Technical Review of Approved Document B (Fire Safety)

This article was written by Colt’s Technical Director, Conor Logan

Back in April I wrote about the consultation that the Housing Minister, Robert Jenrick MP released inviting comments on the plans for the future of construction, encompassing the recommendations of the Building a Safer Future recommendations from Dame Judith Hackitt i.e. the forthcoming Building Safety Bill which has now had is second reading in the House of Commons.

The next steps for this legislation will be a review by a select committee during the autumn of this year, expecting Royal Assent next summer. The aim of the Bill is to set out ground rules for improving building safety and implementing Dame Judith’s recommendations, enabling MHCLG in the main, to implement changes without having to revert to a new Bill every time, the overall aim being to ensure that residents are safe in their homes.

The actual specifics of how the rules will be implemented, and enforced, will be subject to further legislation which should follow later in 2021/2.

First of all, there will be a new National Building Safety Regulator, under the control of the Health and Safety Executive (HSE), which is likely to become enforceable under a change to the Health and Safety at Work Act. This Regulator will be responsible for
•    Overseeing safety and performance of all buildings.
•    Implementing a more stringent set of rules for buildings deemed to be high risk.
•    Promoting competence throughout the construction and occupation of buildings.

There will also be 3 support committees, the Building Advisory Committee, advising the Regulator on building matters; a committee to promote/improve competence in construction and management of buildings; and a Resident’s panel, providing a consultation board to the Regulator to consider and review any changes that the Regulator might make that could affect residents in buildings that fall into scope. Importantly, the Building Safety Bill will also provide for the ability to amend the scope in the future, if deemed justified.

So a lot of emphasis on competence, which is something that is very hard to define and measure but equally obvious when not present. The Smoke Control Association has already created a Competent Installers Scheme, through International Fire Consultants Certification (IFCC) aimed at auditing and inspecting installers to ensure that standards are being achieved,  At Colt, we like to think of ourselves as early adopters – we were the first to be registered for smoke control systems, including smoke and fire curtains – so we welcome a scheme that not only raises the level of competence throughout the design, construction, commissioning and maintenance of life safety systems, but also gives MHCLG the power to raise the bar further should it see fit, to eliminate some of the bad practices that exist in our industry. For too long, it seems anyone can set themselves up as a smoke control specialist; there should be more emphasis on proven knowledge, capability and experience.

Likewise, in the wider field of fire engineering, there is clearly a lack of qualified Fire Engineers in the market to fulfil the extra demand of some of these requirements; we should be demanding more fire engineering courses at universities and colleges and encouraging fire engineering as a career choice to our young people.

There will be a new focus on Construction Products, with the introduction of a new Construction Products Standards Committee, which will not only raise the bar for construction products but will also introduce voluntary requirements for third party certification schemes. Of course this already existed with CE marking under the Construction Products Regulation, but was poorly policed and with Brexit, needed a replacement scheme anyway.

There is a little more clarity here: MHCLG will have the power to create a database of ‘safety critical’ Construction Products and impose essential requirements on these that need to be demonstrated. This still sounds very much like the Construction Products Regulation but possibly with a little more flexibility as standards will not necessarily need to be agreed with the rest of the EU. The principal difference is that this should be about raising the safety performance of buildings, whereas as the Construction Products Regulation is more about creating a level playing field and removing barriers to trade.

Finally, the current Covid-19 pandemic is going to put pressure on margins as companies struggle with reduced cash flow - the temptation to cut corners to secure additional work or to save money is going to increase – as will the temptation for contractors to procure at the cheapest price.

Without wanting to refer back to the tragedy of Grenfell, it is often the procurement side of contracting that leads to the biggest problems. A bit of a sweeping statement, as many contractors have highly professional procurement teams, but there are others that are only interested in the price, regardless of the quality.  Of course price is important, every project must have budget constraints, but let’s not forget that compliance and competence inevitability need to be paid for.

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