Review vs Approval: Construction Submittals - Issue 144 - August 2024

Oct 24, 2026

Construction submittal documents communicate how contractors will meet design intent, including shop drawings, samples, calculations, cut sheets, warranties, guarantees, diagrams, and vendor information. Submittal review is a meticulous process requiring initial contractor QC review followed by technical conformance review by the Architect/Engineer of Record and other NIH reviewers. Reviewers identify deviations, ensure required clearances, and assess overall fitness for purpose while avoiding unintended risk transfer to the Government. The guidance explains differences between review and approval, including cases requiring A/E approval, Government selection, or Government approval, and highlights use of change orders to resolve risk-related conditions.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages2

Reading Time5 min

AccessFree to download

Introduction

Review Practices

Submittal Review vs Approval

Submittals Requiring A/E Approval

Submittals Requiring Government Selection

Submittals Requiring Government Approval

Conclusion

References & Further Reading

Issue 144 Aug 2024 Review vs Approval: Construction Submittals Introduction Construction submittal documents (which may include shop drawings, material samples, engineering calculations, product cutsheets, mockups, vendor information, material data sheets, warranties, guarantees, diagrams, etc. ) are a means of communicating how the contractor intends to achieve the design intent as conveyed by the approved-for-construction documents. Reviewing construction submittals can often be a meticulous and time-consuming process, but it is critical to ensure conformance to the relevant specifications, design drawings, and other approved-for-construction documents. The construction contractor performs the initial review and is generally responsible for ensuring count, dimensional coordination, sequence with other work, existing conditions, compatibility with other work, and other factors that are reviewed as part of the contractor’s independent quality control process. This is followed by subsequent review by the Architect/Engineer (A/E) of Record and other NIH reviewers (including professional staff, users, and contracted independent consultants) . Per contract language and liability, the A/E is responsible for technical conformance review of construction submittals. Other NIH parties provide review focused on conformance with design intent, including functionality, maintainability, operability, reliability, etc. Review Practices The contractor must provide the initial review and approvals of all submittals, followed by the A/E of record, who is responsible for compliance with the construction documents. It is preferable to wait until the A/E of record has reviewed the submittals before beginning NIH review, though project timelines often demand parallel review by the NIH. In all cases, NIH reviewers must exercise care to not give direction to the contractor, unless delegated with such authority by the Contracting Officer (CO) . Reviewers must also be cautious to avoid unintentionally transferring risk from the A/E and construction contractor to the Government. To mitigate this risk, the Federal Acquisition Regulation includes a clause that states that “approval by the CO shall not relieve the contractor from responsibility for errors oromissions”6; regardless, avoid creating approval language which confuses the distribution of risk as defined by the contract or which may be used in a manner that appears to alter the contract. The proper tool for resolving this type of condition is the change order process, managed by the CO. NIH reviewers should compare the submittal to the approved-forconstruction specifications and other documents, identifying and commenting on any deviations (e.g., discrepancies, inconsistencies, etc. ) from the specifications, applicable regulations, quality, fitness for use, function, compatibility, reliability, maintainability, etc. Reviewers should also consider ensuring the provision of all operational and maintenance clearances. Overall, look for whether the submittal appears fit for the intended purpose. Catching potential problems early in the submittal process can save time, money, and potential maintenance headaches. Submittal Review vs Approval Although NIH reviewer comments should generally seek to avoid transferring risk to the Government, there are instances where selection and/or approval by NIH representatives is required, such as: Submittals Requiring A/E Approval: The most typical submittal type, where the A/E of Record or their designee is responsible for a Quality Control (QC) level of review of the proposed product and selected options (e.g., material of construction, finishes, functions, etc. ) against the approved-for-construction documents (i.e., specifications having determinative authority, supplemented by the calculations, drawings, basis of design, etc. ) . In this case, NIH reviewers are responsible for a Quality Assurance (QA) review, ensuring adequate QC by the

FAQs

What is the purpose of reviewing construction submittal documents?

Reviewing construction submittals ensures they conform to approved-for-construction documents, relevant specifications, and applicable requirements, and that the proposed work is fit for the intended purpose.

How does the review process differ between contractor review and A/E of Record review?

The contractor conducts initial review as part of independent quality control, then the A/E of Record performs technical conformance review as required by contract, with other NIH reviewers focusing on conformance with design intent.

When might NIH representatives need to provide selection or approval of submittals?

Selection/approval may be required for submittals needing A/E approval, limited Government selection, or Government approval for specialized or highly critical systems, with risk mitigated through QC reviews and, when needed, testing and commissioning.

Oct 24, 2026

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