Pennsylvania Architect — v3n1 2011
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Why Does The AIA Oppose Interior-Design Licensure?
Paula R. Maynes

The American Institute of Architects (AIA) does not support the licensure of interior designers. We oppose interior-design licensure laws primarily because interior designers are not trained in the full array of issues impacting the public’s health, safety and welfare (HSW). However, there are many other critical considerations, including the fact that interior designers themselves are divided on this issue.
Further, there is no body of evidence calling for the regulation of interior design, an interior-design practice act would create new and unnecessary governmental costs, and adding a lower level of licensure is likely to lead to confusion and result in abuses. Moreover, severing the regulation of building interiors could do harm to the integrated practice of architecture.

Architects value the contributions that interior designers make as members of the design team and recognize that their education level is higher than that of decorators; however, the AIA does NOT support diminishing or weakening licensure standards. We must remember that licensure is a matter of law. At the heart of the issue is a debate over competency, authority and the public trust. For many years, a contingent of interior designers, often friends and co-workers whose work we respect, has campaigned for the passage of an Interior Design License Act in order to gain the right to sign and seal permit documents. In 1989, the AIA negotiated an accord with the ASID, the Institute of Business Designer (IBD) and the International Society of Interior Designers (ISID). The IBD and ISID later merged to become the IIDA. The accord would allow interior designers to gain a “title” but not be “licensed” to sign and seal permit documents. The accord was violated within a few months when a contingent of interior designers sought “licensure” rather than just “title.” Notably, interior designers remain divided on the issue of a practice act. Similarly, many AIA members are greatly frustrated by the dispute over interior design licensure. As a membership organization, AIA policies are debated, vetted and determined by the representatives we elect to carry our concerns to a national forum. In turn, each chapter of the AIA agrees to support these policies.

As interior-design practice acts continue to be debated, it is essential to understand that licensure is a legal process meant strictly to establish a level of competency in order to protect the health, safety and welfare (HSW) of the public. A licensed professional must demonstrate his or her preparedness to sign and seal building permit documents and his or her willingness to assume all the liability associated with that responsibility. Licensure is NOT a measure of creativity or even of professional stature. While design quality and professional respect are brought into the debate, the core of the dispute remains a fundamental disagreement over the standard of competency required in order to sign and seal building permit documents.

The American Institute of Architects opposes interior design licensure for the following reasons:

1. Health, Safety and Welfare Education, Training and Testing — AIA opposes interior design-licensure because interior designers do not undertake the necessary education, training and testing to appropriately and competently address the full array of design issues that impact the HSW of the public, including structures and building energy systems.

In contrast, there are three essential and highly regulated stages of development to be fulfilled in the arduous process of becoming a licensed architect: (1) obtaining a degree from an educational program accredited by the National Architectural Accrediting Board (NAAB); (2) on-the-job training and documented experience through the Intern Development Program (IDP), monitored and prescribed by the National Council of Architectural Registration Boards (NCARB); and (3) a rigorous series of licensing examinations conducted by the state or commonwealth that often take years to complete. As a matter of fact, among other requirements, an intern who has earned a degree from a nonaccredited educational program must invest no fewer than nine years of monitored internship training in addition to passing the licensing exam to achieve architectural licensure in Pennsylvania.

Interior designers do not receive a comparable level of instruction and training in the full array of issues impacting the public’s HSW and, essentially, do not know what they do not know.

2. Interior Designers Are Divided — Many interior designers do not wish to assume the responsibility, the liability and the ongoing costs associated with licensure and liability insurance that would result from interior-design licensure. Additionally, interior-design regulations may restrict trade by making the services of those who provide retail-based design services unlawful.

3. No “Body of Evidence” — There is only one reason to establish licensure for any profession, and that is when there is a clear threat to the public’s HSW. There is no body of evidence calling for interior-design licensure. The public is not being harmed by, or perishing as a result of, a lack of interior-design regulation. Consumers are not demanding pro-tection from interior designers. In 2007, the Alabama Supreme Court upheld a lower court ruling saying that the Alabama Interior Design Practice Statute was unconstitutional in that “enforcement of the act has no rational relationship to health, safety, or welfare of the citizens of the State of Alabama.”

4. Governmental Costs — The cost of creating and maintaining an Interior Design Licensure Board in Pennsylvania is estimated to be $700,000 for a two-year period. The establishment of an Interior Design Licensure Board would be a substantial new cost to the government and is not expected to be supported by enrollment levels. In 2005, states with Title or Practice Arts for interior designers averaged fewer than 1,000 registered designers. For example, in Virginia, where there is a Title Act, there were only 479 registered interior designers in 2005. There is a movement to rescind this law underway now. Similarly, Georgia had 294; a state with a Title Act since 1994. In his 2008 veto of S.B. 3659, then-Gov. David Paterson said, “This bill could also limit new entrants into the field of interior design, and thus, retrain competition. Morever, no evidence has been presented to suggest that harm is occurring to the public as a result of unregulated practice of interior design.”

5. Nature of Architectural Design — Past interior-design licensure bills have attempted to define interior design in a manner that causes great harm to the practice of architecture by splitting out the interior elements of a building and relegating architects to the design of building cores and shells. Further, in an era when green design and integrated project delivery encourages a more comprehensive look at project design, management and delivery, breaking out interior design as a standalone activity is counterproductive and antithetical to the sustainability movement.

6. Public Confusion — Adding a lower level of building-design licensure will confuse the public about levels of competency. More significantly, varying standards for licensure are bound to lead to abuses and pose a genuine threat to the public.

7. NCIDQ Branding — Interior designers have the opportunity to differentiate themselves in the marketplace by educating the public about their brand of certification, the National Council for Interior Design Qualification (NCIDQ), without incurring the liability and cost of licensure. Interior designers could choose to follow the example of Leadership in Energy and Environmental Design (LEED) as an excellent model of how branding can be successful in the building industry.

8. Become an Architect — Better yet, interior designers have the option to expand their education and become architects. We would welcome them into our ranks.

Architects are collaborators and problem-solvers, and we look for ways to make everyone happy. However, this debate provides an opportunity for architects to do a better job of educating our legislative policymakers about the value of the services we provide by explaining that we create the interior and exterior spaces where people work, live and play by using the physical matter and components of buildings as tools. We can point out that the best works of architecture do NOT segregate the interior and exterior of a building but, rather, are holistic compositions. We can remind lawmakers of familiar examples, such as the Capitol Building Rotunda in Harrisburg, Falling Water in Southwestern Pennsylvania, the New York City Apple Store and Notre Dame Cathedral in Paris, where the interior and exterior of each building is an integrated work of art and science.

Please feel free to contact AIA Pennsylvania with questions or concerns about protecting and maintaining the standards of professional licensure.

In the public interest, the AIA holds that only architects and engineers licensed through examination possess the necessary education, training and experience to protect the health, safety and welfare of the public in the built environment. Other individuals may possess useful skills in designing within the built environment, but fragmentation of responsibility for the building design process endangers and misleads the public as to respective areas of competence and expertise. The AIA opposes practice or title regulation of individuals or groups other than architects and engineers.