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Approved Inspector Building Regulations
Fire Risk Assessment

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Hackitt Report

Posted by wilkinsoncc on May 8, 2018 at 5:45 AM

The much awaited Hackitt Report into the future of Building Control is due to be published soon.


In this blog we look at the changes to the system that we would like to see in the recommendations.


  1. Approved Inspectors have no powers of enforcement unlike Local Authorities. This needs to be reviewed and either powers given to Approved Inspectors or a new National Enforcement Body set up to ensure a level playing field. In addition powers should be introduced to enable on the spot fines and stop notices to be issued in line with the way the HSE currently enforce CDM regulations.
  2. There needs to be consistency on service delivery and a single overarching licencing body should be provided to licence and oversee both public and private sector BCB - a sort of OFFWAT for Building Control. The current Licensing body for Approved Inspectors (CICAIR) would be well placed to undertake this role, however would need additional resources and enforcement powers.
  3. A Golden Thread is required to preserve the original design intent throughout and making sure any changes go through a formal review. The current system of Building Notices should be withdrawn and replaced with a requirement for outline Building Control Approval to be in place prior to works commencing on site. This stage would require that plans showing basic fire safety measures (in line with Reg 38 guidance) are submitted, the fire service consulted where applicable and agreed in principle prior to works commencing
  4. All projects should have a single designated person to take responsibility for co-ordinating Building Regulations compliance. This role already exists on the statute books and is known as an Appointed Person. However this section of the Sustainable and Secure Buildings Act has never been enacted
  5. To ensure that there are no conflict the Appointed Person should ensure that all BCB are assessed prior to appointment and that they have the necessary resources and experience for the nature of the project. Additionally there must be no conflicts of interest and the BCB should not have any design or financial interest in the scheme - for example the BCB should not own the building and should not directly or indirectly (for example as part of a group of companies) be involved in designing the scheme.
  6. Building Control fees ideally would be set against a national fee scale to help prevent competition on price, and should be paid in advance (eg at application stage) to ensure that there is no conflict of interest and no pressure to sign off non-conforming works in order to receive payment.
  7. The regulations themselves need to be simplified and Government should take a greater role in determining interpretation rather than leaving it to industry. For example the BCA Guide 18 that allowed the use of desktop studies should not have been produced and instead Government should have stepped in to clarify the correct interpretation. This can be done through the use of an smart phone App to improve access to the regulations and a FAQ section allowing questions to be posted and replied to.
  8. We would like to see the guidance on Cladding clarified to permit only systems that are either Limited Combustibility or have been tested in the exact combination to be used. It will also be necessary to improve the collection of data to show what materials have been installed and where, for example in the event of a future product failure it should not be necessary to undertake removal and destructive testing as was the case at Grenfell. This could be achieved by manufacturers bar coding products and builders using smart phone technology to GPS position and record exactly what product and batch was used on what building – again uploaded to a national database. Where BIM is used this would also flag up instantaneously any deviations in design or product substitution and ensure the Golden Thread is maintained.
  9. British Standard Fire Tests should be reviewed to ensure that the current assumptions on fire growth (Eg time and temperature) accurately represent the increased use of plastics within buildings.
  10. The Regulations on controllable works need further clarification, as even minor works such as installing cabling can breach fire separating or compartment walls, replacement doors can also reduce fire protection, and these elements need to be captured either through self certification by competent contractors or by formal Approval.
  11. The current regulations do not require retrospective improvements for fire safety - so a tall building that does not have sprinklers can continue to be non-complaint as long as works are not made worse. We would like to see the introduction of consequential improvements for fire safety measures (these already exist for thermal upgrades). This would require that a % of the cost of any project is spent on upgrading fire safety measures and would encourage owners to implement improvements recommended within Fire Risk Assessments. For example if 2% was applied as a bench mark then on a £1M project £20'000 would need to be spent on improving fire doors or fitting sprinklers if these didn’t already comply.
  12. In addition it needs to be made clear that Building Control approval is a minimum standard and not a get out of jail free card. Building Regulation Approval is similar to a MOT certificate – it looks at ensuring the minimum safeguards on the day of the inspection. The culture of industry needs to change and instead of trying to design down to the minimum standards of Fire Safety (or even below them), designers and building owners should compete & innovate to become the safest building. The use of Euro NCAP markings on cars have encouraged motor manufacturers to exceed minimum MOT standards introducing additional air bags, collision detection etc. Elsewhere similar marking systems have encouraged improvements in Energy Efficient buildings and appliances and even in food safety standards. We would like to see the introduction of a mandatory Fire Safety Marking scheme based on the current FRA process requiring a summary to be displayed on all buildings.
  13. We would also like to see a requirement for FRA to be deposited up to a national database accessible to the Fire Service so that they can see that they are up to date and that the recommendations and risk levels can be monitored and enforced as necessary.


Many of these ideas are hardly new and most have been around since the Future of Building Control Implementation Plan published in 2009 a report that has still not been implemented by either the coalition or the current Government.

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