DESIGN WORKING GROUP MEETING 12-03-2025

ANDREW DE SILVA ‘DAS” One of the things that we are, as architects, being asked to help with in terms of clients is Jarek and I with input from the BIM4Housing community created that Miro board, a workflow diagram for new build HRBs and various links to HSE website information or gov.uk. so, we shared that and had good feedback, but mindful that actually we’re now getting a lot of clients, whether they’re local authorities, housing associations, who have a lot of existing stock. And they’ve got multiple demands in terms of improving, let’s say, the thermal properties of those buildings to meet national and their own internal local targets. So, simple upgraded EPC ratings, for example, or the net zero targets.

So, what we wanted to do in this forum is to get feedback from other’s experience of doing similar projects. I will share those two scenarios that I shared, one was to do with works to existing HRBs. And we reached out to the Building Safety Regulator, they’re very quick in terms of responding with setting up a meeting to discuss strategic queries that we have about the application process. And the other one was a project for re-cladding and existing building, which I think is more straightforward and I think yourselves will have had more experience than me. (shares screen). In order to get any sort of advice from the BSR from a process point of view, I’ll share this on the chat so everyone has access to it.

This email address and this subject matter or heading is what has been shared with us and should be used to generate a request for any sort of strategic discussion with the BSR. There’s a gentleman called Josh who replies, a lot of you might have seen him on the HSE webinars. He emailed back and we set up the call to discuss it, a half an hour talk, it was free and we could have follow up meetings if required. In addition to that he shared this one his contact the Building Safety Regulator link, and that’s an online for further clarification in terms of understanding about duties a bit more, or some of the Gateway submission application and guidance. Again, nothing to do with answering the technical queries because that’s something that they’ve said many times that they’re not going to do.

Another thing that came through from information is this recent request from the freedom of information. And it’s quite telling in terms of the timeframes that are actually being taken for new build projects and existing projects, so the top two after the approval. But it’s also in terms of rejection, they’re taking quite a long time, even just to reject it. I guess that’s to give them time to go through the information that’s been submitted and feel that it’s not adequate. So, that’s some serious timeframes, even one, to get approval, but actually the rejection timeframes are probably more worrying, in a way, because you could be waiting there for months and then get pushback. So, that was freedom of information on the 17th of February, so very recent.

So, I guess something to me mindful of if you’re advising clients or you are a client in terms of programmes. The project that we’re working on at the moment that I’m just about to give a fee for, the contractor client is taking a pragmatic view that after Gateway 2 submission they’ll just stand the team down, pretty much, until information is requested. Or a decisions has been made by the BSR, so it’s not really costing anyone and that’s making the client aware of that’s the process that they’re going to go through. And finally this is the scenario that I talked about, that we had the discussion with the BSR with. The scenario is a local authority client, they have something like 147 HRBs which have already been registered.

However, they don’t necessarily have control of all of the properties within each of those blocks. Some are clearly their tenants, but some are leaseholders properties who may or may not want things done to their apartments. So, essentially they’ve got 147 HRBs, but they only have control of access to percentages of apartments within those. And the works that they’re looking to is, simply speaking, internally insulating the external envelope wall. So, nothing to do with doors or fire detection or anything like that, just simply installing internal insulation. Some of them is internally having to be done because of the fact that they’re listed buildings, so changes to the facade or also difficult. And interestingly, the actual works may only take 2 or 3 days to complete.

So, one of the things that we didn’t know about was how would that effect in terms of the need to notify the BSR about when you’re starting work, when you’ve commenced work and when you’ve finished work. So, if you’ve only got 2 or 3 days to come in and do the work, they all fall into one day essentially, there’s not much difference. However, the access to those different departments within the HRB may not be possible in one go. The local authority may have to wait until the apartment is free, because maybe the tenants are away on holiday, or just feasibility in terms of the actual work that could be done. So, those were the kind of questions that we had and we raised to the BSR. And we were looking to maybe use an archetype approach.

An archetype of the sense of coming up with build-ups, products, details that could be used on one apartment, but actually would relate to pretty much all of the other apartments in the same block. Now, if the blocks are multiple blocks built exactly the same, cut and paste that we see in some estates. We were then asking also the question can we use that as a blanket approach, an archetype approach. And this is the feedback that we had. So, the view that one application for multiple apartments in one HRB is a potentially viable strategy. And what they noted was that already the HRBs would (or should) have been registered, therefore however they’d been registered would determine how applications for the works would need to be submitted.

So, the idea of sort of submitting an application which covers 4 identical blocks of HRBs was not something that they felt could be done. However, multiple flats within one HRB could be covered under one application. The thing they said that needs to be mindful of is a kind of a detailed construction control plan and a strategy for undertaking the works, because if it affects the completion and certification. So in terms of when this commencement and starting onsite, once we’ve got the approval from Gateway 2 the works have to start within 3 years, that’s a given. But then also trying to identify when 15% of the works. So, simply speaking, if you’ve got 100 apartments you need to know and notify them when 15 of those apartments will be completed in order to define that commencement of the works.

And then that impacts on when you get the completion certificates. Because these tenants are already in situ, there is no need for the completion certificate to be there for them to continue to be able to occupy their homes. Unlike, obviously in new build where you need that completion certificate for the HRB to be registered before any work can commence. So, that was quite interesting. It could be that there is a request for completion certificates by every time you finish works to a floor. Or, I guess the whole block, for example. So, that’s something that the client or the contractor would need to develop and put forward as part of the construction control plans and strategy.

And the archetype approach may be possible, they said, i.e. what we’ve done at the moment is gone into some of the flats, we’ve surveyed it, we’ve given a detailed section drawings, build-ups, specifications etc. But we’ve only been into one of, let’s say, 10 apartments which are similar. So, one thing that we’ve gone back to them and said they definitely need a floor plan of each floor of that HRB. Now, whether that needs to be super detailed, I guess depends on the work. In our case, we’re simply proposing to do works to that internal wall. So, my mind is that actually from a building safety/PD role we are kind of saying it’s compliant and here is where the works are going to be done. So, we’d have preplanned/T planned? 11mins 34secs more general arrangement plans of every single floor.

We’d identify the particular flats where the archetype section would apply to. And then say well, in our view the design is compliant and the works are compliant with the functional requirements etc, and they apply to these buildings. If obviously you’re doing works which are changing the layout of the flats or works to communal lobbies or anything like that, then clearly the level of detail in those plans need to be much more comprehensive. But for the work that we’re doing, I feel that actually the set of generic floor plans which covers every single floor, where the section that we’ve developed is applicable we would note that on the drawings. And that would then, along with the specification and data sheets etc, we would say that’s enough in our view to comply.

So, that third sentence there is something we would need to really test. And that’s something that the Regulator said is that you’re best off almost putting one application rather that doing an application for all of the buildings in one go and all of them getting rejected. Do one as a pilot, see how it goes with the technical team within the BSR and then take it from there. And that clearly is ultimately the client and the BSR PDPC needs to ensure that they’re justified why the information that we provided is demonstrating the functional requirements and complying with the building regs etc. The process in terms of applying for feedback and having a workshop was very quick, they came back within a day or two. The meeting was very useful, very open in terms of dealing with it.

And interestingly, they hadn’t had this scenario put forward to them. Which sort of surprised me because I would have thought that actually a lot of, especially local authorities or housing associations, would have this scenario. But it was good because we’ll obviously share in this forum what we’ve found. And really the next step is for our client to take that, we’ve already developed the archetype information, we’ve now got to take it to another step of generating the information for a Gateway 2 application. So, I’ll obviously keep you updated. That’s the feedback that I have at the moment, it would be interesting to hear whether you’ve had similar experiences or other experiences. And obviously, going forward, any sort of case studies that would be great.

MATT TAYLOR You mentioned about the rejection times for the submissions. Was any reasoning given as to why they are the length that they are? The other thing, I’m assuming that there is a potential for resubmission after rejection, with potential changes. So, was there any justification given for the extended turnaround time of rejection?

ANDREW DE SILVA ‘DAS’ No, it wasn’t myself who put in that freedom of information request, it was another party who then shared those dates. I don’t think, from the webinars and stuff that I’ve been to, it could be as simple as that the basic set of information hasn’t been submitted. Information about the project, for example, or suitable plans and sections and details. Or it could be that what they’re proposing in terms of the justification of the regulation that the team are following and therefore how they’ve aligned to that regulation, or that British Standard or whatever it may be, is actually not strong enough to bring comfort to the BSR. So no, is the simple answer, I don’t know and I’m not sure how, I think that would be more on an individual basis that they would provide that feedback. But previously it has been something from very minor to something quite fundamental about the design.

MATT TAYLOR But they’ve not given any justification on why that takes so long.

GEORGE STEVENSON In answer to the question, Matt, really the problem is that there’s just too few people, they don’t have enough people. They are bringing people in from a range of different organisations like Bureau Veritas to actually do it, but they just don’t have enough people. I think they’re completely overwhelmed. I think it’s also the case that there’s quite a lot of submissions that aren’t really fit for purpose. So, some people are really doing their best to do it properly, and others are…I heard of one where somebody had actually written on their submission ‘I don’t know why I’m having to do this’.

MATT TAYLOR OK, so some of them are almost thrown in and hope for the best.

BEN BLACKWOOD Just picking up on George’s point, those sorts of submissions are an exception rather than the rule. And I think the BSR’s continued citing of them is doing a disservice to the vast majority of people that are killing themselves trying to stay alive in the industry when there’s just a concrete dam across the whole thing. And we’re doing our absolute best and unfortunately the Regulator is not coming to the party. I’m not saying that those examples are not true, but I don’t think they’re representative of the majority. The key point was, just to dig into that FOI response that you received, because I did one myself in December and they kind of swerved my question slightly.

My question was how many new build HRBs have been approved? And they didn’t answer that question, they responded that this many applications have been approved. And that wasn’t the question that I asked. And what would be interesting to understand there is the average time between submission and approval for new build projects being 26 weeks. So, I’m aware of, I myself facilitated the implementation of two of the first applications which were done in the middle of February 2024. And I believe we were one of the first HRBs to put in a Gateway 2 application, probably because everyone else was clever enough to put their applications in before the 1st of October, because we weren’t quite ready.

So, we had to then obviously go back and do all of the prescribed documents and whatnot. I just wonder what is the data set that that average time between submission and approval for new build projects is based on? Because if it was none, the first application being put in, assuming it was ours for argument’s sake, in mid-Feb, and to now, an average that by dividing it in half is 26 weeks. So, there was talk of there being a hill project that had been approved at Walton-On-Thames, but we looked into that and it’s not a new build HRB, actually it was not representative. So, have there been any new build HRBs that have been approved, that’s what I’m trying to get at.

ANDREW DE SILVA ‘DAS’ I think I saw on Linkedin a couple of posts, for example, like Safer Sphere who I know are another BSA advisor/PD services they provide. That looked like a brand new building, it was something they posted a couple of days ago, or last week, but it I can ask. I’m just looking back, there’s another set of stats by September 2024, 6 months ago, and it had 14% of the thousand or so Gateway 2 applications were approved, only 14%. And 20% of them were rejected for being invalid.

Again, whether they were for new build or refurb I don’t know, but the general trend is that we’re not, if it’s only 14% of a thousand we’ve got a lot of learning to do, I guess. Or the scenarios are so difficult, or whatever. And the reasons they gave at that was that things like the mandatory information wasn’t provided, insufficient competency declarations, the compliance statements were not specific, Golden Thread of decision making not evidenced and a focus on health & safety, not building regulations and submissions. So, those were some of the things that were noted and in the feedback from 6 months ago.

BEN BLACKWOOD That’s interesting because those are the things that we had to, obviously they’re additional to a conventional application. We got a validation quite quickly on that, so within 3 or 4 weeks they came back and they had a question on one of the letters that we’d provided about competence. But that was responded to and then approved, so the application was validated quite quickly actually. All of the proscribed documents were acceptable without changes. But we are, I stopped counting at about 26 weeks, but we’re in week 54 and we still haven’t got a proper response telling us that it’s been approved.

ANDREW DE SILVA ‘DAS’ Maybe one thing I could suggest is it would be useful if it’s possible for you to do a little bit of a show and tell of what the scheme was, the high level of what you submitted. Just so that for me, being a visual person, it’s quite nice to see what was submitted and the level of detail. And I’m sure it would be useful for the team there, if that is possible maybe at the next session.

BEN BLACKWOOD OK, I’ll discuss that with my colleagues because we’ve got a consultant team and we’ve found that the consultants have really come to the table on this and put their best foot forward. But a lot of that work, for example, the building regulation compliance schedule, it’s something that we’ve developed together. And the consultant team might be a little bit reluctant, having put so much effort into it.

ANDREW DE SILVA ‘DAS’ No, understood, maybe not a deep dive, but more of a high level of this is what we had to submit, this is what it looked like approximately. Just to get a bit of a flavour and the time scales that you’re working with.

GEORGE STEVENSON I’ve been asked to join a working group in ASFP (the Association for Specialist Fire Protection). It’s a Golden Thread working group and what they’re talking about doing is asking if people are willing to share the feedback or the rejections from the Regulator. So that they as ASFP can identify any consistent things that can be worked on. Clearly, Ben, you’re quite right, there’s a level of confidentiality there, but on the other hand if everybody is doing stuff uniquely then we’re not going to get through some of this stuff. So, I don’t know whether, if some credible organisation like the ASFP would be doing this, I imagine that they’d be happy to have some sort of Chinese wall, some confidentiality that could then be doing that. I don’t know whether you think that’s a good idea.

BEN BLACKWOOD I think so, I would have no issue with it at all, I just want to be respectful to all the organisations and I don’t want to necessarily assume that they will be in the same position. But certainly on the Golden Thread piece, I did that myself and I’d be more than happy to share that around because I think the more we all work in the same structure it’s just going to make everyone more efficient.

GEORGE STEVENSON Definitely, and I think that obviously could have an impact on the Regulator’s ability to actually start to respond more effectively. Because if there were more standardised methods of reviewing these things the better.

BEN BLACKWOOD Yes, they’ve done that on the safety cases as well.

GEORGE STEVENSON Sorry, who has?

BEN BLACKWOOD Well, obviously by stating that they won’t be prescriptive and just letting everyone do what they want, they’ve then created a problem for themselves because everything is different. But then on the safety cases they’ve now produced a structure, so everyone can then follow the structure and it’s just going to make everyones lives much easier. It’s just a shame they didn’t do it a year ago.

GEORGE STEVENSON Yeah, I was at a workshop last week that was organised by Risk Flag, who produce safety case software, but there was lots of building safety managers there. And I raised the point that Das made about these archetypes and the fact that individual schemes are struggling with that. And there was a guy from Newcastle who was talking about ventilation, he was saying when you’ve got a smoke vent or something like that that’s going up the whole of the building. One of the big challenges is all of the different interfaces from individual apartments into that, each of those could be an individual submission to the Regulator. Because each time that happens that’s supposed to be signed off. And that was something that I thought was relevant.

The other thing is that I also go to a working group of building control people. It meets every couple of months and raised this with them last week as well. And they’re quite interested in seeing if there is something that can be done there as well. Because at the end of the day it’s not just about the Regulator, it’s actually about notifiable things that are relevant to compliance with building regs, irrespective of whether it’s an HRB or not.

ANDREW DE SILVA ‘DAS’ Nikita, are you from a housing association or local authority, or have had any experience with any of the applications before?

NIKI OKALA Not yet, I work for a main contractor.

ANDREW DE SILVA ‘DAS’ And you’re acting like a design manager and maybe working on HRBs going forward?

NIKI OKALA Correct, I am working on one at the moment, but it fell under the ?? 30mins 19secs period, so we don’t actually have to follow the Gateways. However, we are tendering for projects which will do…although I managed to escape it this time, it won’t be the case going forward.

ANDREW DE SILVA ‘DAS’ Yeah, I don’t know if they have taken the same approach where we as a practice is trying, a bit like what we did with the various BIM standards and naming protocols etc, we’ve kind of applied it across the board. And even when it comes the specifications and material choice. Because there are various nuances or different requirements with HRBs etc, we’re taking the view of, well, let’s just look at and specify materials which would be compliant whatever the height of the building and whatever sector. And using protocols and methods that capture the decision making on all projects where possible because the reality is the goalposts are going to change at some point in the future.

PAUL SMITH I’m from an architect, Fairhursts, we’re part of the Bond Bryan group and Bond Bryan have some HRBs on the books. I guess I’m here with an interest in documentations and standards and stuff and where that’s going. I’m part of the BIM team so we’re looking at that to try and gauge where the industry is moving, to make sure that we’re up-to-date. But I don’t have experience myself on an HRB.

GEORGE STEVENSON We’ve got a working group in BIM In Asset Management looking at handover information, Paul, that you might find useful. Standardising health & safety files and O&Ms and the whole handover piece, you’d be welcome to join. We’ve also got an event next Wednesday at 11am which is a sort of master class in 360 photography and scanning and all of that sort of stuff.

ANDREW DE SILVA ‘DAS’ And Paul, one of the things that we’re doing within DMA is trying to standardise through creating of content, so content library and then ensuring whether they’re individual components like doors, or assemblies are then also linked to the specification. So, trying to do as much as we can as an architectural business to standardise and use known or agreed classification systems like Uniclass, to make sure that we’ve got that audit trail. We use BIM 360 as our common data environment and that sometimes is shared and others in track with it.

But now that Autodesk are moving to the ACC, a new name for BIM 360, one of the things that we’re thinking about is that, even internally, should we be raising RFIs issues within the team when we’re commenting on our own design or commenting on other consultants? So that there is a more formal audit trail of the decision making leading up to a Gateway 1 or planning or tender or Gateway 2 application. Because typically at construction stage the contractors will be hosting the CDE. So, there is a discussion about well, you sort of have to package it all up, transfer it across and also then another transfer of that information to whatever the system that the client has used.

So, there are potentially still three breaks in that Golden Thread. I’ll share the Build UK guidance on Gateway 2 and the Golden Thread definitions because the Golden Thread definition is quite vague, in a way, but it’s useful to refer back to.

I’m going to also share the Miro board link again with the password to enable you to see the work that we’ve done previously to help work your way through whether determining if the existing building is an HRB or the work your going to do is an HRB, or not. And I’ll share the two Build UK PDFs which are also quite useful in terms of a good checklist for the Gateway 2 submission and the Golden Thread definition as well.

PAUL SMITH I was just going to ask, I’ve been internally trying to encourage the use of ACC for design issue tracking and commenting between teams. But admittedly I see a lot of pushback from people to keep doing it the old way, as it were. On the Bond Bryan side, we’ve just been bought out so I’m still getting used to the Bond Bryan team. They’ve got Golden Thread building people, they’ve generally been tracking by LXE? 37mins 23secs and Excel spreadsheet which tends to be a typical one of keeping a list of RFIs and decision tracking. Are you seeing much uptake on your side into the ACC? Do you enforce that? Or is it like you just encourage it?

ANDREW DE SILVA ‘DAS’ Yeah, we’re a smaller animal in terms of that because there’s 25 of us across the Liverpool and London offices. So, it’s easier than guess the task that you’ve got within a bigger organisation as well, an umbrella group. We’re about to move to ACC, we haven’t done it yet. But typically the team that we have is quite, probably from the older team because we’re older and stuck in our ways, the younger team are more easy to get them to work in that way. So, we just propose it we change the systems and the workflows and we just get on with it. Like I say, it’s easier because we’re not a biggish ship that we turn around, and that’s always been historically our advantage, in a way. But Bond Bryan with people like Rob Jackson, I know he’s left now, would have had lots of protocols and systems in place.

Because he and the BIM team there were really knowledgeable about all of those things. But I think it’s just a case of yourself, but also maybe speaking to more of the senior teams. We’re lucky David and Fiona are very pro making sure that we’ve got systems in place, so they back the R&D team when we say we want to do something. So, there’s not a lot of resistance, just more the older team resisting because we’re older, not because we don’t want to do it properly. I probably get told of more than anyone else about it, but the younger team are always up for it. So, I think you just have to get that and make sure the senior team are on the same page as you are when you’re implementing these things.

And really just try it on all schemes and start small is always what we try to do. So, we just try and use it on all projects so it becomes a standard workflow on everything, even just naming protocols, so then it becomes more second nature. If you try and pick and choose what you apply one process against another, then that actually makes it harder because it’s not business as usual. So, it might be a little bit painful on smaller projects, but in a way they’re easy ones to work and get it wrong. It’s better to get t wrong on those that on a new build, huge HRB, for example.

PAUL SMITH That’s good advice. It will be an interesting one in that we’ve got a further complication in that Bond Bryan generally is Archicad which is separate to Autodesk.

ANDREW DE SILVA ‘DAS’ Harshul, what’s your background?

HARSHUL SINGH That’s including modelling, creating schedules, managing software recommendations and all of that.

CHRIS BICKNELL My interest at the moment is generally as teaching a professional practise course at De Montfort. So, having just left AECOM, we were very much involved in trying to understand the intricacies of what's going on. I don't think we got particularly very far before I left, so I'm kind of re-approaching it from a small practise academic side at the moment. So not much to add at the moment, but pretty interested in it as I learn a bit more, I will be feeding back. I was working in the asset consultancy team, I led the lifecycle cost and consultancy piece in their strategic asset management team. So, I’m an architect by background, but I did join AECOM as a consultant, rather than an architect.

ANDREW DE SILVA ‘DAS’ And now you work for research, or is it an academic practice?

CHRIS BICKNELL No, I decided it was time to retire and have some fun and then I got approached by De Montfort who said you should know a lot about professional practice, so come and teach it for us. So, I’m doing a part-time role for them at the moment as a bit of an interim, and thoroughly enjoying it.

ANDREW DE SILVA ‘DAS’ Yeah, i guess that combination of the asset management, that’s something with lifecycle which is clearly going to be relevant to owners of buildings.

CHRIS BICKNELL Absolutely, well, most of the work we did was for a large estate owners hospitals and academic institutions. So, understanding large programmes of works, what’s refurb, what’s new build, what actually comes under which regulation, it’s something that I’m still working with George on to understand. So, there will probably be some feedback from the two of us. And just as a rocket right back to the beginning of my career, I did work for Bond Bryan in the old days when we were just one office in Broom Hill.

ANDREW DE SILVA ‘DAS’ I guess what would happen in things like hospitals, the feedback that we had from the BSR meeting is relevant to depending on if you’ve got a programme of works. If you’ve got a programme of works in a wing, for example, and they may be separated by time, what seemed to be coming back from the feedback was you don’t necessarily have to put an application every single time that you want to do something. George, in a way that example that you used about connecting to a central riser, what they were sort of saying is well, you could put an application to do works to that whole riser and connecting from each residential unit as one application, but you’d need to define a timescale for when the works would happen or may happen.

If it changes, that could be controlled through the change control mandatory occurrence, or the change control process, or that route. So, you’ve got one application that you may change, rather than many applications which would clog the whole system up again. That was sort of the high level feedback I was getting from Josh, which I think is helpful.

CHRIS BICKNELL I think the complexity that we’ve also found is that most of my asset work has been in PFI for AECOM because that’s where the lifecycle piece was wanted at the time. And just to try to understand the difference of approach between what is classed as general maintenance and upgrade, through to capital works which would require project control. Is an interesting one because they usually are led by different teams, so they’re just trying to get the alignment between the approach between the maintenance teams and the capital projects teams, and then the client’s capital project teams and maintenance teams has always been a little bit complex.I think that’s something that’s going to be teased out by these regulations as to who has to own what and what applies to what.

ANDREW DE SILVA ‘DAS’ Yeah, and I guess simplifying it from the Building Safety Regulator’s point of view the feedback again is if needs building regs compliance, then it needs building regs compliance.I guess the internal organisation of that entity and whether it’s maintenance or not maintenance on a major project, it sort of doesn’t come into their kind of thinking.

CHRIS BICKNELL It doesn’t come into theirs, but it comes into a lot of clients as it’s who actually owns this and who is actually being the responsible person for the sign offs and the compliance with the regulations.

ANDREW DE SILVA ‘DAS’ Yeah, one thing I’ll just pick up again, the proposal that I’m about to make today is an interesting one where there’s a block of residential, there’s 12 or 13 buildings within a little estate. Some are HRBs, some are not. The technical client is almost like a resident’s committee which have been created, but their skill set to be a client is quite limited in terms of all of these new regulations etc. The contractor who is going to do the work, and I think the committee got an estate agent to help advise on certain things. But that’s one of the issues, we’ve kind of been asked to do the BSA PD role by the contractor, but they may not be the client.

So, then there is that kind of technical issue about well, if you’re not appointed by the actual client, and then we can only be the advisor, you had to be the PD etc. So, there are some nuances and the kind of skill set of these client organisations, who may actually own 12 or so buildings on site, a couple of them are HRBs. But they don’t realise their duties themselves. So, there’s some very basic upskilling that’s still required across the board for residential care homes/hospital owners, before we get to any of the nitty gritty itself.

CHRIS BICKNELL But it’s further complicated if you’re in a housing association that has shared ownership because there’s a whole host of other owners, occupiers who have various rights with an other contracts that they’ve signed. So who is the client?

ANDREW DE SILVA ‘DAS’ Patrick, any similar experience or anything in that nature from your side?

PATRICK WILSON No, this is a different scale of operation, what you’ve been discussing. My interest continuing is both as a client leading a small project team in Wiltshire for some community-led housing. But also because of another community-led housing project that George knows about that was much larger. The only difference, a topic that hasn’t really come up, is I took part in a South-West regional group meeting online and most of the other, these are architects drawn a lot from the far South-West, so Dorset, Cornwall and Devon, and a few in Wiltshire. But the problems that they have in understanding what their roles should be on considerably smaller projects and the lack of understanding on part of the clients.

And this seems to be completely, it goes right the way back to Portland Place, that the guidance, their perception was the guidance that the RIBA have provided has focused, as always a constant occurring gripe, on larger practices and not for people that are operating at perhaps up to 10 people, and certainly not for micro practices. And there is complete confusion and a desperate need for better guidance in taking on the role of PDs, really at any level, whether it’s under the BSA or just CDM.

CHRIS BICKNELL Well, actually, Patrick, I’m meeting up with Chris Williamson in the next week or two, so if you’e got some particular points to make, drop me a note and I’ll take it up with him.

PATRICK WILSON Yeah, I will, I’ll go back to the individual that set this up in the regional office and try and pick up a recording from them. Because it’s actually generally quite a good thing to address the smaller practices.

ANDREW DE SILVA ‘DAS’ I think, Patrick, that you made a wise point because I don’t know whether it’s exactly true or not, but it’s something like 80-90% of architectural practices are sole or partnerships, for example. When I did the RIBA BSA PD course there was a lady called Keri Barr who was sort of representing the sole practitioner in the presentations. And I thought she was very clear in terms of, so I’m sure she’s happy to share her knowledge as well. And you’re right because the Building Safety Act’s competency requirements are obviously across every project, every sector and not many people know that either.

And a lot of contractors, even if they are Tier 1 or Tier 2 and you get smaller down, they are not necessarily able to demonstrate their competency. Especially if it’s like a D&B, for example, because they don’t have a design lead or capability. So, that’s also kind of problematic, I think, at the moment in terms of a client being able to say well, yes, we’ve appointed them, but actually we’re not 100% sure technically that they can demonstrate competence, we think they are. And that may take out quite a large chunks of contractors, for example. I did find Keri’s explanation of what she did on domestic projects, non HRBs, quite good and clear.

And in many ways it’s not different what architects should be doing or would be doing which is identifying the project, identifying the regulations that apply, ticking them all off and then moving forward. So, it’s more the process that she did just to kind of document that in a slightly more digital way if questions were asked or if evidence needed to be provided later on. So, that was the bottom line in terms of what she was presenting.

PATRICK WILSON I think probably what smaller practices need is the RIBA documentation and guidance is top heavy and geared for large projects and large practices. And my experience is that most contractors are still struggling with their duties under CDM, we’ve had those for long enough. The idea of anything that, even just protecting their own interests, quite apart from new requirements, to recording what they’ve done during the course of a contract, and recording it adequately and not changing things along the way. I think they’re completely ignorant and consider that this is something that just doesn’t apply to them.

And obviously there is a commercial pressure on smaller clients to cut corners and listen to a contractor that says we can provide you with an adequate service to deliver your building. Because we can build it, not because we can actually do anything that is now required. And so if it’s the difference between 200 or 220 thousand pounds everyone is going to follow the money and it only comes out in the wash much later on. And I think that there are aspects that we could be considering, you might consider that asset management of individual houses is a daft idea, but actually it shouldn’t be that difficult to demonstrate a commercial, an added premium value to a property anyway, even for things that are really quite small.

But we don’t try and do that because it sounds as though it’s a lot of work. But if we were to start on that route, it would certainly make deep retrofitting far more effective and realistic for people.

CHRIS BICKNELL To be honest, even talking lifecycle with individual domestic clients, when you get the message across is it's not about what it costs you, it’s what it costs you to own and how long you're going to be here, they start to think about things differently. I mean, the whole thing about lifecycles, thinking differently about the same questions, asking about the cost of ownership, not the cost of purchase.

PATRICK WILSON Yeah, it’s a different scale.

ANDREW DE SILVA ‘DAS’ It’s actually a different scale, but it applies to probably a much wider net than the HRB ones, in many ways, everyone’s individual homes and all the terraces that we have in the country etc. I actually do think that contractors have got a much harder thing to be able to do. For us designers to design to say that this design is compliant is easier than for contractors to demonstrate that they built it and it’s compliant. There’s so many more moving parts and so many more people that they have to manage and check and audit. Someone the other day talked about, historically there’s always been that comparison between car or airline manufacturing etc.

Whereas I think the idea of offsite manufacturing has always had certain pros and cons in case studies, but what was quite interesting about what the gentleman was saying is not necessarily that we should necessarily follow the airline industry in how they built things, but their checking process, they’ve have the 3-point checking onsite with different people double checking. In a similar way that we would in a practice have 3 points of check. Does that kind of thing get done onsite? Is that something that contractors are having to resource? Because that’s really again, I guess, George, you’re looking at that as well with the 360 capture on a timeline basis that you have to peel back.

So, maybe it’s the kind of auditing and checking process of the automobile/airline industry that we can maybe learn more from, without necessarily building onsite being the focus. Has anyone else got any thoughts or queries? Again, if anyone’s had any experience it would be really good to get more of that in the coming weeks. And I’ll share how I’m getting on in the two scenarios, one which is the existing HRB retrofit, and the external cladding project that some bidding hopefully will be starting in a month or two to see how that goes. I’ll definitely have two case studies that I’ll be looking to give you incremental updates on. But if anyone else has got anything that they don’t mind sharing, whether it’s a submission that went well, or things that didn’t go well.

And then what we’ll try and do is like the Miro board that I shared, the aim is to create a couple of different workflows to deal with these hopefully typical scenarios. One being let’s say the HRB archetype, one being re-cladding, one could be the more domestic scale projects and so on and so forth. So that again, it’s got as many people inputting it from their experience to hopefully give something that everyone can follow to try and ultimately reduce those times. Because it’s in our interest to make sure that projects are going forward because otherwise we’ve all got nothing to do. So, we need to do stuff to make it easier or easier for the BSR to get things ticked off. And really, part of what we’re trying to do in this community is to keep everyone employed and keep building things.

PAVITER PHULL I personally don’t have experience of this, but our team is looking at various aspects. The two themes that we’ve been talking about is the assurance of the design process, evidence of compliance would be quite interesting i.e. is there a from the route RIBA standardisation to the standards working to the standards working out? And the variance that you’ve got is can we do any automation? Can we do speeding up of how we gather evidence, how we do design coordination and assurance? And then the whole of life in mind i.e. the client has a duty of the Golden Thread. You might have different variations of what does that client look like who’s managing the Golden Thread. Not a lot of people have got understanding of that.

But how does the design merge into the Golden Thread? And then how do you do something called performance design, or variations of design, as you go along, to change control, change management? So that three themes are quite interesting and they’re quite tough. There are other organisations that are looking at regulatory compliance, automation. So, it’s just linking this group to what’s actually happening in the market place so that we have a consistent approach that nobody is doing the hard lifting together. if there’s a best practice or a best practice guide that you sort of talked about, or do we need one?

ANDREW DE SILVA ‘DAS’ George, there’s probably a couple of groups that you could link Paviter to in terms of the Golden Thread, because Paviter is from a CDM predominantly background. But working with Aracada on the Curzon Station and stuff, so a kind of big scale of infrastructure. I guess the only thing that I would say from a design point of view, I guess this is about taking it back to the basics of we tried to, for example, in our assemblies in the Revit try and build in compliance. So, for example, a Part M 43 bathroom, we’ve created versions which are compliant with the building regulations. So, we know that if you use those assemblies in our projects then they are compliant, so not having to start from scratch every single time that you do a resi scheme.

So, assemblies can be interesting, whether that’s an external envelope buildup, or a bathroom or a kitchen or bedroom, or train station or whatever it might be. And ultimately, the technical requirements of building regs haven’t changed, it’s more just that evidencing. We talked before a little bit about using the Autodesk software and using RFIs issues which are electronically you can keep a tab on the decision making. Which then again allows you, as a design team, to maintain that decision making audit trail. And then how those different design teams meet to create the one golden thread, or maybe it should be a golden rope because a rope is made up of lots of threads.

They’re the little things that we’re doing. I guess basics will be keeping notes and actions of all of the decision making and keeping an Excel RFI tracker of decisions, who made then and when it was made. So, it could be as simple as that, or more clever and automated and AI and all sorts of things. But just kind of got to step back and think basics and then what technology is out there that you’re already using, or could use, to make that more watertight.

GEORGE STEVENSON Pav and I are talking anyway and Pav has been a very active contribute to BIM In Asset Management. I should say that the 360 workshop that we’ve got next week, we’ve got about 35 people already signed up for it.

ANDREW DE SILVA ‘DAS’ On the chat there was a clerk of works, bring them back call. And in fact, funnily enough, we are seeing that on a residential scheme for a local authority. Not for HRBs, but the client has appointed a clerk of works…one thing is finding people who have got that level of experience to question what’s happening. I guess they can’t also be there all of the time either in terms of that construction period. I think some contractors are using almost package-based checking, auditing people within their own organisations who might be a specialist in precast facades, or whatever. They’re the kind of things that I’ve heard about that people are using to try and document or evidence to quality check things that are happening.

MATT TAYLOR The issues with the clerk of works, the last time I can recall active participation on a project with a clerk of works involved was probably about 2013, 2014. And whether that was in an official capacity or not, but that was the role that they were appointed by the principle contractor. And the problem was that to expect somebody to be an expert in all areas of the building works is perhaps unrealistic. I was working on development of the design of the dry lining package at the time, and the questions that were being asked were not really the questions that should have been asked.

So, we we’re being asked to justify bits and pieces that were justified quite easily by manufacturer’s information in terms of standard documentation, not relating to the fundamental design items that should have been justified. And were, but it wasn’t necessarily immediately clear unless you understood the design and detail. So, whilst I don’t think it’s a bad thing to bring back, I don’t agree that the clerk of works role should have ever been removed anyway. But I do feel that it needs to be, certainly in today’s climate, a lot more detailed. I think there needs to be individual package specialists that need to be saying what questions need to be raised. It’s still being left too much to manufacturers.

And just in relation to Pav’s comments, there is information that is available, both from specification stage, all the way through to construction, in terms of guides. I’m obviously more familiar with the dry lining and internal fit out versions, but there are, certainly our industry advisory body has specification guides. Pre-construction and construction-based guides that we’ve actually developed with them, and they are published to all of their members. So, there is information out there, it’s just at the moment I don’t know how well it’s being utilised throughout the industry.

ANDREW DE SILVA ‘DAS’ Yeah, and I think that role of the BSR PD, again in the tenders that I’ve been responding to have said something like your role is to check the design is compliant. But it’s not, that’s not the role of the BSR PD. And you’re then working on the weakest link, so that’s why I guess in a way nothing much has changed in terms of yes, you’ve got toe client as ultimately responsible for checking competency. And then the contractor is responsible for checking the competency of their subcontractors and so on and so forth. So, it’s that kind of weakest link, and each party ultimately has to be doing their own checks and balances to be able to sign those declarations at the end. So, it does rely heavily on that chain of command.

It’s a bit like the army, I guess. If everyone does their thing then everything will work and go in the right direction. So, I agree, the clerk of works or any other person who’s doing QA role, can only do so much. But then it does require everyone to make sure that they’re doing their bit correctly. That’s why I think it’s quite hard for contractors to be able to, at the end as a principle contractor, sign to say that we’ve built this building and it’s compliant. Because they’ve got to somehow be sure that it has, and that’s much hard that designing it to be compliant.

MATT TAYLOR But, in some cases, compliant with what? I mean, we’re looking at design intent that assumes that it’s going to be achievable. With tested arrangements, it never is. So, it’s a matter of the principle designer looking back on that and saying well, we’ve designed something, we’ve supplied an intent that’s not achievable with tested systems. But we’re happy to approve the level of risk from the information that’s been provided. And I think we talk about compliance too much as is it backed up by test information. And on that basis we assume that there is far more testing than there actually is to justify any of the stuff that’s being built.

So, I do agree that in a way there needs to be more focus on compliance, that’s always a good thing. But I think it’s also very important to be realistic about what compliance looks like, because at the moment there is a lot of misconception on that topic.

ANDREW DE SILVA ‘DAS’ Agreed, and I think that’s where how much can you bring forward in terms of those specialists, but before a Gateway 2 application procedure, let’s say. When it’s a non HRB that design during Stage 5 is still aneka?? 1hr 10mins theoretically. But on this re-clad project, for example, even though we’ll be starting from Stage 1, the agreement with the contractor is they will appoint for design input as well the actual manufacturer who’s going to be installing that cladding. And that’s as much as I think you actually can do to make sure that the design works within the parameters of installation, testing, data or whatever.

But I realise that that’s not always possible for every package and every level of that package in terms of design or delivery. That’s what we’re here to share, I guess, what the benefits are. I’ll continue to provide feedback on these two live projects and I think that’s where we will then be able to generate those Miro boards so that it’s not just talked about, we want to get actual output from these meetings. The Miro board I think is the best way to capture these workflows, any other ideas, please let us know. If you do look at the link that I sent in the chat, again, if there is any experience which is different to what we wrote, please do let us know. And you can comment on it using that password and then we’ll pick them up and review them incrementally.

Because the reality is that was a moment in time when we understood what we understood. And as things change we want to keep updating that, and I think the aim of this design group is to generate some more Miro boards for existing buildings and scenarios which are not covered in the more easier theoretical new build HRB process.

CHAT

P T Andrew de Silva (External) Yesterday 11:08 am

To: HRB-OPS-Policy <HRB-ops-policy@hse.gov.uk>
Subject: BCA application strategy for complex project

For other general BSR queries one must go through this Gov.uk portal / link:

Contact the Building Safety Regulator - GOV.UK

Freedom of information following a request on the 17th of February 2025:

• The average time between submission and approval for new build projects – 26 weeks
• The average time between submission and approval for existing projects – 24 weeks
• The average time between submission and rejection for new build projects – 18 weeks
• The average time between submission and rejection for existing projects – 15 weeks

Scenario:

• HRB block of flats, in which the local authority only has control over some of the properties, due to leaseholder agreements etc.,
• Internal insulation / secondary glazing works proposed to improve the thermal performance / EPC ratings,
• Works may only take 2/3 days to complete and ideally done while the tenants are in-situ – but maybe away on holiday i.e. not decanting them,
• Therefore, the works to complete works to all the flats in the blocks may take months / years to complete,

Feedback:

• One application for multiple apartments in one HRB is a viable strategy.
• Construction Control Plan / completion strategy – in relation for the works to commence within 3 years and when is 15% complete
• An architype approach maybe possible, but would need as a minimum floor plans for all levels, clearly identifying the location of the details to improve the thermal performance of external walls,
• Ultimately the Client / BSR PD / BSR PC has to be able to justify the works / information submitted are meeting / showing that the functional requirements of the building regulations

Contact the Building Safety Regulator - GOV.UK

Anyone in England or Wales can use this service to contact the Building Safety Regulator (BSR).

Brockett, Alastair (Unverified) Yesterday 12:02 pm

Bring back CoWs!

Chris Bicknell (External) Yesterday 12:07 pm

Agree - We always had that role on our projects - always delivered value in excess of the costs as direction of travel tested on regular basis rather than at end of project. As example on Gov refurb in excess of £1.5M the final account took 2 hours and project completed 3 months early under budget...

Paul Smith (psm@fairhursts.com) (External) Yesterday 12:11 pm

we’ve also had a CoW appointed on a non-HRB project. a particularly detail project, so more to do with QA as you say

Chris Bicknell (External) Yesterday 12:14 pm

BS8000 - a good start for site based workmanship and a framework..

Developed by HAPM as a workmanship checklist for site Audit many years ago.. (Still available on Amazon!)

Phull, Pav Singh (External) Yesterday 12:16 pm

Can I request that BIM4Housing could create a signposting location of guidance available.