FIS technical director Joe Cilia considers the key points from the review into Building Regulations and Fire Safety commissioned by government following the tragic fire at Grenfell Tower last year.
Dame Judith Hackitt’s final report, Building a Safer Future: Independent Review of Building Regulations and Fire Safety, was published on 17 May. We had already been given a direction of travel with the interim report. It highlighted that there was a lack of evidence that what was being installed was, in fact, compliant and that there was a lack of competency in the industry. Dame Hackitt had also said that product labelling was, in some cases, lacking and misleading.
The full report, which is aimed at higher risk residential buildings (referred to as HRRBs within the report) but does not rule out other buildings where there is residency, such as hospitals and care homes, aims to address the process to provide an outcomes-based solution rather than a prescriptive one. This approach caused much consternation in the media when the report was published because combustible materials were not singled out and banned for use as a cladding material, yet if the recommendations were in place during the refurbishment of the tower, the cladding used would not have passed.
Fifty-three recommendations are listed in the report, broken into 10 chapters, which include 2) Design, construction and refurbishment, 5) Competence, 7) Products and 8) Golden thread of building information, where I believe the greatest impacts in our sector will be seen.
The report highlights that the responsibility for building safety is often passed down to the sub-contract level. This is where changes driven through ‘value engineering’ – described in the report as “a systematic and organised approach to providing the necessary functions in a project at the lowest cost” and “promoting the substitution of materials and methods with less expensive alternatives” – often go undocumented in what some have termed a ‘design and build’ culture. The report recommends that permission to proceed with a project will only be granted when evidence is submitted through a series of ‘Gateways’ that the build will meet all the requirements of the Building Regulations.
Competence of everyone involved in the design, procurement, delivery and maintenance of the building is a key recommendation. Defining levels of competency for each of these disciplines will be challenging and will require cooperation across the sector to ensure they can be defined, evidenced and the correct training put in place over a transition period that is workable against a background of a skills shortage.
The recommendation for clear, permanent and transparent labelling of products should start to address confusing wording, such as ‘fire proof’ or ‘fire resistant’, that is used without clearly explaining the parameters within which the product can be used. It will also drive manufacturers to provide clear and complete test evidence which includes details of the test, its results, configurations, parameters and installation details, rather than some single-page statements put out with scant information, leaving contractors vulnerable when challenged to provide evidence of compliancy.
‘The golden thread of building information’ was alluded to as a key initiative in the interim report, and here in the final report it becomes key to providing evidence of compliancy and provides building owners and operators with clear information about the asset, how to maintain it and how to make safe changes if required. In a similar way to the processes described in PAS 1192 parts 2 and 3, it will use digital files and data, which are searchable and usable.
To meet the recommendations will require a change in culture where ‘good enough is not good enough anymore’. Specifications will have to be more detailed, tenders clear and unambiguous, the procurement process transparent with changes recorded and justified, product data and evidence of test reports submitted and evidence that products are correctly installed, especially where materials cover up the substantive elements such as studs or service penetrations. And, lastly, the need for a fully carded and trained to a recognised standard team to deliver these buildings.
FIS technical director