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Lesson 8: The inspection process and report format

TDLR RAS Procedures · 14 practice questions

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Reading

Inspection happens after construction is finished, verifying what was actually built against the same TAS technical chapters a plan review checks in the design. The process, the report contents, and the follow-through on violations are all more involved than plan review, because an inspection that finds violations starts a 270-day correction window and, if problems are not fixed, a mandatory transfer of the file.

Before the inspection

The owner of a subject building is responsible for having it inspected not later than the first anniversary of the completion of construction (Government Code Section 469.105 and Rule 68.52(a)). Completion of construction is the date the project results in occupancy or a certificate of occupancy is issued (Rule 68.10). TDLR's plan review transmittal letter also tells the owner to request the inspection no later than 30 days after completion, so treat 30 days as the working target and one year as the outer limit. The request can be in any written format from the owner or designated agent. Before inspecting, a RAS must obtain access to the project file, either through a file transfer request or through the TABS Sharing System, must confirm that a written inspection request from the owner or designated agent is already in the file, and must obtain a copy of the Designated Agent Form if one applies. A TDLR "Notice of Inspection Overdue" is not treated as a request for inspection.

At the inspection

The RAS must obtain a signed proof of inspection form at the time of the inspection itself. This is a contemporaneous record that the inspection actually took place on a specific date, separate from the report that follows.

What the inspection report must contain

Like the plan review report, the inspection report must be typewritten and headed, in this case "Inspection Report." It must include the RAS's name and license number, the report date and the actual date the inspection occurred, the TABS project number, the facility name, the project name and address, and a detailed listing of deficiencies with TAS reference numbers, locations, and violations. Instead of Attachment "A," the inspection report is completed with Attachment "B" (Inspection Completed, Violations Pending) or Attachment "C" (Inspection Completed, No Violations). These attachments are TDLR's prescribed transmittal letters, and the letter date must match the report date. Where there are no violations at all, transmittal letter "C" may be used instead of a full report. TDLR's procedures also make one point explicit: photographs and other documents are not permitted to take the place of a written description of a violation. A photo can support the written finding; it cannot substitute for it.

Submission timeframes

The RAS must issue the inspection report to the owner or designated agent within 30 days of the inspection date, and upload the results and the proof of inspection to TABS within 30 days of the report date, the same two-track 30-day pattern as plan review. The RAS may retain the project file for up to 270 days from the inspection report date, or until verification of corrective modifications is received, whichever comes first.

What happens when violations are found

Where an inspection finds violations, the Attachment "B" letter gives the owner 270 calendar days from the date of the letter, which matches the inspection report date, to furnish written verification that every violation has been corrected. RAS Bulletin 2023-06 (effective September 1, 2023, citing Rule 68.40(d)) adds a first step: the owner must respond in writing on TDLR's Inspection Response Form (EAB-229N) no later than 30 days after the date of the inspection report, stating that corrections are complete, asking for an extension, or saying that a variance application will be submitted. Once the RAS receives written corrective documentation, the RAS has 30 days to issue either Attachment "D," Corrective Modifications with Violations Pending, if items are still uncorrected, or Attachment "E," Corrective Modifications with No Violations, if everything has been fixed. The RAS then uploads that result to TABS within 30 days of receiving the owner's documentation.

Escalation when correction does not happen

If full compliance is not achieved within the 270-day window, the RAS is required to transfer the project file, uploading it to the TABS Transfer System within 30 days of the 270th day, or by the 300th day at the latest. This is not discretionary on the RAS's part. If the file is not transferred, the procedures say it is transferred to TDLR automatically after 301 days. A stalled correction does not just sit in the RAS's file indefinitely; the procedure forces it back into TDLR's system within a fixed window.

Why this two-report structure matters to GCHS

A GCHS-employed RAS working a project from design through completion would produce two separate, differently structured reports on the same building, a plan review report before construction and an inspection report after, each with its own attachment letters and its own deadlines. Treating them as one continuous "accessibility check" rather than two distinct regulated deliverables, each with its own required content and clock, is the kind of procedural mistake TDLR's rules are built to catch.

Inspection process and violation correction timeline A timeline from construction completion, to an inspection due within one year, to inspection and report within 30 days, to a 270 day correction window ending in Attachment D or E, with escalation to TABS transfer by day 300 if uncorrected. Constructioncomplete Inspection duewithin 1 year Inspection +report, 30 days 270-daycorrection window Escalationby day 300 Corrected: Attachment "E" issued within 30 days of owner's documentation Still pending: Attachment "D" issued instead, file stays open toward day 270 Photographs never substitute for a written violation description
The inspection timeline runs from construction completion through a 270-day correction window to mandatory escalation if compliance is not achieved.

Practice questions

1. By when must the owner obtain an inspection after construction is complete?

  1. There is no deadline as long as the certificate of occupancy has been issued
  2. Not later than the first anniversary of the completion of construction
  3. Within 7 days of the plan review report being issued to the owner
  4. Within 270 days of the completion of construction, the same window used for corrections

2. What must a RAS obtain at the time of the inspection itself?

  1. A building permit copy
  2. A notarized affidavit from the contractor
  3. Nothing beyond the report
  4. A signed proof of inspection form

3. What heading must the inspection report carry?

  1. "Compliance Certificate"
  2. No specific heading is required
  3. "Inspection Report"
  4. "Plan Review Report"

4. Which attachment accompanies an inspection report when violations are pending?

  1. Attachment "E"
  2. Attachment "A"
  3. Attachment "B"
  4. Attachment "C"

5. Can photographs replace a written description of a violation in an inspection report?

  1. Yes, but only for restroom violations and other findings that involve fixtures or clearances
  2. Only if the owner agrees in writing to accept photographs
  3. Yes, photographs are sufficient on their own when they are dated, labeled, and attached to the report
  4. No, photographs and other documents cannot take the place of a written description

6. Within how many days of the inspection date must the report be issued to the owner or designated agent?

  1. 10 days
  2. 15 days
  3. 30 days
  4. 60 days

7. For how long may a RAS retain the project file to verify corrective modifications?

  1. 180 days from the inspection, with an extension available on the owner's request
  2. Up to 270 days, or until corrections are verified, whichever comes first
  3. Thirty days from the date the report was uploaded to TABS, unless the owner objects
  4. Ninety days, with one 90-day extension allowed if the owner asks in writing

8. What written verification must the owner furnish if an inspection found violations?

  1. Nothing; the RAS closes the file automatically after 30 days if the owner does not respond
  2. Written verification that every violation is corrected, within 270 days of the report date
  3. A verbal confirmation to the RAS, followed by a new construction permit
  4. A new construction permit and a second inspection request within 30 days

9. Once the RAS receives the owner's corrective documentation, how long does the RAS have to respond?

  1. 30 days, issuing Attachment "D" or Attachment "E"
  2. 90 days, issuing a single closing letter to the owner and TDLR
  3. There is no deadline for the RAS's response, since the file stays open
  4. 7 days, with the results uploaded to TABS on the same day

10. What does Attachment "E" specifically indicate?

  1. Corrective Modifications, No Violations: everything cited has been fixed
  2. The project file has been transferred through the TABS Transfer System after day 300
  3. Violations are still pending after the owner's correction attempts
  4. The inspection has not yet occurred and the request is on file

11. What happens if full compliance is not achieved within the 270-day window?

  1. The 270-day window automatically extends indefinitely while the owner keeps working
  2. The RAS license of the person who inspected the building is revoked
  3. The RAS must transfer the file through the TABS Transfer System by day 300
  4. The file is simply closed with no further action by the RAS or TDLR

12. Is escalation at day 270-300 discretionary for the RAS?

  1. Yes, but only with TDLR's written permission to keep the file open
  2. Escalation does not apply to inspections, only to plan review files
  3. Yes, the RAS may choose to keep the file open longer if the owner is cooperating
  4. No, the transfer requirement is mandatory under the procedure

13. How does an inspection report's attachment lettering differ from a plan review report's?

  1. Plan review uses "A"; inspection uses "B" or "C," with "D" or "E" for the later correction cycle
  2. Both use the same attachment letters, with the type of report shown only in the heading
  3. Plan review has no attachments; only inspection reports use attachment letters and forms
  4. Inspection reports never use attachment letters and rely only on the written heading

14. Why is it a mistake to treat plan review and inspection as one continuous "accessibility check"?

  1. Because they use identical report headings, attachments, and deadlines in every case
  2. Because they are two separate deliverables, each with its own content, attachments, and deadlines
  3. Because inspection replaces the need for plan review entirely on subject projects
  4. Because only one of the two is actually required by TDLR for a subject project

Glossary

Proof of inspection form
Signed at the time of inspection, a contemporaneous record distinct from the later written report.
Attachment "B" / "C"
Accompanies the inspection report: "B" for violations pending, "C" for none found.
Attachment "D" / "E"
Issued after the owner's corrective documentation: "D" if violations remain, "E" if all are corrected.
270-day correction window
The period from the inspection report date within which the owner must document full correction.
TABS Transfer System
Where a RAS must transfer an uncorrected project file by day 300 at the latest.
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