JBeaumont:

541490 Other Specialized Design Services

This industry comprises establishments primarily engaged in providing professional design services (except architectural, landscape architecture, engineering, interior, industrial, graphic, and computer system design).

Illustrative Examples:

Costume design services (except independent theatrical costume designers)
Jewelry design services
Fashion design services
Float design services
Shoe design services
Fur design services
Textile design services

If the other designers were including that in their business description. 

JBeaumont,

Actually, there are other building designers classified in architecture. It depends on how you describe the nature of your business. In the filing, describing the business to what one does.

As a matter of fact, it was Department of Licensing that classified the business to the NAICS code definition. It is also not an advertising of services. Business license and registration does is not a business advertisement nor does it mean the business is authorized to offer or perform architectural service per state law even though he business may very well be under the same NAICS classification.

NAICS definition is not subject to state law. It is not defined by state. It is a federal classification.

https://en.wikipedia.org/wiki/North_American_Industry_Classification_System#History

It is an international (North American) classification system. It's primarily administered and defined by the Federal agency. According to Federal law perspective, what I do is architectural services because they do not distinguish between licensed and unlicensed practice of architecture or anything of the sort. This is because under federal law, there is no architectural licensing, title, or practice laws. 

Other designers you maybe looking at maybe have described their business in such a way they couldn't discern what category to place it in. 

----------------------------------------------------------------------------------------------------------------------

RE:        Case 2013-04-0402-00ARC

Dear Rick Balkins:
 

We have reviewed the complaint against you. Based on information gathered during the review, we have determined you did not intentionally advertise architectural services. You have taken appropriate corrective action with the involved third parties. As a result, this case has been administratively closed.
 
If you have any questions concerning this case, please contact our office.
 
Sincerely,
Jerimiah Wedding
Management Analyst
Design, Funeral & Cemetery Boards
(360) 664-6652
 
Skip a Trip - Go online
www.dol.wa.gov

NAICS classification are classified according to the official NAICS classification. NAICS classification is not about individual state definition. You need to learn that state law doesn't apply to NAICS classification system.

We are getting a little bit off on a tangent don't you think.

I may have been investigated but I have never been fined for disciplinary action. I'm not looking at preparing plans and having them rubber stamped at the end. Some type of work may require more or less extensive supervision by a supervising architect of the work being prepared by persons being supervised. That is where we got off point. Would there be recordkeeping necessary for supervision and control, there should be.

Did you not know that I would be essentially bound to the code of conduct of a licensed architect if my business becomes a registered professional design firm with architect(s) as business partners (as as designated architects accordingly). 

JBeaumont, 

WHAT ADVERTISING ARE YOU REFERRING TO?

The NAICS classification and classification title has nothing to do with advertising.

Bendy Bendy isn't breaking breaking. JBeaumont, I'm sure you are a good guy and all but come on. 

midlander, 

I was somewhat surprised when I first read that. I think it might just be the undertaker.

When the investigator is also the investigator of the funeral & cemetery board than maybe you want to pay attention. Don't listen and they'll send the UNDERTAKER!

He's definitely in charge:

You know when you are at the end of your rope and it's over when:

Angie's List. 

JBeaumont, regarding that, they had administratively disregarded because NAICS classification is ASSIGNED by the Department of licensing and department of revenue based on description of services offered. I did not use the words architecture or architectural in the description. They in fact administratively disregarded it by the time I had received notice of the investigation. I contacted the person on the phone. The focus of my business isn't drafting. There is more to designing projects for clients than drafting a CAD drawing of a clients sketches. 

There is more to the service than the tangible deliverable. There are intangible deliverable of services that defines projects. Do you understand that? I hope. It is a very crucible part of what you do and even more important than technical drawings being prepared.

Jeremiah told me that part of the case which initially had two parts was administratively closed but the case file can't be closed completely until they further investigated the Angie's list which was the third party part. 

Technically, it isn't a third party when it comes to the NAICS code classification.

You need to understand that the NAICS classification for Architectural Services does not and is NOT subject to state licensing laws. They define architectural services more broadly which would include building design because the services and primary focus is the same. In my states, the plans I prepare are submitted to the building department. 

There is a lot of design-builders / furniture or cabinet or millwork designers in Washington. It is these other stuff that may have got them categorized in some of that misc. other design professional categories. When my business in the course of building design is primarily involved in "...planning and designing residential, institutional, leisure, commercial, and industrial buildings and structures by applying knowledge of design, construction procedures, zoning regulations, building codes, and building materials", how can my business not fit into this category? 

To fit into the Other category:

541490 Other Specialized Design Services

This industry comprises establishments primarily engaged in providing professional design services (except architectural, landscape architecture, engineering, interior, industrial, graphic, and computer system design).

Illustrative Examples:

Costume design services (except independent theatrical costume designers)
Jewelry design services
Fashion design services
Float design services
Shoe design services
Fur design services
Textile design services


Cross-References. Establishments primarily engaged in-- 

• Providing architectural design services--are classified in Industry 541310, Architectural Services;
• Providing landscape architecture design services--are classified in Industry 541320, Landscape Architectural Services;
• Providing engineering design services--are classified in Industry 541330, Engineering Services;
• Providing interior design services--are classified in Industry 541410, Interior Design Services;
• Providing industrial design services--are classified in Industry 541420, Industrial Design Services;
• Providing graphic design services--are classified in Industry 541430, Graphic Design Services;
• Providing computer systems design services--are classified in U.S. Industry 541512, Computer Systems Design Services; and
• Operating as independent theatrical designers--are classified in Industry 711510, Independent Artists, Writers, and Performers.

"This industry comprises establishments primarily engaged in providing professional design services (except architectural, landscape architecture, engineering, interior, industrial, graphic, and computer system design)." To fit into this category, my business must not be primarily engaged in "....planning and designing residential, institutional, leisure, commercial, and industrial buildings and structures by applying knowledge of design, construction procedures, zoning regulations, building codes, and building materials". How is the work of building design not fall into planning and designing residential, (commercial in states like Oregon and Washington under the size rule), institutional (if the project fits into the exemption in Oregon & Washington), and other structures (such as farm structures) by applying the knowledge of design (Ding!), construction procedures (ding!), zoning regulation (Ding!), building codes (Ding!), and building materials (Ding!) ? Each and EVERY aspect there fits into building design and what my business is primarily engaged in.

Think? Designing and Planning. Projects don't necessarily have to be built. The service can be pre-design consulting, preliminary design, all the way to construction contract documentation. 

JBeaumont,

Diazoprints have that Ammonia fumes because of the Ammonia used in the developing stage. 

Blueprint (true blueprint... cyanotype) doesn't have that fumes. There might be a little faint fumes but nothing like Diazotype which needs mainly ammonia (or classic Windex) to process (develop) the image after the exposure time.

null pointer, 

No.

If you suggest someone to kill themselves, you have a serious psychological issue.

Ironically, cyanotype isn't that toxic as the chemicals used to make diazo emulsion is more toxic.

Potassium ferricyanide and ammonium iron(III) citrate. First, the cyanide is tightly bound to the iron (hence the ferri- in ferricyanide).

You wouldn't want to necessarily burn this stuff in high heat or something like that.

Most people face more severe health risks with ordinary household chemicals like chlorine bleach and ammonia (for example).

They aren't particularly toxic in their ordinary use and format. Sure, it wouldn't be suggested you drink this stuff.

Those are hardly the reason architects aren't using the old methods. 

Architects can choose for themselves how they want to deliver the deliverable in whatever medium they choose. There is no reason you have to explicitly use any one particular medium of deliverable. They are called choices. 

Architects were paid the same amount of percentage of construction cost that you guys charge today. They did it then. You say you need 75 sheets to design a house? Average sets are 15 sheets or less. Unless you do something elaborate. It was done back then with sets of 15+ sheets. They did it with paper and pencil. They had methods of efficiency to deliver services. 

When you try to be every profession under earth, sky and sea. You have a problem. In California, when state building codes were adopted in the 1920s, architects were still using cyanotype. They had to submit multiple sets. 

When some other entity is dictating that is not licensed to practice architecture is dictating how you practice as an architect, they are violating architectural licensing law by engaging in the practice of architecture without a license.

When it comes to public projects, fine. When it comes to private sector, it is a choice. A reason one may choose to use diazo and/or cyanotype is a choice and preference. With diazo, I can get pre-coated paper with the diazo emulsion already on them. I can hand draw or plot on paper or mylar the original master drawing and then use a halogen lamp for exposure (or the sun itself) and then I apply ammonia with a vaporizing spray bottle and with a hair dryer to heat the paper and dry out the paper quicker. If I had to apply the diazo emulsion on paper (if or when diazo coated paper becomes difficult to impossible to source) than I can do that like the cyanotype. I just don't have the drying wait time at the end of the development process. 

This time needed to coat the paper isn't necessarily a waste. It is a time one can take to study the drawings and make corrections. Especially, when we have CAD and can just plot out another mylar master copy with the correction if necessary.  When the emulsion and sensitizer is mixed, the emulsion has a shelf life of months (if stored properly) compared to years.

 Then I can apply the method to not only paper but cloth (with either diazo or cyanotype). 

That time preparing the paper is time you can be thinking about the design. Design thinking occurs in the mind not on the paper. Haven't you learn anything from Frank Lloyd Wright?

I could use the same diazo emulsion and sensitizer used in screenprinting and apply the mix to paper or cloth. Then store the coated sheets after coating is completed on a shelf that is covered and blocked of any light. 

A halogen lamp used by contractors plugged into a special outlet with a timer switch setup, ( http://www.homedepot.com/p/Intermatic-20-Amp-15-Minute-In-Wall-Auto-Off-Spring-Wound-Timer-FD15MWC/203954910?MERCH=REC-_-PIPHorizontal1_rr-_-204220300-_-203954910-_-N ) so one can set the timer on the lamp and then one can then take the exposed sheets to the developing station ( where the ammonia will be applied )

I don't know about you but this can be used regardless of our computerized changes. Why use this? On job sites, construction documents in physical form needs to be used. In addition, the real sheets can be identified from a xerox copy. Sure, the B.O. may or may not care about what medium you have them in but if you have a working professional relationship with them, they will be able to know the real McCoy copies from the architect from that of the client because clients making copies for other sites than they are authorized exposes the architect to liability. Most clients making counterfit are not going to go through the effort to make counterfit copies. It's like the U.S. dollar. The average client that does this does not have the time, resources or inclination to do this. They make cheap copies by taking an original B&W print and print copies of it at a local print shop.

The moment they do that with diazo prints or cyanotype, it would be easily identified because copying machines can't produce a proper copy. If the architect uses muslin cloth and they calendered it and starched it or otherwise, they just aren't going to make a duplicate that matches. 

Again, it comes down to choice. Your time in applying the exposure and sourcing 10% ammonia (can be done) and applying it in fine mist and hair dryer, it'll work just fine. 

You make efficiency somewhere and you time when you apply emulsion/sensitizer, exposure and the ammonia development around your day. Architects ran businesses even as big as your own and still had to do a great ordeal of business management. They did it then. Today's world isn't all that different. 

As a profession, it is our choice as to what medium we want to deliver the deliverables as. Using mylar or vellum originals and a final drawings. Remember, they aren't buying a commodity. They are buying a service.  How you deliver your service and what medium you put it on is NOT up to the client. IT IS YOUR PROFESSIONAL DECISION. Clients don't tell an attorney what make, brand, type of paper the attorney uses. It is none of their decision. When it comes to competing with other architects? The only competitor you are competing with is yourself. The other architects have their own design concept. So do you. There is no determination of how many floors, how many hours, how many this and that. You don't know. They don't know. You don't even know what you are going to make until a contract is signed and is awarded the project. Even then, you don't know. If I choose to provide a deliverable that is more sophisticated than bond paper that is plotted, it isn't any of the client's business. They have to pay for the service which includes the costs. The cost isn't that much to make a difference. The quality of design and service is more important so it doesn't matter. If I choose to do high quality work than it isn't going to piss off the client to use cyanotype or diazo. They get real blueprints or blueline prints. The quality work is charged more.... right? 

I can save more time in the long run by taking time to actually do design thinking and thinking about the drawing than running through 50 Million iterations in CAD. It isn't about quantity. It is about quality.

When sending deliverable a certain way that isn't easily reproduced by the client without being noticeable as a copy made. So, by choosing cyanotype or diazo, there is no misidentifying the official released copies from some photocopier reproduction.

Keeping my originals in my office is an office rule as with retaining all proprietary rights to the designs. 

Diazo and Cyanotype are methods of making released copies. 

Common CAD blocks details can be printed on small sheets of mylar and through layering techniques can be incorporated. There is so many tricks to the trade that saves time as needed.

Obvious use of gloves when handling mylar makes sense.

Therefore, is there any reason one can't do what they need to do for all this to work?

There are ways to do all this. I'm not saying this is necessarily the fastest reproduction method. Incorporated in the process is to take more time and direct clients into good practice of getting all the design issues done at the design phase before rushing into construction. 

Even if I was working on this reproduction process, there is time to THINK. One attitude that is being mistakenly done in the architecture practice is rushing to get everything done but no real efficiency is actually attained. Rushing means you make more and more reiteration in CAD but drawing it out is not as fast as the mind. Take 15 to even 30 minutes more to think can save you 3-4 iterations of corrections that can cost you an entire day's worth of work. 

CAD has its benefits and it has its problems, too. I speak of CAD as broadly as possible to include ALL computer design tools used to aid the design process. 

There is benefits to the process that gets one away from the computer to think more about the design. Am I against CAD? No. Am I against plotting out using a plotter? No. 

I'm also the kind of person to not depend ONLY on that method to get the job done. Diversity of method and knowledge of and even applying the use of. Using cyanotype or diazo process does not preclude use of CAD processes.

I'm not necessarily looking at being a corporate architectural firm, either. I'm not necessarily looking to be Bill Gates rich or running a firm the size of SOM. If I became license, I would likely be aiming to run a small to modest size firm if that is to give you any insight to my own aspiration. 

By office as in de-centralized. At my house, the property is zoned accordingly. It has been that way since the 1980s. Home occupancy. It doesn't matter where in the house as long as a spot is available that is not in the midst of the rest of the house. 

As a matter of fact, my office, is essentially on the third floor at this time. Exterior stair case. Utilizing a room up there and the loft section. A little bit of sorting out space and some more work there, it will be more adequately setup for my office use. 

Later, in the future, it will probably be moved into the ground level which will be better in the long run for such a use. For diazo or cyanotype process, it would be adequate. Add some insulation along the roof line and it will be even better.

I may set up a conference/meeting room downstairs at some point in time but still utilize the top floor area for aspects of the work not needing to be involving the public in general until such a time, it could all be on one floor.

Actually, the basement is occupiable and meets occupiable space. 

First off, I didn't say I was going to hire someone. It was a hypothetical statement that if I hired someone. They also make something called chemical masks. I wasn't talking cyanotype machines. That's brushed on with a foam brush. If you ever worked with cyanotype, there isn't off-gassing. Cyanotype machines haven't been produced in probably 75 years. Most architects never had such a "machine". It was almost always manual process.

They apply the emulsion to the paper to which is a liquid and there is no gas state in the process. Unless you heat the stuff to high temperature or something, the stuff isn't going to emit cyanide to any major hazard level. In the loft, there is eave ventilation and the windows and there isn't much in the realm of it being sealed.

I think you are talking about diazo machines. Those equipment would have ventilation to the outside.

I'm not talking about using diazo machines, either. I'm talking about manual application of ammonia. In which case, ventilation would be recommended highly. Where gloves, a chemical cartridge respirator and open ventilation without direct sunlight exposure. 

I worked with chemicals that are far more toxic than the chemicals used in cyanotype or even the ammonia used in the diazo process. I worked with expoxies used in column restoration which is probably a bit more toxic than what we are dealing with.

The ammonia mixture can be anywhere from lower end household 3% ammonia to slightly stronger 10% mixture used in janitorial / commercial-household use. 

I don't need the high concentration. Diazo machines also known as blueline machines used. 

Blueline machines (diazo machines/copiers) typically use 30% mix. Difference if, they are using vapor where as I would use direct contact application at a lower concentration but it might take a little longer to develop as multiple applications maybe needed to reach suitable level. Very Fine mist application and the paper will reach the level it needs to. Surely, one can use a small tray with maybe a 1/8" deep fill and the vapor will have its effect. 

Cyanotype doesn't need an extreme amount of ventilation. Far less than would be with diazo. If you employ ventilation, the only amount needed is a small household fan, and two windows opened about 6" or so with a screen (to keep flies out) in a loft area of 22' x 50'. You don't need a dark room to work the emulsion. Just outside of direct UV light source. Hence a simple halogen worklight like one of these: (link: http://www.homedepot.com/p/Workforce-250-Watt-Halogen-Portable-Work-Light-265-669/202066791 ) 250w or 500w.

You see, when the chemicals are mixed in the cyanotype, it doesn't really doesn't have the fumes emission of toxicity. Even then, the necessary ventilation can be sufficiently achieve by cracking open a window no direct sunlight at the work space. There isn't the extreme toxicity as you may think and basic mask with chemical cartridge is sufficient. 

Again, MSDS doesn't even require a chemical cartridge and only a dust mask is needed during powder state. A chemical cartridge mask is probably more than sufficient for when it is in liquid state. Remember, you're dilluting the powder in water to make Solution A & B. Only time such a mask is even remotely needed is during the exposure. They recommend basic lab gloves and lab coat (or just any overcoat needed to cover your regular cloths). In facts, its toxicity is no more than bleach.

https://sargentwelch.com/store/asset?assetURI=https://sargentwelch.com/stibo/hi_res/std.lang.all/26/52/13962652.pdf

https://sargentwelch.com/store/asset?assetURI=https://sargentwelch.com/stibo/hi_res/std.lang.all/23/05/13962305.pdf

15 mg/cubic meter. Duh, don't snuff it. Wearing a dust mask is all that is needed. When you are working with the stuff in liquid solutions, at best, wear a OSHA/NIOSH approved respirator with current chemical cartridges.

Bleach is considered a tad more hazardous. Really, you're kidding me? 

Now, regarding your question about these processes being prudent? That depends on what criterion we are judging by. Every situation is different. 

Is it prudent to protect your copyright and for unauthorized copies to be discovered and identified? Isn't the liability to buildings built from unauthorized copies of your plans exposing you to each building built from those copies from which you were never paid for? How does a building official or plan reviewer readibly identify a fraudulent copy from an authorized issued copy?

Cyanotype and diazo prints are not easily reproduced without it being noticeable that it is a copy. A cyanotype copy is pretty difficult to xerox and it look like a real cyanotype? 

They don't match up. If I used a fabric instead of paper, can the xerox copy match that fabric? I doubt it.

In residential work, it is not unheard of unauthorized duplication of your plans being made and additional residential structures built from those plans by xeroxing. Easy to do if the plans were black & white... and cheap, too! They just go to a reprographic center. Most reprographics don't make cyanotype or diazoprints let alone make copies off those copies as it is a tedious, time consuming and expensive process to do. Usually with a great chance of loss of detail as they would not have the original master copy. 

Put it short:

I'm not saying there isn't ANY toxicity to the chemicals. They aren't in and of themselves that highly toxic in the kinds of quantity that is used in cyanotype or diazo process. 

If they were that toxic, they would never had been used by architects.

Second, the level of toxicity and exposure risk of the chemicals used in cyanotype is comparable to household chemicals like household level bleach not the higher strength bleach used in commercial/janitorial level. 

Cyanotype is less a risk to health than ammonia used in diazo copiers. The level risk is minimal. A dusk mask when working with the powder, a respirator equipped with cartridge filter for chemical vapor at the most when dealing with the chemicals. Mostly needed when doing diazo process manually without a mechanical fume hood discharging the vapor to the exterior of the building. Cyanotype does not present that kind of risk but on the safe side, it is sufficient. As most of such respirators are also equipped with a dust filter part as well on those cartridges. 

Sure, basic precaution like wearing lab gloves and eye protection and lab coat (to keep the chemicals off your regular clothes, and a mask/respirator to keep the stuff from being digested or inhaled, that is sufficient along with basic knowledge of safe use of the chemicals. 

Sure, if someone was drinking the solutions, is a f---ing idiot. As for fume exposure risks, people have more risks and harm by smoking a cigarette or from the exhaust off of automobiles and trucks than we are going to get from the cyanotype.

JBeaumont,

I'm not telling you. However, enough projects. There are not any restrictions on the use of cyanotype prints or diazo prints.

The only restriction to such use is self-imposed.

Building departments still accept plans on physical media. I'm sure the diazoprints will get a little bit of departmental prioritization. 

EPA is on crack.

If EPA had their way, NO human engineered chemicals can ever be made or used.

You are too damn worried about EPA. Everything has a certain extent of hazard. When used in terrorism, you need to use a hell of a lot of the stuff. Every human engineered chemical can be used in terrorism. You know bleach and ammonia when mixed is a very VERY deadly gas that will kill you if you are exposed. Every chemical has risks. 

EPA takes absolutely EVERYTHING to extreme that as if one single drop of the chemical will kill millions of people. It doesn't work that way. SCIENTIFICALLY, IT DOESN'T WORK THAT WAY.

People using this stuff in photography aren't all having massive health problems and deaths. Frankly, terrorists are deploying potassium ferricyanide. They are deploying anthrax. They deploy pure cyanide not something they have to use extreme amounts like a superdome volume of the stuff being deployed into a city reservoir. They are going to source more toxic chemicals.

It's the same stuff used on blueprints from the 19th century and early 20th century.

If it was that deadly, it would be a highly controlled substance. I'm not talking about huge volumes. We're talking like less than 10 grams to every 100 mL. The other solution being 25 grams to every 100mL. 

EPA is controlled and operated by Environmentalist nutjobs that worries that one drop of a very low risk chemical like bleach or ammonia (both of which has more risk to human health than BOTH cyanotype solutions combined) will kill the entire city of Los Angeles. They are fucking wacked.

Seriously. Yet, cigarettes with actual CARCINOGENS has more risk to a person's health and those around them. Have they banned cigarettes? No.

Seriously, take that EPA statement with a grain a salt as being over paranoid and part of EPA standard mode of operations of scare tactics in causing public panic so they can get more control. They already have too much control for their own good.

NO ONE has ever died or ever was hospitalized for applying the chemicals on plans unless they directly digested entire bottles of this stuff. No one has EVER had health problems because of the use of cyanotype in blueprints or the so minute traces of cyanide in the air of a room that  could be emitted off the sheets from exposure of UV. Hell man, the UV emitting lamp will have more risk to your health if your skin was exposed.

You need entire cyanide pill of pure concentrated cyanide to kill you.

UV exposure doesn't cause enough hydrogen cyanide gas to be emitted at a time. You don't use the stuff in powdered form in direct UV. The indirect UV of a unlit attic away from direct light coming through a window is not going to emit enough. Only way to cause enough hydrogen cyanide to be a risk is placing it in an EXTREMELY acidic situation. So provided you operate near a window but not directly in line with light coming through the window from the sun, your risks are minimal.

The gas emission will need to be up into the 100 mg/cu.meter or m^3

300 mg/m^3 will kill. The level of emission is highly unlikely to reach that level when operating with any ventilation. The only time it is exposed to UV is during the 5-10 minutes under a halogen lamp.  

The total emission is rate would be ridiculously slow and you're going to have some degree of ventilation and air exchange. Yes, there is risks but to what extent is going to be extremely little because the level of emission would be far below that level. 

You tell me, if this was that extremely toxic in practice, how come no architect has ever been hospitalized or killed because of cyanotype process?

The rate of emission of any hydrogen cyanide gas is very unlikely and you have to be in a very well sealed environment with no ventilation which by the way is unlikely in the loft or in the basement/garage area because there are windows and there is a door. By far, there will be plenty of ventilation by convection. 

You don't mix solution A and B until you apply it to the paper and the lamp exposure is still a low risk. It isn't like one is going through 5000 sheets in a day. If there was, sure, ventilation as needed would be used. Lets be realistic not EPA's exaggeration of risk. Sure, the risk has the potential to be a serious risk but at what condition do you need to have for there to be that kind of risk? Sure.... in a Sealed up room with no air exchange rate at all or so low it is ridiculous. We aren't talking about a closet for crying out loud.

placebeyondthesplines,

Go screw yourself. I won't ask you to go kill yourself. There had been enough of that already.

Just go screw yourself.