There is a short list on the cover sheet of most commercial permit sets. It usually sits under the general notes, and it is often the last thing anyone re-reads before an issue goes out. It names the parts of the building that are not in the drawings yet.
That list is the deferred submittal list, and it is one of the few places in a set where absence is the correct condition rather than an error. A permit set carries other documented absences: work marked not in contract, work by others, a future phase, scope carried by an allowance. What separates this one is that the absence has to be licensed by the building official in advance, and that it stays attached to the registered design professional in responsible charge afterward.
Most QC checks ask whether what is drawn is right. This one asks whether the right things are missing, whether someone with authority agreed they could be missing, and whether the set accounts for what has not been drawn. Those are three different questions, and a checklist built to look for drawings will not ask any of them.
The code language behind that list is four sentences long. That brevity is misleading. The four sentences settle very little, and the documents that settle the rest are local, are not in the code, and disagree with each other.
What the four sentences actually say
The provision is Section 107.3.4.1, and it sits under Section 107.3.4. The Washington Association of Building Officials and the Structural Engineers Association of Washington reproduce it in full in their joint white paper 6b-2023, issued March 2023 against the 2018 IBC, and it runs to four sentences. The same paper reproduces the Chapter 2 definition: those portions of the design that are not submitted at the time of the application and that are to be submitted to the building official within a specified period.
The section imposes four obligations, and it is worth separating them because they land on different people at different times:
First, deferring anything requires the prior approval of the building official. Deferral is a permission, not an election. Second, the registered design professional in responsible charge lists the deferred items on the construction documents so the building official can review the list. Third, when the deferred documents are produced, they go to the registered design professional first, who reviews them and forwards them to the building official with a notation that they have been found to be in general conformance to the design of the building. Fourth, none of it may be installed until the building official approves it.
Read that sequence again and notice what it does not contain. It does not say what may be deferred. It does not say how many items. It does not say when the deferred documents are due. It does not say what happens if they are late. It does not say what a general conformance review consists of. Every one of those is left to the jurisdiction, and every one of them is where a schedule gets damaged.
The Washington paper fills two of those gaps by recommendation rather than by code, and both are worth having. On what may be deferred, it says the primary structural frame of a building, or any portion of it, should not be permitted to be a deferred submittal, and that mechanical, electrical, plumbing and fire protection permits should not be listed as deferred submittals either. It also says, flatly, that deferred submittals are not a method for submitting design revisions or change orders.
On that first question the four jurisdiction policies are not silent, and they are not consistent either. Houston answers it at length. Citrus Heights and Redding each answer part of it. St. George prints four blank lines and no rule about what may go on them. Redding makes the separate-permit point itself, telling applicants that deferred submittals do not require a separate permit and should not be confused with the separate permits a rooftop solar, fire sprinkler or fire alarm system needs.
The second gap is a harder one. On what a general conformance review consists of, the four say nothing. Houston's form and St. George's agreement do not use the phrase at all. Redding and Citrus Heights both use it in their own operative instructions, not only inside the code text they reprint, and both use it the way the code does, as the thing the notation has to assert. Neither says how a reviewer is supposed to arrive at it. To fill that one a reader has to go outside all four, and what fills it here is the Washington paper again, which says that for structural items general conformance applies to both the loads imposed by the deferred component and its deformation compatibility with the primary building structure. That is an association recommendation, a different kind of authority, and worth naming as such.
The California school construction interpretation read for this piece answers more of this than any of the four do, though not for buildings like these. Its glossary defines a related term, Statement of General Conformance, and that entry describes the notation rather than the review behind it. Its Appendix B, the example statement for the structural engineer of record on a deferred submittal drawing set, does describe the review: the drawings have been examined for design intent against the applicable code and the project specifications prepared by the signer, and for coordination with the signer's own drawings and specifications. That is a direct answer to the question the four leave open, and it applies to California school projects under the Education Code rather than to ordinary commercial permitting.
Four jurisdictions, four rulebooks
The following four publish their deferred submittal policy as a document anyone can open. They do not even restate the provision the same way. Redding and Citrus Heights reproduce it word for word, both of them from the California Building Code. St. George paraphrases it. Houston's form quotes no code text at all and does not print the section number anywhere on its two pages. What the four require of an architect diverges considerably further than that.
Houston enumerates, and puts a clock on it
Houston pre-enumerates. Its Building Code Enforcement form CE-1086, revised May 2025, is a checklist of twelve named categories with a box beside each: precast construction shop drawings, where the architect or engineer submitted plans identify all fire-resistance rated designs keyed to appropriate building elements; prefab metal building plans, non-fire-rated construction only; prefab access floor systems; prefab curtain wall systems not part of a fire-rated assembly; interior retractable bleachers; canopies and/or awnings; spires, non-fire-rated construction only; prefab steel stairs; prefab steel storage racks with no high-pile storage; prefab wood truss details and layout; Texas PE sealed emergency responder communications coverage plans; and helical pile foundation systems. Those are the form's own qualifiers, normalized only for prose, because the qualifiers decide whether an item is on the list at all. Two blank lines marked Other sit at the bottom, so the list is a strong default rather than a closed set. Checking a box is still a request, not a grant, and the form is titled as one. What the enumeration changes is that a project argues from twelve categories the city already recognizes rather than from an open question.
Several of those categories carry an asterisk, and the asterisk means the work requires a City of Houston Approved Fabricator. That is a procurement constraint arriving through a plan review form. If the deferred item is precast, a prefabricated metal building, canopies, prefabricated steel stairs, or wood trusses, the fabricator has to be on the city's list.
The form also sets a deadline the code does not: all deferred plans are to be submitted no later than 90 days from the original plan approval, with emergency responder communications coverage plans excepted. It tells you what the list costs if it is not cleared. Restrictive holds go into the permit system, notes identifying the deferred items print on the building permit itself, and final inspection cannot be scheduled, the certificate of occupancy will not issue, and final release of utilities will not be granted until every deferred item is reviewed, inspected and approved.
One more Houston requirement is aimed squarely at the engineer of record. The engineer must include the minimum required design and performance specifications in the structural plans, and the manufacturer's title block or approval stamp on the shop drawing sheets must be marked for construction and sealed on the structural plans by the engineer of record. The owner and the contractor both sign the form.
Almost none of Houston's deferral rules are in Houston's code
This part is worth stating plainly, because it changes how you would go looking for the answer. Houston adopted the 2021 IBC with amendments under Ordinance 2023-907, passed October 25, 2023 and effective January 1, 2024. The city publishes those amendments as a single document of 145 pages.
Section 107.3.4 does not appear in it. Neither does 107.3. The string occurs zero times across all 145 pages, and the word deferred occurs exactly twice, both inside a single plan review fee provision at Section 118.2.8, which says a fee based on the minimum permit fee is charged where deferred plans are submitted. The document does amend Section 107, once, at 107.5, Retention of construction documents. One qualification on those counts, because they are the load-bearing numbers here: the search is over the document's text. Three of the 145 pages carry a drawing instead. All three are Chapter 31 construction details: a driveway layout sheet and two parking layout sheets, both of the parking sheets marked private property standards. A deferral rule does not live on a parking dimension table.
So Houston adopts the model deferred submittal provision unamended. Be precise about what that means. The fee line is a Houston-specific deferral rule and it is in the code. What is not in the code is any rule about what may be deferred, on what schedule, or on what conditions, so an architect reading the amendments for those would find a fee and nothing else. The enumerated categories, the 90-day clock, the approved fabricator requirement and the certificate of occupancy hold are all real, and not one of them is tied to a deferred submittal anywhere in the adopted amendments. Two of those terms do appear in the amendments on their own. Approved fabricator has its own fee section and its own definition, and certificate of occupancy turns up on more than a dozen lines. Neither is connected to a deferral. The only thing the amendments say about deferred plans is that a fee applies. They are on a form.
Redding requires the effects of the missing work to already be designed
The City of Redding, California handles this through a building official's interpretation of CBC Section 107.3.4.1, issued under the authority of CBC 104.1 and digitally signed by Jeremy Pagan, PE, CBO, Director and Building Official, on February 28, 2025.
Redding requires the deferral to be requested before permit issuance, and the granted items to be listed on a Statement of Facts form signed by the owner, the contractor, and the Building Division before the permit issues. The items must be clearly listed on the title or cover sheet of the approved plans, and their design criteria must be stated on those plans.
Then comes the requirement the rest of this piece keeps returning to. The impacts of the deferred items on the entire building must be included in the original design. The interpretation gives examples: the size of the elevator shaft, the complete load path, the point load from beams, the fire sprinkler water demand.
Redding also charges a time based fee for the review, routes deferred submittals on outside-reviewed projects back through the same outside plan review agency, and states that a stop work notice goes on any project where deferred items are being installed before approval. The Statement of Facts adds a term with teeth: if the deferred items change the building's design after work has commenced, the permit applicant assumes full responsibility and all risk of loss, and the building must conform to the final approved plans regardless of the stage of completion.
Citrus Heights decides at first review, and holds the final inspection
The City of Citrus Heights, California policy CHB1811, revision 06/23, signed by Chief Building Official Joseph Cuffe, puts the decision at a specific moment in the review. The architect or engineer of record lists the desired deferred items on the plans, and during the first round of plan review the plans examiner verifies the requirement and determines whether the listed items may in fact be deferred. Approved items get a Deferred Submittal stamp on the plans, and a note goes into the permit system that prevents final inspections from being scheduled.
Citrus Heights wants two sets of plans and calculations delivered to the registered design professional in responsible charge, who must indicate in writing that the documents are in general conformance. Deferred submittals are then intaken as a plan change to the original permit, with a $75 processing fee at submittal and plan review fees billed on the hours the plans examiner spends, or at the consultant's hourly rate if the review is outsourced. The policy also notes that deferred submittals, though not called out in the Residential Code, may be used on residential projects, and that residential trusses may be forwarded to the Senior Building Inspector in the field.
St. George uses an agreement the architect personally signs
The City of St. George, Utah uses a Deferred Submittal Agreement, form revised 9/2023, referenced to the 2021 IBC. It requires the items to be listed on the approved plans in a conspicuous location, and it requires the engineer or architect in responsible charge to attach a letter to the submittal stating that the deferred item is in conformance with the design of the structure. A letter, not a stamp.
The form has four numbered lines for deferred items. It closes with a declaration signed by the design professional in responsible charge personally, agreeing to comply with the terms of the agreement. The form also prints its own restatement of the parent code section, under the label IBC 107.3.4: the Engineer or Architect in responsible charge is accountable for the review and coordination of all submittal documents designed by others and to ensure they are compatible with the design of the building. That is St. George's wording, not a reproduction. Set it beside the version San Luis Obispo County reprints from the California Building Code, quoted further down, and the two differ in seven places, most of them small. One is not small. The California text covers submittal documents prepared by others, including phased and deferred submittal items. St. George's covers all submittal documents designed by others, and names neither. The clause that puts deferred items inside the duty is in one and not in the other.
The notation is 107.3.4.1. The duty is 107.3.4.
The instinct is to treat a general conformance notation as the lighter option. It sounds smaller than approval, and in scope it is.
Whether it is smaller in responsibility is a separate question, and the answer is not in 107.3.4.1 at all. It is one level up, in 107.3.4, the parent section the deferral provision sits under. San Luis Obispo County's form BLD-2033, revised September 15, 2023, prints that section and cites it: the registered design professional in responsible charge shall be responsible for reviewing and coordinating submittal documents prepared by others, including phased and deferred submittal items, for compatibility with the design of the building.
Read what that assigns. Not review alone. Coordination. And not of the deferred document in isolation, but of its compatibility with the design of the building.
Be careful how far that carries. BLD-2033 is quoting the 2022 California Building Code, and it is the only verbatim reproduction of 107.3.4 read for this piece. St. George's agreement prints its own restatement under the label IBC 107.3.4, and it does not name deferred submittal items where the California text does. Houston adopts the 2021 IBC and never amends 107.3, so the section is in force there, but nothing read here reproduces its wording. What is established is that San Luis Obispo County's reprint of the California code carries this duty in these words, and that a Utah city understands the same numbered section to assign something close to it. What is not established is the published IBC wording of the parent section.
Scoped that way, the structure still holds. Section 107.3.4.1 describes a notation. Section 107.3.4 describes what the person making that notation is responsible for. An office that reads the notation as the measure of the obligation is reading the wrong one of the two.
Construction lawyers writing about the parallel contractual review make the same point from the other direction, and both of them work across two AIA documents rather than one, which matters because the two run to different parties. Kenneth Slavens, writing for IRMI in September 2024, describes the architect's submittal review as limited to checking for agreement with the information in the contract documents and the design concept, explicitly excluding responsibility for the accuracy and completeness of dimensions and quantities, installation instructions, equipment performance, and construction means, methods, techniques, sequences or procedures, and he says plainly that the architect's obligations sit in the General Conditions and in AIA Document B101-2017, the owner-architect agreement. Robert Derner of Allensworth, writing in April 2025, quotes the limiting language from B101-2017 and then makes the warning explicit: the disclaimers in a submittal stamp help, but they are not bulletproof, and the design professional still has to perform a diligent review. He reaches for the Kansas City Hyatt Regency walkway collapse as the illustration, describing an engineer found to have acted with gross negligence in approving contractor submittals that stood at odds with his own design for the suspended walkway, without reviewing those submittals or performing calculations.
Here is the part that is rarely said out loud in a firm. Those are two different reviews of the same sheet.
The A201 submittal review runs from the architect to the contractor, it is contractual, and its standard is the design concept expressed in the contract documents. The IBC 107.3.4.1 general conformance notation runs from the registered design professional to the building official, it is statutory, and its standard is general conformance to the design of the building. Different reader, different authority, different consequence for being wrong. Many offices perform them as a single act with a single stamp, which works right up until the moment someone asks which of the two the stamp was.
What the absence still has to carry
The deferred item is absent from the set. Its effects are not permitted to be absent.
The elevator is a deferred submittal, and the shaft that receives it is not. The trusses are deferred, and the load path that carries them is not. The curtain wall is deferred, and the structural attachment and the fire rating of the assembly it sits in are not.
Two of the four policies state that outright, and it is worth being exact about which. Redding states it as a design requirement on the set: the impacts of the deferred items on the entire building must be included in the original design. Houston states it as a document requirement on the engineer of record: the minimum required design and performance specifications go in the structural plans. Same idea, one written as design and one as documentation. Citrus Heights and St. George say nothing equivalent, which does not mean their projects escape it, only that their published policies do not spell it out.
This is why the deferred submittal list is genuinely difficult to check, and why it tends to be checked badly. The verification is not whether a drawing is correct. It is whether there is a correctly shaped hole here, and whether the surrounding work assumes the right thing about what will fill it. A reviewer paging through sheets sees no drawing and no error. The error, when there is one, is a load path that stops, a shaft dimensioned for a different machine, a water demand figure that predates the sprinkler design, or a performance specification that was never written because the item was going to be someone else's problem.
Why the list decays
Three structural reasons, none of them about carelessness.
It is written early. The list takes shape in design development or early construction documents, when the question is which scopes will be carried by specialty contractors. That is a scope and fee decision. It is recorded as a note.
It lives on the cover sheet. The cover sheet is the sheet most likely to be treated as carried forward, and the deferred list sits in the same visual neighborhood as code data and general notes, which are exactly the blocks a reviewer's eye has been trained to skip because they rarely change.
It grows under pressure. Late in construction documents, moving an item to the deferred list is one of the few remaining ways to shed drafting scope without missing an issue date. Each addition changes who is coordinating that interface, and it also requires the building official's prior approval, which the schedule was not built to wait for.
What this actually means for a review pass
None of this argues for a longer checklist. It argues for a differently shaped one on this one item.
Confirm the list is where the local policy puts it, which is not the same requirement everywhere. Redding names a sheet, the title or cover sheet of the approved plans. St. George names no sheet and instead requires a conspicuous location on the approved plans. Those are different tests and a set can pass one while failing the other. Confirm the deferral was approved rather than announced, because prior approval is the code's first requirement and it is the one most often skipped. Confirm the design criteria or performance specifications for each deferred item appear in the set, which is a separate check from the list itself. Trace one interface per deferred item, the shaft, the load path, the attachment, the demand figure, and confirm the surrounding work is designed for something specific rather than for a placeholder. Know what form the notation has to take, because the four do not agree. Citrus Heights wants it in writing. St. George wants a letter attached to the submittal. Redding says notation and leaves the form open. Houston's form does not ask for a general conformance notation at all. It requires the engineer of record to review and approve every deferred item before the documents go in for plan review, and it has a separate sealing requirement whose wording leaves open exactly what gets sealed and on which sheet. Read that one off the form rather than off this sentence. Know the deadline, if the jurisdiction has one, and know what it holds. A certificate of occupancy hold and a final inspection hold are the same problem discovered at different costs.
And know that the local policy governs most of this. Of the checks in the paragraph above, the code text answers exactly one: that the deferral needs prior approval rather than an announcement. Which sheet the list goes on, what form the notation takes, the deadline and what a missed deadline holds are not in it.
What this piece cannot tell you
These four jurisdictions were not sampled at random. Each was selected because it publishes its deferred submittal policy where the public can read it, and that filter is biased in a predictable direction. A jurisdiction that writes its deferral process down is probably more procedurally settled than one that does not, so the real variation across all authorities having jurisdiction is probably wider than this, not narrower.
Two further jurisdictions were dropped. One was a URL numbered 30.52A.192 on Snohomish County, Washington's code publishing site. The other was a page under the building code path on Beaufort County, South Carolina's former web domain. Neither would return a page during research, at any point in the session. The counties are named from their domains, and Beaufort County's from the county's own published notice that the domain was its previous address, so even the names here come from somewhere other than the pages. What either page actually says is not claimed.
A note on the code text, because it changed during the research. The publisher's own hosted pages never returned the section text, so the base code was not read there. The Washington white paper reproduces IBC 107.3.4.1 and the Chapter 2 definition in full, against the 2018 edition, and its wording matches the verbatim California reproductions in Redding's and Citrus Heights' policies. Three documents from two states agreeing is what the four-sentence claim rests on. It is not the published code, and the Washington paper is keyed to the 2018 edition. Two of the four jurisdictions name an edition of their own, Houston and St. George, and both name the 2021 IBC. Redding cites the California Building Code latest edition without naming one, and Citrus Heights names none at all. So a change made after 2018 would not show up in the Washington reproduction, and two of the four documents would not tell you whether it applied to them.
The parent section, 107.3.4, is thinner. Only one document read for this piece reproduces it, San Luis Obispo County's form, and that is the California Building Code. St. George prints its own restatement under the IBC number, and Houston reproduces no code text at all. So the coordination duty is demonstrated in California and inferred elsewhere, and no claim is made here about how any of it was numbered in earlier editions. One source listed below does give an earlier number, and its entry says why that number was not adopted.
Several kinds of statement here are not quotations from a document. Four of them are worth separating, and they are the main ones rather than a closed set.
The first is practitioner observation. That the list tends to be checked badly, that it sits under the general notes and is the last thing anyone re-reads, that the cover sheet is the sheet most likely to be treated as carried forward, that many offices run the two reviews as a single act with a single stamp, that moving an item to the deferred list is one of the few remaining ways to shed drafting scope late, and that prior approval is the requirement most often skipped. Those are examples and not a complete list, and none of them comes from a document cited below. They come from looking at plan sets. They are the reason the piece is worth reading and they are also the part a reader should weigh differently from the code text and the four policies, which are sourced line by line.
The second is reading. The argument that 107.3.4.1 and 107.3.4 describe two different obligations, and that the contractual submittal review an architect performs for the contractor is not the same act as the statutory general conformance notation the design professional in responsible charge makes to the building official, is drawn from those sections and from the two construction lawyers cited below, but no document read here states it in those words. A reader who disagrees with the reading has the same sections in front of them.
The third is anything said about getting hold of the sources themselves: which ones opened, which ones did not, what happened when they were requested, and one search-result title reported below as a search-result title and nothing more. Three sources could not be read at all, the two county pages and the code publisher's own hosted text, and nothing here is a claim about what any of the three says. An earlier version of this section offered a single test for sorting every sentence into the first two kinds: if a statement is not about one of the documents cited below, it is observation. That test does not work, and saying why is more useful than quietly dropping it. It would call a description of an unopened page sourced, because the page is listed below. And it would call a proposition quoted through one of the cited lawyers an observation, because the AIA document that proposition comes from is not itself in the list. There is a fourth kind, and it does a great deal of the work here: statements derived from a document that was read, by searching it or by setting it beside another one. That a string occurs zero times in 145 pages, that a word occurs exactly twice, that one city's reprint of a section and another's restatement of it differ in seven places, that two cities use a phrase in their own operative text and not only in the code they reprint. Those are not quotations and not observations. They are checkable, and a reader with the same documents will get the same answers, which is the whole reason the URLs are printed. Named kinds and no test is the honest version, and the kinds are not a closed set either. Treat the four as where most of it sits.
One date is unresolved. The Redding interpretation's filename indicates February 2022 while the document's digital signature is dated February 28, 2025. The 2025 signature date is used here because it is inside the document. Which one reflects the original issue is not determinable from the file.
Code adoption also moves. Every jurisdiction named here is described as of its own document's stated date, and local amendments change. Confirm against the current local policy before relying on any of it.
A closing note
The deferred submittal list is small, it is stable across issues, and it reads like boilerplate. It is none of those things. It is a record of scope that has been moved off the architect's drawings and onto someone else's, approved in advance by the building official, and still attached to the registered design professional through a review whose narrowness does not reduce what it carries.
At Setmark we build software that reads construction document sets and checks them against a builder's or reviewer's own requirements. Setmark is not a licensed design professional, it does not replace a licensed review, and it does not replace the authority having jurisdiction. The building official approves the deferral, and the registered design professional in responsible charge signs the notation.