19.3 Submittal Workflow, Review Responsibility & Action Stamps
Key Takeaways
- Shop drawings, product data, and samples are not contract documents, so approving a submittal does not change the contract requirements.
- The contractor must review, approve, and stamp submittals before transmitting them, and the architect may return unstamped submittals without review.
- The architect reviews for conformance with the design concept and the information given in the contract documents, not for dimensions, quantities, or means and methods.
- Standard actions are approved, approved as noted, revise and resubmit, and rejected, and each carries different consequences for fabrication.
- Under A201 Section 3.12.8 a deviation is effective only if the contractor gives specific written notice of it and the architect approves that specific deviation in writing.
Submittal Processing Workflow under AIA A201 Section 3.12
During construction administration, the processing and review of contractor submittals represents one of the architect's most time-intensive and legally sensitive duties. Submittals encompass several distinct categories of technical documentation:
- Shop Drawings: Drawings, diagrams, schedules, and other data specially prepared for the work by the contractor, subcontractor, manufacturer, supplier, or distributor to illustrate some portion of the work (A201 Section 3.12.1). Examples include structural steel fabrication details, precast concrete panel layout drawings, and custom architectural millwork elevations.
- Product Data: Illustrations, standard schedules, performance charts, instructions, brochures, diagrams, and other information furnished by the contractor to illustrate materials or equipment for some portion of the work (Section 3.12.2). Examples include mechanical air handler cut sheets, plumbing fixture schedules, and roofing membrane technical specifications.
- Samples: Physical examples that illustrate materials, equipment, or workmanship and establish standards by which the work will be judged (Section 3.12.3). Examples include masonry brick mock-up panels, paint draw-downs, carpet swatches, and anodized aluminum finish coupons.
The Fundamental Legal Rule: Submittals Are NOT Contract Documents
A central principle of construction law codified in AIA A201 Section 3.12.4 states unequivocally:
"Shop Drawings, Product Data, Samples, and similar submittals are not Contract Documents. Their purpose is to demonstrate how the Contractor proposes to conform to the information given and the design concept expressed in the Contract Documents for those portions of the Work for which the Contract Documents require submittals."
Because submittals are not Contract Documents, an architect's stamp on a shop drawing cannot legally alter the Contract Sum, extend the Contract Time, or modify the contract drawings and specifications. Contract requirements can only be altered through formal contract modification instruments: Change Orders, Construction Change Directives, or Architect's Supplemental Instructions.
┌────────────────────────────────────────────────────────────────────────┐
│ SUBMITTAL PROCESSING CYCLE │
├────────────────────────────────────────────────────────────────────────┤
│ 1. Subcontractor / Fabricator prepares Shop Drawings / Product Data. │
│ 2. General Contractor reviews, verifies field measurements, checks │
│ coordination with adjacent trades, and STAMPS approval. │
│ ► IF UNSTAMPED: Architect returns immediately WITHOUT ACTION. │
│ 3. Architect & Consultants review submittal ONLY for conformance with │
│ the design concept and Contract Documents. │
│ 4. Architect applies Action Stamp (Approved / Approved as Noted / │
│ Revise & Resubmit / Rejected) and returns to Contractor. │
│ 5. Fabricator initiates production only upon receiving appropriate stamp│
└────────────────────────────────────────────────────────────────────────┘
The Contractor's Review Stamp (A201 Section 3.12.5)
A critical gatekeeping requirement under AIA A201 Section 3.12.5 mandates that the contractor must perform an exhaustive internal coordination review before transmitting any submittal to the architect:
"The Contractor shall review for compliance with the Contract Documents, approve, and submit to the Architect, Shop Drawings, Product Data, Samples, and similar submittals required by the Contract Documents... By submitting Shop Drawings, Product Data, Samples, and similar submittals, the Contractor represents to the Owner and Architect that the Contractor has (1) reviewed and approved them, (2) determined and verified materials, field measurements, and field construction criteria related thereto, or will do so, and (3) checked and coordinated the information contained within such submittals with the requirements of the Work and of the Contract Documents."
The Rule of the Unstamped Submittal: If a general contractor forwards a subcontractor's shop drawings directly to the architect without the contractor's review and approval stamp, the architect must return the submittal immediately without action. The architect must not review it, log it, or pass it to consulting engineers. If the architect reviews an unstamped submittal, the architect effectively performs the general contractor's coordination duty, assuming legal liability for dimensional interferences, field layout errors, and trade clash detection.
Architect's Review Responsibility & Action Stamps
Under AIA A201 Section 4.2.7, the architect's contractual duty regarding submittal review is carefully delimited:
"The Architect will review and approve, or take other appropriate action upon, the Contractor's submittals such as Shop Drawings, Product Data, and Samples, but only for the limited purpose of checking for conformance with information given and the design concept expressed in the Contract Documents."
Section 4.2.7 specifically protects the architect against operational overreach:
- Review of submittals is not conducted for the purpose of determining the accuracy and completeness of other details such as dimensions and quantities.
- Review does not constitute approval of safety precautions or of any construction means, methods, techniques, sequences, or procedures.
- Approval of a specific item does not indicate approval of an assembly of which the item is a component.
Standard Submittal Action Stamp Categories
Architectural firms utilize standardized submittal action stamps. Understanding the exact contractual meaning of each action is essential for practice and the ARE:
| Stamp Action | Contractual Meaning | Next Steps for Contractor |
|---|---|---|
| Approved / No Exceptions Taken | Submittal conforms to the design concept and Contract Documents. | Contractor is authorized to proceed with fabrication, ordering, and installation. |
| Approved as Noted / Make Corrections Noted | Submittal conforms to design concept subject to minor handwritten notations or corrections marked by architect. | Contractor may proceed with fabrication and installation incorporating marked changes; no resubmission required. |
| Revise and Resubmit | Submittal contains significant errors, omissions, or non-conforming details that must be corrected. | Contractor cannot fabricate; submittal must be corrected and resubmitted for full review. |
| Rejected | Submittal is completely non-compliant with design concept, specifications, or basis of design product. | Contractor must select a compliant product/system and submit an entirely new submittal package. |
Risk Management Warning: Architects must never use words such as "Accepted" or "Checked" without qualification, nor should they stamp submittals with notes such as "Approved for Dimensions." Verifying field dimensions is solely the contractor's responsibility under Section 3.12.5.
The Strict Rule on Deviations (A201 Section 3.12.8)
Contractors frequently propose deviations from the contract drawings or specifications during the submittal process—sometimes to resolve field conflicts, and other times to substitute cheaper materials. AIA A201 Section 3.12.8 establishes a rigid two-prong standard governing deviations:
"The Contractor shall not be relieved of responsibility for deviations from the requirements of the Contract Documents by the Architect's approval of Shop Drawings, Product Data, Samples, or similar submittals unless the Contractor has specifically notified the Architect of such deviation in the submittal and (1) the Architect has given written approval to the specific deviation as a minor change in the Work, or (2) a Change Order or Construction Change Directive has been issued authorizing the deviation."
If a contractor changes a specified high-performance waterproofing membrane to an inferior product by quietly including the cut sheet in a 400-page submittal packet, and the architect inadvertently stamps the packet "Approved," the contractor is NOT relieved of the contractual duty to install the specified membrane. Because the contractor failed to provide specific written notification calling out the deviation, the contractor remains legally liable for removing the non-conforming material and installing the specified product at their own expense.
A curtain wall subcontractor submits 120 pages of structural aluminum mullion shop drawings and thermal glass product data directly to the project architect. The architect inspects the submittal transmittal and observes that the general contractor has not stamped, signed, or reviewed the submittal package. What is the architect's contractually required response under AIA Document A201 Section 3.12.5?
During submittal review for a commercial laboratory, the architect stamps 'Approved' on a custom air handling unit (AHU) submittal. Six months later, during mechanical commissioning, the owner discovers that the installed AHU cooling coil capacity is 25% lower than specified in Project Manual Division 23. The contractor claims that because the lower coil capacity was listed on page 42 of the approved submittal, the architect's approval relieved the contractor of the original specification requirement. What is the legal status under AIA A201 Section 3.12.8?