Last year I laid out three issues which I felt were crucial to improving fire safety following the Grenfell tragedy. These included a review of Approved Document B (ADB) to the Building Regulations; a need for prescription in certain scenarios; and recognised and mandatory competency systems for those responsible for the design, installation and assessment of life safety systems in our built environment. So where are we now with regards to each of these issues?
Let’s first consider the regulations. The Hackitt Review highlighted a need to review the entire regulatory framework but failed to call for a full review of Building Regulations, which was said to be outside of its terms of reference.
The Ministry of Housing, Communities and Local Government (MHCLG) has undertaken a review of the language and clarity of ADB, which has been released for consultation. In addition, the Secretary of State for Housing, Communities and Local Government James Brokenshire has announced a full technical review to begin in the Autumn.
The move comes following the release of a report from an MHCLG Select Committee of MPs which called for an immediate review of the Building Regulations and declared that, “The Government must immediately take forward its review of the current guidance as a matter of urgency, with the intention of publishing an updated version of Approved Document B before the end of the year.”
The Select Committee report also concluded that Dame Judith “was right to highlight the need for significant cultural change in the industry, with greater accountability and clear sanctions that act as a real deterrent to those that break the rules.” It also agreed that “the building regulations require simplification, that fire safety should be addressed throughout the life-cycle of a building…”.
The ASFP, along with many in the fire sector, welcomes the announcement of a full technical review of ADB and similarly agrees with the MPs’ conclusion that Hackitt’s recommendations for cultural change “could and should be applied to a wider range of buildings and to the construction industry as a whole.”
Subsequent comments from Dame Judith suggest that, while her immediate aim is to concentrate on the estimated two to three thousand high risk residential buildings (HRRBs) she would hope to broaden its application to other buildings over time. Such a move would receive widespread support.
The need for prescription
And what about increasing the level of prescription within the building regulations? There now appears to be a clamour of voices calling for a ban on combustible cladding and for limits on the use of assessments in lieu of fire testing.
I previously argued that, since fire tests will never be able to reflect every product combination or every end-use application, assessments in lieu of fire testing are a necessary and technically justifiable process to cover the huge variety of fire-protection products and their installations. However, I noted that there is a clear need to significantly tighten up the assessment process, particularly for cladding systems, where the market in assessments is not as mature as for other products.
Additionally, I commended Dame Judith for not recommending the introduction of a ‘quick-fix’ ban, agreeing with her argument that in a properly structured and policed outcomes-based regulatory system, combustible materials would never have been installed on a building such as Grenfell. But I now find myself agreeing to some extent with the Select Committee, which states:
“There is no binary choice between having an outcomes-based system with greater accountability, robust regulatory oversight and strengthened sanctions on the one hand, and prescription on the other hand. The two are not mutually exclusive.”
The Committee declares that it wants to see “a system in which a reformed industry can be trusted to put fire safety first, with a robust system of oversight and meaningful sanctions, but underpinned by a strong, prescriptive approach to ensure minimum standards and guarantee the safety of residents.”
While the Select Committee clearly supports a ban on combustible materials, discussions within the industry suggest that a total ban is unrealistic and undesirable. The preferred route is for some form of hybrid control, limiting materials in certain quantities/locations, coupled with a rigorous testing regime. This should satisfy those who want a ban, while at the same time not stifling innovation or making certain types of building unbuildable.
And finally – or should I say, at long last – there does appear to be general recognition of the need for competency systems for all those involved in fire safety throughout the lifetime of a building. The discussions have now moved on to what such systems should look like and who should police them.
Dame Judith has given the construction industry a year to develop its own solutions. There are a whole range of initiatives already in place across both the fire and construction industries. The ASFP is working in several of the Working Groups set up under the Competency Steering Group, which was established by industry in the wake of the Hackitt report. Perhaps the time has now come for us to all work together to develop an industry-wide scheme to which everyone can subscribe.
For more information, go to www.asfp.org.uk