18.3 Construction Changes: Change Orders (CO), CCDs, ASIs & DSA Category A/B CCDs

Construction Changes: Change Orders (CO), CCDs, ASIs & DSA Category A/B CCDs

During the construction phase of an architectural project, unforeseen site conditions, regulatory interpretations, owner-requested modifications, design clarifications, or material supply chain disruptions inevitably necessitate changes to the work. In architectural practice, managing these changes demands rigorous adherence to contractual protocols and state regulatory mandates. Under AIA Document A201-2017 Article 7, construction changes are executed through three distinct contractual instruments: Architect's Supplemental Instructions (ASI), Change Orders (CO), and Construction Change Directives (CCD). In California public school and community college construction under the jurisdiction of the Division of the State Architect (DSA), changes are governed by statutory procedures under the Field Act (CCR Title 24, Part 1, Chapter 4 and DSA Interpretation of Regulations IR A-6) requiring specialized Construction Change Documents (Form DSA 140) classified into Category A and Category B. Candidates preparing for the California Supplemental Examination (CSE) must understand the precise procedural differences, required signatures, cost determination rules, and regulatory pre-approval mandates for each change mechanism.

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The Three AIA Contractual Change Instruments (AIA A201 Article 7)

AIA Document A201-2017 Article 7 governs changes in the work. It establishes that changes may be accomplished after execution of the contract, and without invalidating the contract, by Change Order, Construction Change Directive, or order for a minor change in the work.

1. Architect's Supplemental Instructions (ASI / AIA Document G710)

Under AIA A201 Section 7.4, the architect possesses sole authority to order minor changes in the work that:

• Are consistent with the intent of the Contract Documents; and
• Do not involve an adjustment in the Contract Sum; and
• Do not involve an extension of the Contract Time.

Such changes are issued using AIA Document G710 (Architect's Supplemental Instructions). The ASI is an administrative order signed solely by the architect and is binding on both the owner and contractor. The contractor must execute the work promptly.

Contractor Notice Rule: If the contractor believes that the instructions issued in an ASI will cause an increase in the Contract Sum or Contract Time, the contractor must not proceed with the work and must promptly give written notice to the architect within the timeframe specified in the contract (typically 14 to 21 days pursuant to A201 Article 15) before executing the work. If the contractor performs the work without giving timely written notice, the contractor waives any right to claim additional compensation or time.

2. Change Order (CO / AIA Document G701)

Under AIA A201 Section 7.2, a Change Order is a written instrument prepared by the architect and signed by the Owner, Contractor, and Architect stating their mutual agreement upon all of the following:

1. The change in the Work;
2. The amount of the adjustment, if any, in the Contract Sum; and
3. The extent of the adjustment, if any, in the Contract Time.

A Change Order is a bilateral (or tripartite) amendment to the prime contract. Because all three parties have agreed on the scope, cost, and schedule adjustments, the Change Order becomes immediately binding upon execution. The contractor may bill for completed Change Order work on subsequent progress payment applications (AIA G702/G703).

3. Construction Change Directive (CCD / AIA Document G714)

Under AIA A201 Section 7.3, a Construction Change Directive is a written order prepared and signed by the Architect and Owner, directing a change in the Work prior to agreement on adjustment, if any, in the Contract Sum or Contract Time, or both.

Why Use a CCD?

A CCD is a unilateral contractual tool utilized when:

• The owner and contractor cannot agree on the proposed price or time extension for an essential scope change;
• Time is of the essence, and waiting for formal change order price negotiations would cause catastrophic jobsite delay; or
• An emergency or immediate life-safety condition requires immediate field execution.

Signatures and Mandatory Compliance

A CCD requires only the signatures of the Owner and Architect. It does not require the contractor's signature to be effective. Upon receipt of a valid CCD, the contractor must promptly proceed with the change in the Work.

Cost Determination Under AIA A201 § 7.3.3 & § 7.3.7

If the CCD provides for an adjustment to the Contract Sum, the adjustment is calculated using one of four methods:

1. Mutual acceptance of a lump sum properly itemized and supported by sufficient substantiating data;
2. Unit prices stated in the Contract Documents or subsequently agreed upon;
3. Cost to be determined in a manner agreed upon by the parties and a mutually acceptable fixed or percentage fee; or
4. If the contractor does not respond promptly or disagrees with the method of adjustment, the method is determined under Section 7.3.7 (Time and Material / Force Account).

Under Section 7.3.7, the architect determines the cost based on reasonable expenditures and savings of those performing the work, including:

• Actual costs of labor (payroll taxes, fringe benefits, workers' comp);
• Costs of materials, supplies, and equipment (including transportation);
• Rental costs of machinery and equipment;
• Costs of premiums for bonds and insurance, permit fees, and sales taxes; and
• A reasonable allowance for contractor overhead and profit as defined in the contract.

Conversion of CCD to Change Order (A201 § 7.3.6)

If the contractor agrees with the architect's determination of the cost and time adjustment, the contractor signs the CCD. The CCD then immediately becomes effective as a Change Order.

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Division of the State Architect (DSA) Construction Change Documents (CCDs)

In California public school (K-12) and community college construction projects governed by the Field Act, changes to the state-approved plans and specifications are strictly regulated under California Code of Regulations (CCR) Title 24, Part 1, Chapter 4, Group 1, Section 4-338 and DSA Interpretation of Regulations (IR) A-6. In DSA parlance, construction changes are documented using Form DSA 140: Construction Change Document (CCD).

DSA categorizes all design and construction changes into two distinct legal classifications based on their impact on public safety:

                                  ┌───────────────────────────────┐
                                  │   DSA Construction Change     │
                                  │   Document (Form DSA 140)     │
                                  └───────────────┬───────────────┘
                                                  │
                         Does the change affect any of the following?
                         1. Structural Safety (SS)
                         2. Fire and Life Safety (FLS)
                         3. Accessibility (Access)
                                                  │
                         ┌────────────────────────┴────────────────────────┐
                         ▼                                                 ▼
                       YES                                                 NO
           ┌─────────────────────────────┐                  ┌─────────────────────────────┐
           │       CATEGORY A CCD        │                  │       CATEGORY B CCD        │
           ├─────────────────────────────┤                  ├─────────────────────────────┤
           │ • Affects SS, FLS, or Access│                  │ • Does NOT affect SS, FLS,  │
           │ • DSA Plan Check & Written  │                  │   or Accessibility          │
           │   Approval MANDATORY BEFORE │                  │ • Does NOT require DSA      │
           │   work begins in the field  │                  │   pre-approval to construct │
           │ • Unapproved work subject to│                  │ • Signed by AOR; logged by  │
           │   Stop Work / Non-Cert      │                  │   IOR; filed at closeout    │
           └─────────────────────────────┘                  └─────────────────────────────┘

Category A CCDs (Mandatory DSA Pre-Approval Required)

A Category A CCD encompasses any change that affects one or more of the three pillars of DSA jurisdiction:

1. Structural Safety (SS): Modifications to foundations, structural framing members, load-bearing walls, shear walls, diaphragm nailing, structural connections, or seismic force-resisting systems;
2. Fire and Life Safety (FLS): Alterations to exit corridors, exit doors, occupant loads, travel distances, fire-resistance-rated assemblies, fire alarm systems, fire sprinkler layouts, or emergency lighting;
3. Accessibility (Access): Modifications to accessible paths of travel, ramp slopes, curb ramps, door opening widths, door hardware, accessible restroom layouts, clearance dimensions, or disabled parking stalls.

Strict DSA Field Rule: A Category A CCD MUST be submitted to DSA and receive formal plan check review and written approval BEFORE the work is performed in the field! If a contractor proceeds with Category A work prior to receiving DSA written approval, the DSA field engineer or Project Inspector will issue a Notice of Non-Compliance (Form DSA 154) or a Stop Work Order. Work executed without DSA approval cannot be certified and may have to be demolished.

Category B CCDs (No Pre-Approval Required)

A Category B CCD encompasses changes that do not affect Structural Safety, Fire and Life Safety, or Accessibility. These are minor architectural, mechanical, or electrical revisions that comply fully with code and do not touch regulated life-safety elements:

• Interior paint color changes or finish substitutions (non-rated);
• Minor millwork, casework, or shelving modifications not located in accessible paths or required clearance zones;
• Non-structural ceiling tile changes;
• Minor landscaping revisions outside the accessible route of travel.

Category B CCDs do not require DSA plan check approval prior to construction. The Architect of Record prepares and signs the Form DSA 140 (Category B), transmits it to the general contractor, provides a copy to the DSA Project Inspector (IOR) on site, and submits the document to DSA for informational logging and verification during project closeout.

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Comparison Table: Construction Change Instruments & DSA CCD Rules

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CSE Exam Traps & Practical Takeaways

• Trap 1: Confusing CCD Signatures in Standard AIA Contracts: Candidates often mistakenly believe a Construction Change Directive requires the contractor's signature. It does not. A CCD is specifically designed as a unilateral mechanism requiring only the Owner and Architect signatures so that work cannot be stalled by a contractor's refusal to agree on price.
• Trap 2: Issuing an ASI That Costs Money: An architect can never use an ASI to resolve a field problem that increases the contractor's cost or schedule, even by one dollar or one day. If cost or time is affected, a Change Order or CCD must be used.
• Trap 3: Commencing DSA Category A Work Without Pre-Approval: In public school projects, contractors often pressure architects to let them proceed with Category A framing or door changes "while DSA plan check is pending." Permitting this violates Title 24. Category A work executed without DSA written approval jeopardizes the school's certification and the architect's professional license.
• Trap 4: Forgetting the DSA Project Inspector's Role: Under Title 24, the DSA Project Inspector (IOR) cannot inspect or sign off on any work that deviates from the original DSA-approved plans unless the inspector has an approved Category A CCD (stamped by DSA) or an issued Category B CCD (signed by the AOR) in hand.