On most commercial projects, the subcontractor or supplier prepares shop drawings, product data, and samples. The general contractor reviews and approves them first, and by submitting them represents that it has checked them against the contract. The architect or engineer of record then reviews them for conformance with the design. Design-team approval typically doesn’t relieve the contractor of responsibility for errors or undisclosed deviations, so most of the liability for what’s inside a submittal stays with the party that submitted it.
That arrangement surprises people on both sides of the table. Contractors sometimes treat the architect’s stamp as a safety net, and owners sometimes assume an approved submittal is a guaranteed one. Neither reading matches how standard contract documents divide the work.
Three submittal types, three different questions
Each submittal type asks the reviewer something different:
- Shop drawings are prepared specifically for the project by a fabricator, detailer, or subcontractor. They show how a portion of the work will be fabricated, assembled, and installed, and reviewers ask whether that approach reflects the design intent and coordinates with adjacent work.
- Product data is manufacturer literature for products that already exist. Reviewers ask whether the selected model, options, ratings, and certifications meet the specification.
- Samples are physical examples of materials, finishes, or workmanship. Reviewers ask whether they match the design intent, and approved samples often become the standard the finished work is judged against.
The contractor’s stamp is a representation
The general contractor’s review carries real contractual weight. AIA Contract Documents’ explanation of contractor submittal review walks through Section 3.12.6 of the A201-2017 general conditions: by submitting shop drawings, product data, and samples, the contractor represents that it has reviewed and approved them, verified the related materials and field measurements, and checked and coordinated the information against the contract documents. The article adds that a contractor who simply receives and stamps a submittal without an independent evaluation hasn’t met that obligation.
In practice, that makes the GC’s stamp a contractual act. A package forwarded without a real review leaves the contractor exposed to any error a proper check would have caught.
Product data: where field language and contract language differ
What field teams call a technical submittal in construction is, in contract terms, usually product data: manufacturer literature marked to show the selected model, options, ratings, certifications, and warranty terms for a specific spec section. The jobsite term never appears in the general conditions, which is one reason subs and GCs sometimes disagree about what a complete package looks like.
Because product data comes off the shelf, reviewing it is mostly a comparison exercise. Each value on the cut sheet is checked against the corresponding requirement in the spec and the equipment schedule. Shop drawings call for more engineering interpretation, while product data calls for patience and thoroughness, value by value. When a mismatch slips through, it’s generally treated as a miss in the contractor’s review, since that’s the review designed to catch it.
What the design team is responsible for
The design team’s review is real, but its scope is set by the contract, and public contracts spell that scope out especially clearly. The Federal Acquisition Regulation’s clause on specifications and drawings for construction requires the contractor to coordinate shop drawings, review them for accuracy, completeness, and compliance with contract requirements, and mark its approval on them as evidence of that review. Shop drawings submitted without that evidence may be returned for resubmission.
The same clause states that approval by the contracting officer doesn’t relieve the contractor of responsibility for errors or omissions, or for complying with the contract, except for variations that were described and approved under the clause. Its definition of shop drawings is also broad, covering descriptive literature, schedules, and performance and test data alongside drawings, which brings much of what private contracts call product data under the same rule.
| A useful rule of thumb
Approval narrows the question the reviewer answers. It rarely moves responsibility for what the submittal contains away from the party that submitted it. |
Delegated design changes the chain
Things get more layered when design responsibility is delegated. STRUCTURE magazine’s article on delegated design in structural steel explains that the AISC Code of Standard Practice offers three ways to handle connections, one of which assigns connection design to a licensed engineer working for the fabricator. Under that approach, the connection engineer confirms in writing that the shop drawings incorporate the connection design, and that confirmation doesn’t replace the engineer of record’s approval.
The same article notes that CASE’s national practice guidelines keep responsibility for the primary structure with the engineer of record. The specialty engineer owns the delegated design, and the engineer of record still reviews it for conformance and for how it fits the overall structure.
Deviations belong in writing
Across these frameworks, one habit protects everyone: disclose deviations openly. Most contracts expect variations from the contract documents to be called out explicitly; the FAR clause, for example, requires them to be described in writing, separate from the drawings themselves. A deviation buried inside a package and later approved without anyone noticing generally remains the submitting party’s risk.
Timing matters as much as content
Liability questions often turn on sequence. Work performed before a required submittal is approved is generally at the contractor’s risk, and many contracts, including the FAR clause above, say so directly. Ordering equipment early to protect a schedule can make sense, but that decision should be made knowingly, with the exposure understood by the people who carry it.
Review durations need room in the schedule, too. Contracts commonly give the design team a defined period to act on submittals, and every resubmittal restarts that clock. Contractors who sequence critical submittals early, and design teams who flag incomplete packages quickly instead of holding them, both reduce the pressure that leads to rushed reviews.
Practical habits for each party
- Subcontractors: mark selected options, ratings, and tags clearly, and list every deviation on the transmittal.
- General contractors: review against the spec section as well as the cut sheet, and treat the approval stamp as a representation.
- Design teams: state the scope of review on the stamp and respond to disclosed deviations explicitly.
- Owners: avoid approving technical content outside the roles the contract assigns.
Reading the stamp correctly
A submittal stamp records that a review happened at a particular level and for a particular purpose. Teams that understand who checks what, and who stays responsible afterward, catch more problems early and argue less about them later.
