2.3 Inspection Sequence & the Permanent Energy Certificate (R105, R401.3)
Key Takeaways
- R105 requires energy-relevant inspections at footing/foundation, framing and rough-in, plumbing rough-in, mechanical rough-in, and final; work must remain visible until approved.
- R105.2.1 footing/foundation checks insulation R-value, location, thickness, depth of burial, and protection; R105.2.2 framing/rough-in is before interior finish and covers insulation, fenestration U/SHGC, and air-leakage controls.
- Where required by the code official, blower-door, duct, and ventilation testing shall be conducted by an approved third party, with a signed written report provided to the code official (R105.4 and the Chapter 4 testing sections).
- R401.3 requires a permanent certificate completed by the builder or other approved party, posted on a wall in the furnace space, a utility room, or an approved interior location — and if placed on an electrical panel it must not cover the circuit directory, service disconnect, or other required labels.
- The certificate must list predominant R-values, fenestration U and SHGC (largest-area value and area-weighted average if available), duct and envelope leakage results, HVAC/DHW types/sizes/efficiencies (no efficiency for gas-fired unvented room heaters, electric furnaces, or electric baseboard), on-site PV data if installed, ERI with and without on-site generation if R406 is used, and the code edition and compliance path.
2.3 Inspection Sequence & the Permanent Energy Certificate (R105, R401.3)
Quick Answer: The plans examiner locks climate zone, design temperatures, R-values, NFRC numbers, and the compliance path before permit. The field inspector uses R105 stages — foundation/slab edge, rough-in, insulation before cover, then final — and will not occupy the house without the R401.3 permanent certificate. If that certificate is on the electrical panel, it must not cover the circuit directory, service disconnect, or other required labels.
Exam 79 scores general plans and inspection as 28% of the outline, including general inspection tasks at 6% and location/design conditions at 2%. This section is that inspection half of Chapter 2: who looks at what, when the work has to be visible, when a third party may test, and what the permanent certificate must say in 2021.
Plans examiner versus field inspector
The two hats are different even when the same person wears both in a small jurisdiction.
Plans examiner (construction documents, R103, before permit). Confirm the county climate zone from Figure R301.1 or Table R301.1, the R302.1 indoor design temperatures, the compliance path (R401.2.1 prescriptive, R401.2.2 performance, R401.2.3 ERI, or R401.2.4 tropical), envelope and fenestration numbers for that zone, NFRC or default fenestration ratings, duct location and insulation, and that the drawings depict the building thermal envelope. Reject a King County 4C set that uses 4 except Marine floors. Reject a Manual J at 72°F cooling. Reject unlabeled windows that have been given a fantasy U-0.30.
Field inspector (R105, after permit). Confirm that the installed work matches the approved documents while it is still visible. Foundation insulation and its 6-inch-below-grade protective covering cannot be verified after backfill. Window NFRC labels and air-sealing details cannot be verified after drywall. Blown-attic markers cannot be verified after the hatch is blocked with storage. The permanent certificate cannot be verified until it is actually posted.
Do not open R104 looking for inspection stages. In the 2021 IECC residential first printing, R104 is Fees, and R104.3 Work Commencing Before Permit Issuance only assesses an additional fee when work starts before a permit. Inspection stages and approved agencies are R105. R105.4 Approved Inspection Agencies authorizes the code official to accept reports of third-party inspection agencies not affiliated with the building design or construction, provided those agencies are approved as to qualifications and reliability relevant to the components and systems they inspect. That is the legal hook for HERS raters, duct testers, and ventilation balancers when the code official requires them.
R105 — Work stays visible; five named inspections
R105.1 subjects permit work to inspection by the code official or a designated agent. The construction shall remain visible and able to be accessed until approved. It is the permit applicant's duty to keep the work visible. Neither the code official nor the jurisdiction is liable for the expense of removing finish that was installed too early. "We already hung drywall" is not an energy-code exception.
R105.2 lists the inspections the code official or designated agent shall make upon notification:
R105 energy inspection map (2021)
| Stage | Section | Energy items the inspector is there to see |
|---|---|---|
| Footing and foundation | R105.2.1 | Insulation R-value, location, thickness, depth of burial, and protection as required by the code and approved plans (slab-edge, basement exterior, crawl exterior — including the R303.2.1 covering extending 6 inches below grade). |
| Framing and rough-in | R105.2.2 | Before interior finish: insulation types and R-values, correct location and installation; fenestration U-factor and SHGC and proper installation; air-leakage controls required by the code and approved plans. |
| Plumbing rough-in | R105.2.3 | Insulation types and R-values and protection, plus required controls (hot-water piping, circulation, heat trace as later chapters require). |
| Mechanical rough-in | R105.2.4 | HVAC type and size, required controls, system insulation and R-value, air-leakage control, programmable thermostats, dampers, whole-house ventilation, minimum fan efficiency. Exception: systems serving multiple dwelling units are inspected to C105.2.4. |
| Final | R105.2.5 | Building shall have a final inspection and shall not be occupied until approved. Verify required building systems, equipment, and controls and their proper operation, and the required high-efficacy lamps and fixtures. |
R105.3 allows reinspection where the code official determines it is necessary. R105.5 covers inspection requests. R105.6 covers reinspection and testing.
Practical sequence that matches those code names
Inspectors talk in job-site language. Map it onto R105 so you can find the section in the book:
- Foundation / slab edge — R105.2.1. Vertical slab insulation, basement/crawl exterior boards, protective covering, burial depth. Once the trench is filled, the evidence is gone.
- Rough-in — R105.2.2 plus R105.2.3 and R105.2.4 as those trades call. Air sealing, window installation (NFRC labels still on the units, flashing, shims), and ducts (location, insulation R-8/R-6 where required, no framing-cavity plenums) happen here. Mechanical rough-in is also when equipment type/size and ventilation are visible.
- Insulation (before cover) — still R105.2.2, which is expressly before application of interior finish. Batts with observable R-marks, spray-foam thickness, blown-attic 300-square-foot markers, installer certificates posted. This is the last look at cavity insulation.
- Final — R105.2.5 plus the R401.3 certificate, lighting, and test reports (envelope leakage, duct leakage, ventilation airflow). Occupancy waits on approval.
Third-party testing when the code official requires it
R105.4 plus the Chapter 4 testing sections govern third-party reports. Blower-door testing (R402.4.1.2): where required by the code official, testing shall be conducted by an approved third party; a written report of results shall be signed by the party conducting the test and provided to the code official. Duct leakage testing uses the same "where required by the code official, approved third party" pattern. Mechanical ventilation airflow testing (R403.6.3) likewise: where required by the code official, an approved third party tests, signs, and delivers a written report. R406 ERI verification of R406.5 and R406.7 is completed by an approved third party; R406.2 verification is by the authority having jurisdiction or an approved third-party inspection agency in accordance with R105.4.
The field inspector's job is not to pretend every jurisdiction mandates a HERS rater on every house. The job is to know that when the code official requires third-party testing, the tester must be approved, not affiliated with design or construction under R105.4, and must produce a signed written report. A verbal "we were about 3 ACH50" at final is not a report.
R401.3 — Permanent certificate: who, where, and what it must not cover
R401.3 requires a permanent certificate completed by the builder or other approved party and posted on a wall in the space where the furnace is located, a utility room, or an approved location inside the building. That is an interior, durable posting — not a permit card in the front window, not a PDF in the cloud, and not a page in the homeowner's closing packet that never gets mounted.
Panel rule (the Exam 79 field trap). Where located on an electrical panel, the certificate shall not cover or obstruct the visibility of the circuit directory label, the service disconnect label, or other required labels. A certificate taped over the panel directory fails R401.3 even if every energy number on the sheet is perfect. Move it to an adjacent wall in the furnace space, the utility-room wall, or another approved interior location. If the only available panel face is used, the certificate must sit where those electrical labels remain fully visible.
What the certificate must indicate (2021 R401.3 list)
The certificate shall indicate the following:
- The predominant R-values of insulation installed in or on ceilings, roofs, walls, foundation components such as slabs, basement walls, crawl space walls and floors, and ducts outside conditioned spaces.
- U-factors of fenestration and the SHGC of fenestration. Where there is more than one value for any component of the building envelope, the certificate shall indicate both the value covering the largest area and the area-weighted average value if available.
- The results from any required duct system and building envelope air leakage testing performed on the building.
- The types, sizes, and efficiencies of heating, cooling, and service water-heating equipment. Where a gas-fired unvented room heater, electric furnace, or baseboard electric heater is installed, the certificate shall indicate "gas-fired unvented room heater," "electric furnace," or "baseboard electric heater," as appropriate. An efficiency shall not be indicated for gas-fired unvented room heaters, electric furnaces, and electric baseboard heaters.
- Where on-site photovoltaic panel systems have been installed, the array capacity, inverter efficiency, panel tilt, and orientation shall be noted.
- For buildings where an Energy Rating Index score is determined in accordance with R406, the ERI score both with and without any on-site generation shall be listed.
- The code edition under which the structure was permitted and the compliance path used.
Item 7 is easy to skip and it is required on every 2021 certificate, including a simple prescriptive house with no PV and no ERI. Write 2021 IECC (or the edition actually permitted) and the path: R401.2.1 prescriptive, R401.2.2 simulated performance, R401.2.3 ERI, or R401.2.4 tropical. R401.2.5 additional efficiency is part of how that path was completed; the certificate still has to name the edition and path so a future inspector, appraiser, or energy rater is not guessing.
Items 5 and 6 are conditional. No PV means no array/inverter/tilt/orientation block is required. No R406 means no pair of ERI scores is required. Do not invent an ERI of 54 on a prescriptive certificate. Do not omit tilt and orientation when PV was installed.
Item 4's efficiency ban is another classic miss. A certificate that lists an electric furnace as "98% AFUE" or an electric baseboard as "100% efficient" is noncompliant. Name the equipment. Do not list an efficiency for those three product types. A gas furnace, heat pump, or water heater that is not in that banned trio still gets type, size, and efficiency.
Certificate checklist (use at final)
- Posted on a wall in furnace space, utility room, or approved interior location.
- If on the electrical panel: circuit directory, service disconnect, and other required labels remain fully visible.
- Predominant R-values for ceilings/roofs, walls, foundation assemblies, and ducts outside conditioned space.
- Fenestration U and SHGC: largest-area value and area-weighted average if available.
- Duct leakage and envelope leakage test results when those tests were required.
- HVAC and DHW type, size, efficiency — with the no-efficiency rule for unvented gas room heaters, electric furnaces, and electric baseboard.
- PV capacity, inverter efficiency, tilt, orientation — if PV is installed.
- ERI with and without on-site generation — if R406 was used.
- Code edition and compliance path.
Field scenario — certificate taped over the directory. At final in a 5A Morris County, New Jersey house, the builder has taped the R401.3 certificate across the entire front of the service panel so the circuit directory is unreadable. Lighting is high-efficacy, blower-door and duct reports are in the file, and the R-values are correct. The energy certificate location still fails R401.3. Have it moved to the furnace-room wall (or another approved interior wall) or repositioned on the panel so the directory and disconnect labels are visible, then reinspect. Do not trade electrical safety labels for energy documentation.
Closing the loop from Chapter 2 into Chapter 3
By the time the certificate is posted, the project should already have a defensible climate zone (Section 2.1), identifiable materials (Section 2.2), and a documented inspection trail (this section). The next chapter teaches which compliance path that certificate must name and how additional-efficiency and Total UA documentation attach to the same permit file. Wrong zone, unlabeled windows, or a missing certificate will make every later path discussion academic.
At final inspection the builder has taped the R401.3 permanent energy certificate over the entire face of the electrical panel so the circuit directory cannot be read. The listed R-values and test results on the sheet are correct. What is the R401.3 result?
A dwelling is heated only by an electric furnace. The R401.3 certificate lists 'electric furnace, 98% AFUE.' Which correction matches R401.3 item 4?
A prescriptive R401.2.1 house has no on-site PV and was not scored under R406. Which R401.3 item is still required on the permanent certificate?
Per R105.2.1, inspections associated with footings and foundations shall verify which energy items?