Frequently asked questions - Plumbing plan review

1. What types of projects need to be reviewed by the DLI?
2. Do I need to submit plans for just handicap restroom remodeling?
3. What about projects are considered "minor remodel?" Do I need to submit plans?
4. Why does DLI review plumbing plans for public and commercial buildings?
5. Who is the "administrative authority?"
6. Who can prepare and submit these documents?
7. What is the approximate amount of time that should be allotted for the plan review process? Also -- plan review used to take one to two weeks - why does it sometimes take longer now?
8. Delays cause expense.
9. Cities should be able to do plan review.
10. What can be done to speed up the plan review process?
11. Are approved plans returned to the applicant?
12. Should those approved plans be on site?
13. Can work begin without approved plans?

1.) What types of projects need to be reviewed by DLI?

Minnesota Rules, part 4715.3130 states: "Prior to the installation by any person, corporation, or public agency, of a system of plumbing that serves the public or that serves any considerable number of persons, or any plumbing system that shall affect the public health in any manner, complete plans and specifications, together with any additional information that the commissioner of the Minnesota Department of Labor and Industrymay require, shall be submitted in duplicate and approved by the commissioner. The appraisal of the commissioner shall reflect the degree to which these plans and specifications affect the public health and conform to the provisions of the Minnesota Plumbing Code. No construction shall proceed except in accordance with approved plans. Any material alteration or extension of the existing system shall be subject to these same requirements. This rule shall not apply to cities of the first class, except those plumbing installations in hospitals or in buildings in these cities owned by the federal or the state government."

Except for cities with formal plan review agreements with DLI, all plumbing installation must be submitted to the department for review.  This includes all new, additions, extensions and alterations in public and commercial buildings, and residential buildings in units of five or more.

Approximately 45 cities have a formal agreement to perform plumbing plan reviews on all projects requiring plan review. Contact this office or the Plumbing Standards Representative in your area of the state if you have any questions or concerns. View a list of cities that have plan review agreements with DLI.

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2.) Do I need to submit plans for just handicap restroom remodeling?

Except for state licensed healthcare facilities, projects that would simply involve restroom fixture replacement or moving fixtures to accommodate handicap installation requirements without substantially changing concealed piping would not require plan submittal. Plumbing inspections must still be performed. Please check with the administrative authority.

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3.) What about projects that are considered "minor remodel?" Do I need to submit plans?

A "minor remodel" project is considered a plumbing project consisting of five or fewer fixtures and applies to standard installation where the work does not present any ambiguity of code compliance for a licensed plumbing contractor. An inspection must still be performed by a qualified inspector from the city or DLI to verify compliance with the Plumbing Code.

Five-fixture type  "minor remodel" installation shall NOT apply to:

1. Any state licensed facilities (MDH licensed health care facilities and MN state correctional facilities as defined in MN Statutes, 326B.43, subd. 1), and
2. Any commercial kitchens, or other food/beverage preparation or processing areas. Exception is if the scope of work is solely within the restroom with five or fewer fixtures.

A checklist has been established for use as guidance to determine if the proposed  "minor remodel" project may qualify for exemption of plan review by DLI. The administrative authority retains the right to deny any request that is not considered standard installation not listed in the checklist or if any plumbing work is installed prior to permitting.

For projects where the municipality is the administrative authority and the scope of the plumbing work is limited to standard plumbing installation consisting of five or fewer fixture-type in non-licensed facility considered a "minor remodel" such as water closet/lavatory installation in existing facilities, check with the administrative authority regarding plan review. This is not binding in any municipalities. A municipality can still require plan review and submittal to DLI for any plumbing installation. Plumbing inspections must still be performed by the administrative authority.

For projects where DLI is the administrative authority and if the proposed plumbing work is determined to be considered a "minor remodel," ALL of the following required information must be submitted to DLI:

1.   An inspection permit application from DLI must be completed by the plumbing contractor.

2.   Pay required inspection fee calculated from application; and

3.   Submit signed plumbing plans for the minor remodel for filing and inspection purposes. However, no plan review fee is required if plan review is exempted.

Upon confirmation from DLI receiving the required items, the plumbing contractor may proceed to install without plan review. All installations must meet the Minnesota Plumbing Code and required inspections must be notified and performed in accordance with Minnesota Rules, parts 4715.2800 and 4715.2810. View more information about inspections.

Be advised that incomplete submittal or inaccurate information will delay the request and/or the permitting application will be declined. In cases where the information provided on the permitting is not accurate or misleading, and does not reflect the scope of "minor remodel" installation, a letter will be issued requesting for an additional plan review fee and/or information.   

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4.) Why does DLI review plumbing plans for public and commercial buildings?

The Minnesota Plumbing Code requires that plans for all plumbing projects that serve the public must be reviewed and approved by DLI. The purpose of plan review is to check whether proposed projects will comply with the Minnesota Plumbing Code. If they do not, corrections can be made to the plan rather than to an actual plumbing system, saving time and expense.

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5.) Who is the "administrative authority?"

"Administrative authority" usually means the commissioner of the Department of Labor and Industry. However, when a governmental subdivision (e.g. a city) adopts and maintains a comprehensive plumbing enforcement program that is conducted by persons knowledgeable about plumbing installation requirements, and includes enforcement of all code provisions including materials, methods, inspection, and testing, then the administrative authority is the governing body of the adopting unit of government, its agents, and employees. The commissioner of DLI retains the ultimate authority to enforce Minnesota Statutes, sections 326.37 to 326.45, and provisions of the plumbing code that are necessary to ensure compliance. (From Minnesota Rule, part 4715.0100 "Definitions").

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6.) Who can prepare and submit these documents?

According to the Board of Registration of Architecture, Engineering, Land Surveying, Landscape Architecture, Geoscience and Interior Design, plans shall be submitted by a registered engineer. However, a master plumber may also submit plans for projects where they are performing the installation.

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7.) What is the approximate amount of time that should be allotted for the plan review process? Also - plan review used to take one to two weeks - why does it sometimes take longer now?

The amount of time needed to review plans once they reach our office may vary depending on the number of plans submitted for review. Typical turnaround time has been two weeks in winter and fewer than four weeks in summer. An optional accelerated plan review fee can be paid and those turnaround times have been approximately one week. Contact DLI for current information about plan review turnaround time at (651) 284-5043.

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8.) Delays cause expense.

We understand that delays in projects can cause expense. We would like to have enough staff to always keep our turn-around time for plan review to one to two weeks, or even less. However, at this time, we are not able to hire additional staff to handle high workloads. Our turn-around time during the construction season is always somewhat longer during spring and summer than during fall and winter months. We frequently assess workloads and procedures to minimize delays.

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9.) Cities should be able to do plan review.

NOTE: The Minnesota Department of Labor and Industry has suspended the issuance of new plumbing plan review agreements with municipalities. Municipalities with existing agreements may continue to do plan reviews.

Minneapolis, St. Paul, and Duluth all have their own plumbing programs. A number of other cities have plan review agreements with DLI, and take responsibility for plan review on most plumbing projects.

Cities may request an agreement with DLI to take over responsibility for plan review if they have passed an ordinance requiring submitting of plans to the city for review, hire staff with the expertise to conduct plumbing plan review (assessed on professional experience and passing a competency evaluation), and agree to enforce the Minnesota Plumbing Code in its entirety. Approximately 45 cities have a formal agreement to perform plumbing plan reviews on most projects requiring plan review. View this list of cities that have plan review agreements with DLI.

For cities with a plumbing plan review agreement with DLI, there are some projects that still require state review. Projects in these cities that require plumbing plan review by DLI are:

• buildings owned by Federal or State government;
• projects of a special nature for which review by DLI is requested by either the city or other state agencies.

In addition, health care projects in these cities that require plumbing plan review by both DLI and Minnesota Department of Health are:

• Hospitals, nursing homes, supervised living facilities, and similar health care related facilities regulated by the Minnesota Department of Health (MDH).

Contact us if you have any questions or concerns.

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10.) What can be done to speed up the plan review process?

Encourage designers to submit complete, easy-to-read plans. A project described in an incomplete or illegible plan must be reviewed at least twice - an initial review, and then additional review(s) of the materials the designer failed to provide with the original plans. Incomplete plans often require twice as much staff time to review and respond as complete plans. Incomplete or illegible plans increase workload and takes staff away from plan approvals, and results in delay of plan approval. For January through July 2002, 521 of 1639 plans submitted were incomplete. This means almost 1/3 of the plans submitted had to be reviewed more than once because the designer did not provide a complete, or legible plan. Up to 1/4 of our staff time is spent requesting and reviewing corrections of incomplete plans.

Do not fax plans. They don't transfer well and are often illegible.

Please resist the temptation to call on status. On average, a status call takes an engineer away from plan review for about five minutes. While that may not seem like much time per call, in typical summer months our engineers receive over 1,000 calls per month. That translates into more than 80 hours of time per month on the phone that cannot be spent on plan review. Our support staff spends a similar amount of time, which is time away from preparation and mailing of approval and correction letters.

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11.) Are approved plans returned to the applicant?

If the submitter requests, the plans can be returned, otherwise they will be discarded.

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12.) Should those approved plans be on site?

Yes, a copy of the plan that was submitted for approval should be on site to allow the installer to install according to the approved plan and to assist the inspector to verify installation according to the approved plan.

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13.) Can work begin without approved plans?

"No construction shall proceed except in accordance with approved plans" (Minnesota Rule, part 4715.3130). We send approval or correction letters on all projects submitted for review. On occasion, this department has given verbal approval to a contractor to begin installation after the plan has been received, reviewed for compliance, and contact has been made with the local administrative authority to ensure that they are aware of and approve the contractor starting prior to receipt of the plan approval report. DLI staff will also work with designers and contractors regarding "fast track" projects where a part of the plan for underground or above-ground plumbing has been submitted for review and approval, and the remaining part(s) of the plan are to be submitted at a later date (but prior to installation of those parts of the plumbing system!).

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