in most cases these clauses are unenforceable and will simply be ignored by the general contractor.

Most general contractors prefer to deal with as few subcontractors on a project as possible, and for this reason alone, prefer to give the security/surveillance and other low voltage work to the electrical contractor rather than hiring 3 or 4 additional specialty subcontractors.

"must have done at least 15 jobs of a similar type","must be factory certified by ABC and XYZ", must maintain local spare parts inventory", etc.), but in most cases these clauses are unenforceable"

Why are they unenforcable in most cases? In what cases would they be enforceable?

In a public sector jobs, clauses of this type are often thought to be backdoor ways of wiring a spec to a specific supplier or contractor and are therefore considered to unfairly restrict competition. Some clauses, such as "must have done at least 15 jobs", are considered arbitrary: why is someone who has done 14 jobs not qualified, but someone who has done 15 jobs is?

It is possible to insert requirements such as these in a spec, but you had better be prepared make a compelling case (backed up with facts, not opinions) for them if they get challenged in a bid protest. Many owners, particularly in the public sector, are scared to death of bid protests and usually back down rather than try and enforce requirements that they don't feel are absolutely essential.

In private sector jobs, the owner can pretty much ask for anything he wants, but considers his relationship with the general contractor far more important than his relationship with his architect or other consultants. If the general contractor insists on one thing, and the security consultant is asking for another, the general contractor usually wins.

Michael,

That makes sense.

How about if the requirement was 'must have done at least 1 / 2 / 3 jobs of a similar type.' I agree that 15 sounds fishy but there appears to be a reasonable interest for specifiers to block out someone who has never done a similar job.

I have found the best approach is to specify the experience and certifications that the people doing the work (not the companies) must possess in order to do the job. I tend to make these fairly general ("must have experience with network based security management systems of a similar type and size...) rather than require a specific number of jobs or years.

I also tend to call out experience and certifications by type of work rather than for the entire job (technicans making final connections and programming the intelligent control panels shall have XXX certifications, xxx experience. This allows lesser qualified people to do things such as pull wire, terminate devices, etc. while at the same time requesting that people doing higher level work be qualified to do so.

Indeed. I think the qualifications and record are the most important thing to the job. After all, when all the other contractors are long gone, the integrator/customer relationship continues. Anyway, Part 1 of the CSI Format spec section allows specific requirements the integrator must satisfy before being considered for a project. It is here you would specify a list of credentials, certifications, years of service, systems installed, etc. It is also here where many specs fail by not requiring proof of such qualifications at the time of bid. In this way, you don't get past the contracting stage and feeling all warm and fuzzy about your decision, only to find out your integrator was not telling the truth or no longer has the same talent to dedicate to your project.

I have never had this problem. Prior to the CSI 28 division change, i used to put specs under Division 16 (electrical). CIS is the standard format and it has always worked well for me. I have two ways to bid work: one is a "negotiated award" where there is a quality competition between bidders; the other is a strait low bid where i control the quality through the spec the decision is based on the lowest QUALIFIED bidder cost. The Owner could select an UNquailifed bidder (i.e. that does not meet the requirements of the spec), but thankfully, i have never had that problem. In fact, typically, the Owner leaves the decision up to me (using my methods for justification of course). As a rule, when the GC Submits his list of subs, I am their to review the submission and offer my opinion. Just because he may be the lowest price does not mean he is the worst candidate. If he is meets the quals (as part of his bid submission, there is a number of forms and proof submittals require) he gets the work.

In my ongoing school project, the integrator's cost was in fact greater than both the budgeted cost and the lowest bidder.

I have used the CSI format for years and believe its the best thing out there. It’s easy to understand, well known by design pros and most contractors and subs and it’s layout simply makes sense. That said, the format may be a bit unfamiliar to many integrators ... perhaps because most jobs they do are not designed by a professional security designer/consultant or even (yes even) a professional engineer (PE). Here is a link to the CSI Masterformate complete with a description of the three level numbering systems CSI introduced in 04. Division 28 (the first level) is assigned to “Electronic Safety and Security” and it is this division where all your specs for security systems should be found. Prior to 2004, I would put security systems in Div 16 (Electrical) as that was the most logical place. Typically Electronic Access Controls and Intrusion Detection are now found in section 28 10 00 and Electronic Surveillance in 28 20 00.

It is noted that a number of other sections are/may be relevant to security systems—Division 08 (Openings) being the most obvious. My preference is Section 08 74 00 (Access Control Hardware), but you can also find electrical door hardware in the Finish Hardware Section (Section 08 71 00). Other divisions (i.e. Division 26 Electrical, Division 27 Communications, Division 14 Conveying Equipment) are also often involved.

Check out the link. I think you will find more answers. You can also purchase a number of explanatory publications from www.CSInet.org .

I have seen Access information under div 10 Locks. I see with frequency Division 28 on bid sets everyday

Hi Marty. Division 10 is "Specialities" which covers things like signs, directories, cubical items, partitions, toilet and bath specialities. It would be very strange to find door hardware in this division. Division 8 is for "Openings" which includes doors, windows and finish hardware. Section 087000 is where you would find door hardware; but here is where it gets different because some like to call out "Access Control Hardware" (basically intended only for readers) while others will put electrical hardware in Sections under level 087000 because the architect wants to give the responsibility for providing electrical door hardware to the same guy who installs the mechanical items.

Know that CSI is revising these CSI sections for issue sometime later this year.

I started another discussion about this issue. Im interested in seeing how integrators respond.

I don't have any problem or confusion with my specs in Div 28. In fact, it works for me by separating all safety stuff. Often the integrator is capable of bidding all the Div 28 items which sweetens the deal for the integrator. I also coordinate my work closely with Div 8 using an independent hardware consultant who works for me or the architect. We have a way of specifying all the hardware under Div 8, while segregating each hardware set into categories if we want the Integrator to bid the electrical hardware. Its really the best way to do it and make sure new doors are properly templated.

I recall reading one study that said door hardware was the top coordination problem listed by architects. To ease the burden, the project architect will assign hardware scheduling to a manufacturer. Pretty sweet deal for the manufacturer. I have an Independent Hardware Consultant who tries to save cost for the owner by specifying needed hardware for the project (i.e. maybe only one leaf of a door pair needs to be electrified, or he specifies a retrofit kit for $200 instead of two new exit devices ($4000 or more).

"To ease the burden, the project architect will assign hardware scheduling to a manufacturer. Pretty sweet deal for the manufacturer."

Indeed. See: Should Manufacturers Write A&E Specs?