Did you know that EWI will save the world?

Last week at the INCA AGM we were delighted to welcome Andrew Warren from the British Energy Efficiency Federation. A man who has been working across sectors in energy efficiency for his whole career, Andrew entertained us with his take on the value EWI brings to the world. He told the meeting that energy use in the UK is reducing substantially, which has an obvious impact on the health of the planet. He described how measures such as EWI are key to this reduction, and those who work in this sector must feel proud of the contribution we make.

Aside from Andrew Warren’s fascinating talk, the meeting heard about the work that INCA is doing for its members. This includes engaging with Government stakeholders such as BEIS and MHCLG both formally – consultation responses, and informally to ensure that our industry is represented. Mitch Gee, Executive Chairman also described the work of the Technical Committee in engaging with the BBA and BRE. There is clearly a lot going on at the moment!

A highlight of the meeting was the announcement of the INCA Awards shortlist. Anna Wesson, INCA Manager, reported a high number of entries – over 70, and the challenges facing the judges when they shortlisted. A quick reminder that tickets are now on sale for the event on 1 November in Manchester.

A key topic of discussion at the meeting was the Government Consultation on the use of combustible cladding on residential buildings above 18 metres. This closes on Tuesday 14 August, and in order to ensure the INCA response is as representative as possible, we value your input. Please get in touch if you have any comments you would like to make.

The AGM elected Mitch Gee to continue as Chairman at INCA for another year. This will allow him to continue much of the work he has started in terms of raising the profile of the Association and recruiting new members. The Board of Management also remains the same.

Independent Review of Building Regulations and Fire Safety – Final Report

Mitch Gee, Executive Chairman

The much-anticipated Independent Review of the Building Regulations was published last week. I have yet to read the full report but will endeavour to do so over the coming weeks and submit a fuller response to its contents.

Since her interim report in December, Dame Judith Hackitt has unearthed further evidence that the regulatory system for high rise is not fit for purpose. It does not just relate to cladding systems but for the industry as a whole.

The report was damning of the industry listing key issues for its failure:

  • Ignorance
  • Indifference
  • Lack of clarity and responsibility
  • Inadequate regulatory oversight and enforcement tools

She states there needs to be a clear model of risk ownership with clear responsibilities for the client designer, contractor and owner. It must be ‘outcomes-based’ rather than based on prescriptive rules and complex guidance with serious consequences for those who try to ‘game the system’. The model is dependent on competent people thinking for themselves and taking responsibility for their decisions. This is a breath of fresh air in our ‘tick box’ society where we are guilty of hiding behind guidelines that are at best confusing and at worst contradictory.

The report states the building must be considered as a system and not just a collection of products stitched together. Transparency of information and an audit trail. I am amazed in my own experience, how poor many of the archives are for construction projects. In an era of digital technology, one would expect the opposite, but contractors appear to invest very little in keeping good ordered records.

The report calls for systematic change which will require legislative change and it should not only consider new buildings, but look at our existing housing stock.

One has to compliment Dame Judith Hackitt on her ability to grasp the weaknesses in the current systems and culture of the building industry that results in ‘a race to the bottom’ for the construction and refurbishment of housing. We live in a tick-box culture that invades our society, the construction industry being no different in this regard. Dame Judith appreciates that there needs to be a shift change in this culture. It’s a big ask – can it be achieved?

Dame Judith, an Engineer by profession provides a pragmatic rational approach to solving some of the systemic failings in the system which ultimately resulted in the tragedy of Grenfell. She proposes to do this without restricting the industry to a limited range of products it can use on high rise cladding. As an industry we wish to build exciting, varied buildings, cost effectively and without compromising on safety. The report’s proposals should allow us to do that.

The politically more palatable solution however, is to only use non-combustible products over 18m. This may result in unnecessarily limiting the options for exciting design for architects, creating capacity issues and resultant inflation in the supply chain. We are already seeing price rises well above inflation in the supply of some non-combustible elements of high rise cladding. This will not solve the systemic problems that Dame Judith Hackitt has identified and most of us agree exist.

We wait therefore as the government consults on whether to ban everything but non combustible materials on high rise buildings.

It would be great to get feedback from the membership before we formulate INCA’s official position.

Comments on, “Amendments to statutory guidance on assessments in lieu of test in Approved document B (Fire Safety)’’

Mitch Gee, Executive Chairman

Dame Judith Hackett’s interim review of Building Regulations and Fire Safety advised that the Government should significantly restrict the use of desktop studies to approve changes to cladding systems.

The Secretary of State made the following commitment:

‘’On desktop studies we will revise the approved documents on fire safety and commission work to produce a new British Standard on how such assessments can be used.’’

There are 4 routes to compliance:

  • Linear route – all elements of the façade are of limited construction or better (non-combustible in Scotland)
  • Fire safety engineering route – the whole building is assessed for spread of fire which is undertaken by a fire engineer
  • Undertake full scale fire test BS8414
  • Assessment in lieu of test – this route will be available if there is only a slight variation in design from the original BS8414 test.

The consultation paper seeks views on whether Government should prohibit the use of assessments in lieu of tests either for all fire tests classifications or for the fire test classifications relating to BS8414 full scale cladding test.

I think most in the EWI industry would support this approach as the EWI sector has traditionally undertaken full-scale fire tests for systems offered for use over 18m. It is obviously not practical to eliminate all assessments in lieu of tests, but as an industry we would support there use be significantly curtailed.

The current Building Regulations require that the external walls on all buildings adequately resist the spread of fire. This needs to be demonstrated in one of two ways:

  • Each individual component of the wall meets the required standard for combustibility
  • That all combined elements of a wall when tested as a whole adequately resist the spread of fire to meet a set standard.

Some assessments in lieu of tests of cladding systems have been criticised for their lack of supporting data. An assessment in lieu of test should be an extrapolation or interpolation of relevant existing test data, not an estimate. Questions have been raised over the competence of some assessment authors. The Government is proposing to issue amendments to Appendix A of Part B of the building regulations which will clarify the existing text and create new requirements for assessment in lieu of tests.

The Government has commissioned the British Standards Institution (BSI) to draft a standard for the extended application of BS8414 results.

Two scenarios are being considered:

  1. Make no changes to Approved document B to restrict the use of assessments in lieu of tests
  2. Issue amendments to Appendix A of approved document B and implement the changes which are being consulted on.

Alternatively, they could prohibit assessments for all fire tests or those specifically relating to BS8414.

The impact assessments predict a 25% increase in the cost of undertaking a more rigorous assessment in lieu of test in option 2, there being more assessments in lieu of tests as there will be greater confidence in them. The calculated impact of implementing proposed change to document B is £8.0m.

It should be noted that fire tests do not directly measure fire hazard. Performance in fire tests is only one of a number of factors that should be taken into account.

The policy objective is to tighten up the use of assessments in lieu of tests and ensure they are only used where appropriate with sufficient relevant test evidence, and they are undertaken by competent staff within appropriately certified organisations.

INCA’s position is that there should be least assessments in lieu of tests and more full-scale tests, which would reduce the potential for substituting products and increasing the risk of compromising the original system. There may be some requirement for minor changes such as fixing numbers or manufacturer, or different coloured finishes.

We welcome the input from our members before we respond to the consultation. We will be responding on Tuesday 22nd May.