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  May 2000

A Report from the President
(from Direct Connection newsletter, Volume 3, Issue 1, 2000)

Over the past year, NCARB has enjoyed a number of positive events: the Practice Analysis, which will become the basis for the next test specification for the Architect Registration Examination, is underway; the Cooperation Agreement with China has taken another step toward mutual recognition; the Council's financial picture is brighter; and, the increase in candidates taking the computerized ARE is positive. However, there is an issue at hand that is of great concern to NCARB.

In late 1999, the formal abandonment by interior designers of their 1988 Agreement with the AIA to seek only "title acts" coupled with a well-funded lobbying effort to create "practice acts" brought the question of how the public will be protected under such circumstances to the forefront of discussion with NCARB's Board of Directors.

These "practice acts" advocated by the interior design lobby attempt to divide a building, and thus the practice of architecture, into two parts: the outside and the inside. Where possible, they seek to limit what an architect can do on the inside. Interior designers are claiming to have specialized knowledge that should allow them to practice just a little bit of architecture without a comprehensive knowledge of building systems or the need to meet the rigid standards required of an architect. In the naive belief that the structure is the only life-safety system they might encounter, interior designers include only "non-structural" components of a building in their definition of interior design. But where does the inside and outside of a building begin and end? What is "structural" and what is not? In the 21st century, the "interior" of the simplest building is a complex mechanism that requires knowledge of more than color and texture to comprehensively design and coordinate its life-safety systems. If their attempt is successful, and untrained persons are allowed to take on tasks traditionally performed by registered architects, it will have a profound effect on public safety, the profession of architecture and the construction industry. The following serves as background for NCARB's developing position on the subject.

Who are "interior designers?"
In 1988 there were about 200,000 persons engaged in interior decorating ranging from those who worked in a furniture store to those working in architectural offices and calling themselves "interior" designers. At that time, the latter were working under the supervision of an architect who maintained the comprehensive project overview and dealt with issues affecting public safety. It is this group that now wants to claim "interiors" as their own. But to add to their numbers in hope of gaining that right, many are willing to accept a substantial majority of the 200,000 persons who, only a decade ago were clearly "decorators," as equally qualified.

Are there significant differences between the qualifications for licensing of architects and those for interior designers?
Yes. Most states require a minimum NAAB-accredited five-year degree and three years of a structured internship before allowing a candidate to sit for the 36-hour Architect Registration Examination which is entirely directed at health, safety and welfare issues.

Of the 21 states that license interior designers, most require only two years of post-high school education, have no requirement for structured training, and allow licensure after taking a 12-hour examination, less than a third of which is even claimed to cover life-safety issues.

Interior designers say they want to raise the standards for licensure so their standards are comparable to architects; shouldn't we encourage that?
No one would oppose raising the standards of any occupation, but interior designers don't need legislation to do that. For more than a decade they have talked about raising their standards, but have done little else. And they cannot. The great majority of their "practitioners" are simply decorators who consider rigorous standards excessive and beyond their grasp. In our view, those engaged in decorating should give up the quest for licensure, and those wanting to be involved in "interior architecture" should meet our education, training, and examination standards and become licensed as architects.

But isn't interior design a distinct profession, requiring separate and distinct education and training?
No. But to understand the question requires some understanding of the diversity of practice that is conducted under the umbrella "interior design." Decorating is a distinct occupation, but, while bad taste might be offensive, there is no evidence that anyone has been killed by a bad color scheme. So that occupation requires no licensure to protect the public. A 30,000 square foot tenant build-out, on the other hand requires a broad range of architectural skills, including knowledge of structural, mechanical, and electrical design to coordinate and integrate those components into a comprehensive working whole that incorporates all the elements of life safety. Architects are educated, trained and examined for those skills. Interior designers are not.

If interior design isn't a distinct profession, what is it?
If interior design is anything, it is a sub-specialty of architecture. And, like any sub-specialty, medicine for example where every specialist must first become an M.D., the would-be sub-specialist must master the specialty first, in this case architecture.

Isn't there a clear distinction between the inside and outside of a building? If so, where is it?
Answering a question with a question is poor form, but even so, what is the distinction? Common sense suggests that "inside" is everything that is not "outside." If, as interior designers would have it, an architect is to design the outside and an "interior designer" the inside, shouldn't interior designers be educated, trained and tested on everything inside: stairs, elevators, structural systems, demising walls, floor-to-floor fire separations, heating, cooling, energy conservation, air distribution, lighting, electrical power systems, fire protection, security, smoke control, and plumbing? And if they were, wouldn't they be architects?

Sure, but proposed "interior design" licensing laws exclude electrical, mechanical and structural systems from the scope of "interior design." Isn't that adequate protection of the public?
No. "Interior designers" say they will call on knowledgeable consultants to supplement their limited knowledge. But that begs the question. How will an "interior designer" who knows nothing about post-tensioned slabs, know that putting an electrical outlet in the wrong place could get the electrician who drilled the slab, killed? Or that moving a "non-structural" wall could violate the integrity of a smoke barrier and leave the occupants vulnerable to death from smoke inhalation? Clearly, if "interior" designers don't want to learn about an inherent part of construction, how will they know when they have undone that part? Simply put, they cannot, and therein lies the danger to the public.

What effect does "grandfathering" have on "interior design"?
A devastating and detrimental effect. To satisfy decorators who make up the majority of the interior decorating and furnishing industry and are affected by the proposed laws, interior designers always include a generous "grandfather" clause in their proposed acts. The AIA estimates that individuals licensed without taking any examination comprise 80 percent of the license holders in California, 83 percent in Minnesota, and 67 percent of the license holders in Connecticut. And with their equally generous reciprocity provisions, those same unqualified persons can be licensed in other states.

Who is funding the lobbying for these proposed acts?
We don't yet know. However, they have put a lot of money into the effort. In a recent panel discussion, representatives of the interior design industry admitted that they have spent more than $5,000,000 in recent years "fighting architects" to obtain licensing.

If interior designers are denied licensing, won't they lose their livelihood?
No. Most large architectural firms have interiors departments employing both architects and interior designers, in which case the architect provides a comprehensive overview of all the construction disciplines and takes responsible control of the exterior and interior work. Many independent interior designers offer their services to architectural firms as specialized consultants where, again, the architect takes responsible control. No one suggests these arrangements be changed; no interior design licensing is required in either case. It is when an interior designer attempts to design an "interior" without an architect in responsible control that a problem arises, because they cannot get a building permit for the work. That is the problem they want to solve, and they are willing to jeopardize the public to solve their problem.

These are some of the issues that I expect will be debated in June during NCARB's 2000 Annual Meeting in Chicago. At that time the NCARB Board of Directors will propose a resolution for Member Board action which is expected to establish a clear and unambiguous policy on the question.

Why, as NCARB President, have you not encouraged discussion with representatives of the NCIDQ?
Because we do not speak a common language or share a common objective. The NCARB mission is to "safeguard the health, safety and welfare of the public"; the NCIDQ mission is to "increase interior designers' knowledge and expertise regarding issues affecting the public health, safety and welfare." NCARB "safeguards"; NCIDQ "increases knowledge." NCARB serves the public; NCIDQ serves interior designers.

NCARB's funding comes solely from NCARB services and Member Board dues. We do not rely on manufacturers, suppliers, professional societies, or others in the construction industry for our funding. We are independent. And when the public's interest is in conflict with the architect's interest, NCARB has a long history of protecting the public interest.

On the other hand, NCIDQ is funded and run by organizations like the ASID whose mission is to serve interior designers. However well-meaning the leaders of NCIDQ may be, at the end of the day, they bow to the will of the furniture manufacturers and finish suppliers, because to do otherwise would put them out of business.

And finally, as the president of an organization that has spent 80 years and millions of dollars developing a system of education, training, and examination designed solely to protect the public, I do not want to have our name and reputation co-opted by those who hold views that are contrary to the public interest.

Joseph P. Giattina, Jr., FAIA
President, NCARB