The Competence Steering Group (CSG) has issued an interim report for consultation into improving the competence of those working on Higher Risk Residential Buildings (HRRB).
The report represents twelve months of work by more than 150 institutions and associations from the construction, built environment, fire safety and owner/manager sectors, and sets out a package of measures for improving the competency of those involved in the design, construction, inspection, assessment, management and maintenance of HRRBs.
What is the report?
The report, Raising the Bar, forms part of the post-Grenfell review following Dame Hackitt's Building A Safer Future report in May 2018. Dame Hackitt pointed to a fragmented approach to competency of individuals and a lack of consistency in processes and standards for those working on HRRBs, which constituted a major flaw in the current regulatory system. The CSG was set up to address those failings.
The CSG tasked 12 working groups to develop competence frameworks for individual sectors, and also to develop a competence framework for a new over-sight body. The recommendations dovetail with the Government proposals for reform of the Building Regulations.
The report contains 67 recommendations on how competencies can be improved across those sectors.
What are the key recommendations?
The key recommendations include:
- a new oversight body, the Building Safety Competence Committee – to create a central register of duty holders eligible to work on HRRBs, and be responsible for competency standards, assessment frameworks and guidance for driving improvements
- new competency frameworks to be adopted for different specialisms, such as fire engineering, project managers, designers, engineers, building standards officers, site supervisors, and installers
- the principal designer/principal contractor/building safety manager should have additional competencies relating to their proposed overarching role
- competence should be demonstrated by independent third party assessment and periodic re-assessment (no less frequently than every 5 years)
- organisations carrying out assessments and re-assessments should themselves be subject to oversight by a body such as UKAS ("accrediting the accreditors")
- common principles of continuing professional development to be established across all sectors to maintain competence
- fire safety materials explaining basic fire science to be available to anyone working on, or managing occupied, HRRBs
- the proposed building safety manager title (under Hackitt) should be amended to building safety co-ordinator and have its own competence framework
- there should be a new role of Independent Construction Assessor appointed by the client
- there should be a Procurement Lead for HRRBs with the required level of procurement competence.
What is the proposed Independent Construction Assessor?
The Independent Construction Assessor (ICA) would be separate to the Approved Inspector or Building Control role and would be appointed by the client for HRRBs.
An ICA would assess that on-site and off-site works comply with the design and necessary building standards and regulations, providing an additional level of independent scrutiny. The ICA would also be in a position to maintain the continuity of the Golden Thread of information.
For clients, the appointment of an ICA would inevitably increase project budgets for HRRBs, but would tie in with the potential general duty to promote building safety set out in the Government proposals for reform of the Building Regulations. The ICA could be used to support the proposed gateway process.
Although the competency has been devised for HRRBs, there is a suggestion that these could be modified for those working on other buildings. Independent on-site checking by a clerk of works has all but disappeared, but there is clear support for the re-introduction of such checks.
What is the role of procurement lead for HRRBs?
Another new potential role is the use of a dedicated procurement professional with the appropriate competence to ensure that procurement best practice is adopted for HRRBs, and that a safety first mentality is adopted ahead of price.
A procurement lead would need to have a comprehensive understanding of the construction process and the wider external environment, so as to ensure that safety requirements are not compromised for cost reductions.
Are there sufficient skills?
Putting the new frameworks and training courses in place is likely to take time to implement, with some reports suggesting that this might take several years to complete.
In addition, the industry is already facing a shortage of skilled workers, so it is unclear whether or if there will be sufficient numbers of suitably qualified people to work on HRRBs if these proposals are adopted.
In relation to the possible shortages for the ICA role, the report suggests that Approved Inspectors and building control professionals, principal designers, construction managers and building surveyors could be upskilled to take on this role.
The ambition is that the new competency frameworks, combined with the introduction of third-party assessment, an ICA, HRRB Procurement Leads and a new oversight body will result in a step-change and improve competence, resulting in more robust safety management processes for HRRBs, and drive cultural change.
Beyond this, the report calls on the Government to take the lead by requiring that those who work on all government projects, not just HRRBs, to meet these new competency frameworks.
In the longer term, the report suggests that improved competency frameworks should be adopted for other areas beyond the 12 roles identified, such as clients, one-off designers, contractors and sub-contractors and facilities managers.
It remains to be seen whether government and the industry will back these proposals. The report is an interim report and subject to consultation until 18 October 2019.