For all you federal architects, engineers, and contractors out there, did you know there has been a big change at the GSA that directly affects all of our work? The GSA rescinded the P100 (Facilities Standards for the Public Buildings Service) on February 24, 2025.
For those of you who have not used the P100, it established mandatory design standards and performance criteria for GSA-owned buildings and touched on multiple disciplines, including architecture, landscape architecture, structural and civil engineering, mechanical engineering, electrical engineering, fire protection, and physical security.
This applies to projects that:
“1. are in GSA-owned or lease-construction facilities, regardless of funding source, budget activity, or project contract value (e.g, design, construction, services, and study contracts);
AND
2. have less than 50% of construction activity completed as of January 21, 2025, as measured in dollar value.”
In lieu of this, they have issued “Interim Core Building Standards” Memorandum, which “lists laws, Executive Orders, codes, regulations, and standards for use by contracting officers, projects teams, and others involved with developing contract documents for design, construction, renovation, or maintenance projects.”
This Memorandum addresses most of the same disciplines but directs the users to baseline standards (ANSI, ASTM, etc.), the Code of Federal Regulations (CFR), uniform building codes developed by the International Code Council (ICC), executive orders, etc., many of which have been incorporated into the P100.
Of note is that the Physical Security Standards are essentially unchanged as the new document specifically includes:
Interagency Security Committee Standard: Risk Management Process
- GSA Facility Security Requirements for Explosive Devices Applicable to Facility Security Levels III & IV
- GSA Alternate Path Analysis and Design Guidelines for Progressive Collapse Resistance
- GSA Federal Courthouse Physical Security Best Practices Desk Guide 2023
- Interagency Security Committee Appendix C: Child Care Level of Protection Template (FOUO)
So, while the final requirements may not be completely different from those included in the P100, we expect some churn and uncertainty in current design/construction projects to which the new document applies and in the early phases of new projects as they get kicked off.
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