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CROSS Safety Report

Production of as-constructed drawings

Report ID: 1056 Published: 14 October 2022 Region: CROSS-AUS


The reporter is concerned about who should be responsible for producing accurate “as-constructed” drawings.  The reporter’s experience is that the as-constructed drawings are typically likely to be incomplete and contain errors. If the as-constructed drawings do not accurately record the works as constructed, there could be serious consequences for any future building works, including where such works rely on the accuracy of the drawings.

Key Learning Outcomes

For clients, building owners, and managers:

  • Include the submission of as-constructed drawings as a contractual obligation and define the parties responsible for their production and verification as an as-constructed record
  • Building owners and managers should ensure that as-constructed drawings are retained for future purposes

For civil and structural design engineers:

  • Where production of as-constructed drawings is your responsibility, maintain comprehensive records of changes carried out during the works in order to facilitate their production
  • Issue changes to design by way of the working drawings. In situations where last minute changes are required on-site, amend and reissue the working drawings within a predetermined timeframe

For contractors:

  • Where production of as-constructed drawings is your responsibility, appoint an engineer to oversee the maintenance of comprehensive records of on-site changes and for the production of as-constructed drawings

For certifiers:

  • Withhold the issue of Certificates of Occupancy until satisfactory receipt of as-constructed drawings

For regulatory authorities:

  • Consider mandating the submission and retention of as-constructed drawings as a standard building works requirement

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Based on their experience of working on projects using a Design & Construct form of contract, a reporter is concerned about responsibility for producing accurate “as-constructed” drawings.

The reporter’s experience is that the onus is placed on the consultant to produce the as-constructed drawings and to pass these to the client. However, these are likely to be incomplete and contain errors if they have not been produced or considered by the contractor who actually built the project.

The reporter believes that there are inherent safety risks with this approach if the as-constructed drawings are not an accurate record of the works as actually constructed. For example, there could be serious consequences for any future building works that rely on the accuracy of these drawings.

It is the reporter’s opinion that a number of issues may have contributed to this situation including a lack of professionalism in the industry (particularly when using Design & Construct forms of contract) and a lack of mandatory enforcement by regulatory and other governing bodies.

The reporter proposes that it should be mandatory for accurate as-constructed drawings to be produced for Class 2 - 9 structures by the contractor. In addition, the reporter proposes a requirement that the contractor signs the drawings to signify that the drawings are a true and accurate record of the works as-constructed.

Expert Panel Comments

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The question of as-constructed drawings is a serious problem in the industry. Whilst the submission of accurate as-constructed drawings may be contractually mandated, this is often not enforced.

Reliable as-constructed drawings are extremely important so that all buildings can be responsibly and safely managed, renovated and demolished.  Particularly in New Zealand, the lack of accurate "As Builts" hinders the seismic assessment of existing structures. They are also imperative in the burgeoning area of forensic structural engineering, where practitioners spend their working lives examining defects in structural members and determining the safety or otherwise of the building or structure.

Typical risks associated with as-constructed drawings include:

  • non-recording of changes made to the design during construction;
  • non-recording of late design changes on the drawings, typically when such changes have been recorded in the form of sketches and site instructions;
  • human factor failures including pressures to comply with schedule and cost, affecting adequate recording of as-constructed details or their quality and clarity; and
  • as-constructed drawing control may not be exercised by the builder if the construction is non-compliant. i.e., there is a conflict of interest.

Poor quality as-constructed drawings

One of the drivers of poor quality as-constructed drawings is that they are typically produced after practical completion when many of the personnel with first-hand knowledge of changes have left the project. 

The designer may be cut off from the construction process and this raises the question as to who certifies the as-constructed drawings as being a true record of the construction. By not being party to the site quality programme and physically verifying that construction is following the design intent, the designer cannot know if the issued for construction (IFC) drawings are suitable for use as the as-constructed drawings. The preferred contractual arrangement would be for the designer to be engaged during construction to inspect regularly, or as a minimum at distinct stages, to check on quality on site and to ensure changes are "red-lined" on the construction drawings. Those drawings could then be used as the basis for production of the as-constructed records.

Responsibility for as-constructed drawings

For Design and Construct projects, the responsibility for the production of as-constructed drawings should rest with the Contractor, as suggested by the reporter. With this form of contract, the Contractor has assumed responsibility for the design and the Contractor’s Engineer is best positioned to produce the drawings.

Where required by legislation, Building Certifiers should be insisting on complete as-constructed drawings before Certificates of Occupancy are issued. Where the Certifier is engaged by the Contractor or Developer, pressure is often exerted on them to issue Certificates of Occupancy prior to receiving such drawings. Such pressures are difficult to counter, exposing a weakness in the private certification process.

As the use of BIM becomes more commonplace, this should make the process of production of as-constructed drawings easier; however, the responsibility for the upkeep of the BIM model still needs to be defined and apportioned.

Beyond the mandatory production of as-constructed drawings, mandatory submission and retention of as-constructed documentation is equally as important. Experience indicates that as assets are bought and sold or transferred, and/or asset managers come and go, the as-constructed drawings are more likely to be misplaced. It is uncertain how this could be ensured without the involvement of approval authorities (e.g. Councils) acting as a centralised repository.

The panel notes that whilst it is good policy for updated shop drawings to be retained and form part of the documentation for the building, these should not be used as a substitute for formal as-constructed drawings.

Reports, Guidance, and Legislation

The responsibility for the production and retention of as-constructed documentation in Australia was one of the issues raised in the Shergold Weir Building Confidence Report (BCR), which noted that:

'A full set of final documents for a Commercial building which includes all relevant documents for the ongoing management of the building is not usually collated and passed on to the owner or subsequent purchaser. This makes it difficult for owners to verify how decisions were made and to adequately ensure that safety systems are properly maintained over the life of the building.'

Recommendation 20 of the BCR states:

'That each jurisdiction requires that there be a comprehensive building manual for Commercial buildings that should be lodged with the building owners and made available to successive purchasers of the buildings.'

With regard to record keeping, the BCR notes with respect to Recommendation 12 that:

'Unfortunately, despite requirements for record creation and keeping, key information is not readily accessible or auditable.'

Recommendation 12 states:

'That each jurisdiction establishes a building information database that provides a centralised source of building design and construction documentation.'

In response to the BCR, the Australian Building Codes Board (ABCB) Implementation Team has produced a series of guidance documents for consideration by State and Territory Governments, including: Building Manuals – Model guidance on BCR recommendation 20 (Guidance Document). This is a comprehensive document and includes 6 Principles for Building Manuals.

Principle 2 is titled "Responsibility for compiling building manual information". It states that:

'Building manual information is compiled and checked by the statutory building surveyor as part of the building approval process prior to issuing an occupancy approval.'

With respect to Principle 2, the Guidance Document recommends the passing of a legislative provision to the following effect:

'The building approval applicant must provide all required building manual information to the statutory building surveyor prior to the application for an occupancy approval.'

(Note: in the proposed legislative provision, the building approval applicant would be the individual or entity, such as the building owner or an agent of the owner, who applies for the building approval.)

In the comments to Principle 2, the Guidance Document states that: 

'On projects involving complex documentation, the building approval applicant may appoint the lead designer, project manager or builder to take on the role of coordinating or preparing building manual information documents for submission to the statutory building surveyor.

Ultimately, the practicalities of how the building manual information will be compiled for checking by the statutory building surveyor will depend on contractual obligations between parties and on digital document retention and sharing practices.'

The Design and Building Practitioners Act 2020 (NSW) (the Act) has brought about a raft of changes including requirements regarding the documentation of structures. For further details of the Act, refer to the NSW Fair Trading website Design practitioners' obligations.


In conclusion, it is recommended that occupancy of the building or the use of the structure should not be permitted until the as-constructed drawings have been submitted and accepted by the appropriate building or controlling authority. On large projects, a requirement for the progressive hand-over of as-constructed drawings, linked to progress payments, could go some way to overcoming the problem identified by the reporter. Further, it may be that independent quality assurance including recording of the as-constructed works could be contractually required, especially for high-risk structures.

Note: As noted in the BCR this is an area of practice that needs to be addressed and there appears to be a range of views as to who should be responsible for the production of a reliable set of as-constructed drawings. Accordingly, CROSS-AUS encourages you to provide feedback on your experience on this matter.

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