RICHARD We’re going to go through some of the documents of Alan Oliver, he did a fire doors inspection document for the NHS which he’s now amended, along with help from various people in BIM4Housing, to be relevant for residential buildings. (shares screen). These are the key people who've actually contributed to this. The foreword is being written by a dignitary in the fire safety world, he wrote the foreword to the NHS document. Basically the guidance is divided into four: the first covers new installations of fire doors, so it’s very in-depth inspections; the second deals with those that are already installed, and again very in-depth inspections of those; section 3 deals with ongoing inspections, so given that they will have already had (whether in section 1 or 2) an in-depth inspection, section 3 inspections are a bit more light touch; section 4 deals with the fire door management system for maintenance and compliance.

GEORGE Just before we move off that, one of the things that has become very apparent is obviously with the new regulations the regulatory of inspections is increasing. I was talking with a fire engineer this morning and he was saying they’ve just completed some work on a hospital that’s been open for 12 years and they’ve identified in this last three months that there are 300 fire doors that are not acting as fire doors. So, in other words, they’re not in compartments and therefore for the last 12 years they’ve been maintaining and inspecting these as fire doors where they don’t need to. I think that’s quite a regular problem that happens, so to a great extent the point that team have made is that the initial inspection, the type 1 and 2 surveys, either for inspecting a brand new fire door and making sure that it’s fit for purpose to create that baseline, that is only every done once.

And then the type 3 surveys are the ones that get done regularly, and exactly the same with the existing fire doors. So again, that inspection is only done once to identify what it is and whether it’s the right thing for the right context, and then on an ongoing basis you’ve got the type 3 surveys. That’s something that I’ve learned over the last year or so as a layperson.

PAUL WHITE The issue at the moment is that everybody thinks they’re doing a type 3, but because of all the legacy stuff they’re actually doing a type 2. So until we get to the point where everybody has had a more recent type 2 then the type 3 is still irrelevant to an extent. So unless you’ve actually got a type 2 report sitting there, which if you don’t have that you need to get, then you can’t really move on to a type 3. It’s the same issue we’ve had with fire dampers is that people have been going around and saying they’ve been checking them, and actually they’ve not been doing a type 2, they’ve been doing a type 3 because they’ve assumed that everything is right. And it works and that’s all that they want to do, but actually they haven’t looked around the outside and realised that they’re not in the wall or something like that. At least it’s more obvious that the door, but that’s the issue.

GEORGE As I understand it fife door inspections are still not, although there is a number of different accreditation agencies and the like there is still no qualification per se, there is no requirement for the person that’s doing the inspection to be at any level. So this is an attempt, I think a very good one, to provide that sort of background and guidance for people to be able to do that. Sheldon, for example, one of the collaborators, they provided those examples there.

RICHARD Now looking at new fire doors, compliance. And then we go into a lot more detail looking at gaps and seals, hinges, locks and latches. The door closer, and other ironmongery, such as letter boxes, vision panels. So there is quite a bit of detail in here and this is all for type 1 inspections. Then type 2, which is about existing fire doors, but more complex. Looking at the absence of information. Again, various examples of things that are wrong. Type 3, as Paul said, these only come into play once type 1 or type 2 has been done. These are less onerous, but just as important.

GEORGE I think the important thing here as well, as I understand it there is no such thing as a simple check list, that’s why there is quite a lot of background on this, and also you’ve got to consider it inline with the fire strategy and other considerations.

RICHARD Looking at the different functionalities. And now the planning, it’s about creating a fire door management system that’s robust. And then, just the glossary. Quite a nice looking document we’ve got together there.

PAUL WHITE I think that looks very good. Perhaps the only thing, one of the things that I’ve been saying to people when they’re going to look at smoke control systems and fire damper systems which is a similar thing is where is last year’s report, where is the schedule, and I don’t know whether that’s mentioned in here. For instance, where is the type 1 report, where is the type 2 report and if you’ve got a management system then brilliant, but what’s changed and have things been fixed. Because one of the key things when you’re auditing something is you’ve been given this list last year and you only did something a week ago, you’d think that’s adequate. So look at whatever records exist and if there have been any intermediate things, a positive record is just as good as a negative record because it shows that somebody’s looked. It’s things like that, when you’re auditing you can have confidence in the management system.

RICHARD I think you’re absolutely right. When we did these roundtables I was charing section 4 on the management system and it was quite amazing, the other sections where relatively straightforward, but they all relied to a large extent on something in section 4. It was very much a question of well, should that be included in section 4 or is that something that is down to the inspector. And there was a little bit of ding-donging on that as which way to go. Another point, as with all BIM4Housing documents, they are dynamic, they’re never finished. Firstly because situations change and secondly because legislation changes or gets added to, but also because we’re always looking to dig deeper. So there will be quite a significant upgrade on this document in the not too distant future, we’ve had some great interesting input and ideas looking at the actual risk side of things, which is not hugely involved in this but is obviously relevant.

GEORGE The other thing is that the whole thing as to whether something is certificated, I’ve learned a lot about it. Essentially you might think that if you’ve got a certificate from a door manufacturer or for a door set then you’re sound, but actually that certification carries with it quite a lot of qualifications. So for example, we’ve been working on a project recently where we’ve been doing a deep dive into the fire door information, in fact all of the Regulation 38 information, and it’s quite shocking where the gaps are. For example, the fire door information, we initially struggled to even find in the handover information (this is in a new build) where the fire doors were installed, a fire door schedule. First of all, we struggled to get the door schedule. We got the door schedule, and fortunately the door schedules did correctly reference the drawings, but there was nothing…we then had to struggle to find what was actually installed. And we’re still struggling to find out the detail of who actually did the installation because the manufacturers detail, the one with warrant and fire information, that was from the blank manufacturer and the door manufacturer who had their doors tested, but they then went to a fabricator. It was the fabricator that put the doors together and therefore they were certified, they’re BM Trada, so there is a certification there. But because we don’t have a record of who installed them or who inspected that installation then it’s arguable whether any of the certification is valid. It’s that sort of thing, at a very simple level of the golden thread, that gets broken.

PAUL WHITE That’s what we see all the time. If you go to a building, and particularly if they’ve changed FM people, the FM people take everything away with them and throw it away because they think, well, we’ve lost the job, why should we make it easy for somebody else. That might sound a little bit harsh, but it’s absolutely true, and people don’t know how to put together Regulation 38 packages because, as you say, with the door it’s actually the whole kit, so it’s not just a bit of wood, it’s not the door blank, it’s anything that’s associated with it. And all of those things need to be listed to show you what the kit is and then that kit needs to be installed, each of those buts needs to be installed properly.

So, it makes fire dampers look relatively simple, but that is the point, there’s hundreds of buildings out there with no fire damper schedules, certainly no installation methods associated with that and none of them will be installed properly. So, you’ve got all those issues, I think they’re now starting to develop schedules of things because people are going around and doing inspections. It’s fairly obvious that a door is missing because you can’t get through a wall, but if somebody has not put in a fire damper where they should have done nobody is actually looking for that.

GEORGE David, I know Balfour Beatty have been doing a hell of a lot of this in terms of quality checking and all the rest of it, do you have something to contribute on this?

DAVID WRIGHT Not without it being subject to litigation. Unfortunately I’ve been rolling my eyes at the conversation because it’s exactly what we’re finding. I work in the post-construction aftercare area of the business and it’s disappointment that the Regulation 38 requirements for the data pack of fire compliance it’s as rare as rocking horse poo in some cases because it’s the last thing that people have handed over. I’m not just talking about Balfour Beatty, it’s just rife across the industry, projects we’ve inherited from contractors who’ve gone under, organisations that we’ve acquired. It’s a disappointing state of affairs to find out when we come to trying to find historical information it’s piecemeal and it’s painful to find. In a lot of cases it doesn’t exist, people don’t know where it is and it’s a disproportionate amount of effort just to find archived documentation.

Without wishing to be too down on the whole construction industry I think this new focus on golden thread in its simplistic objectives of having complete traceability of system design, design development, implementation, execution, validation and handing over to the client in a pack of information is long overdue. I think that this type of work that is being done is great, it needed to be done, it’s just disappointing that we find ourselves in this situation that we don’t have a lot of information about things. Looking forward simplistically we are trying instigate because of the difficulties we’ve encountered, for fire doors for example we now are specifying full door sets to be purchased and installed. Very nervous of when we get an installer procuring components and elements of fixtures and fittings and door leaves from a range of suppliers to suit their particular (generally financial) needs without realising that there are implications on the ability to validate and to substantiate what has been provided.

We’ve got a big push in putting forward certified tested, factory-built fire door sets being installed, that documentary record within our ITP documentation and processes being rapidly expanded. We’re doing it for fire alarm systems, emergency lighting, anything to do with active fire and smoke management systems. It has been and is being a big culture change in the way that we require our procurement, specification and site delivery to now operate. It’s what we’re doing now because of the lessons learned, in some respects it’s disappointing buT it’s what the industry, because of Grenfell, the Building Safety Act and Dame Judith Hackitt said and did and exposed and now legislated for us to do. It needs us to carry it forward and we’re doing it, it’s a process that’s painful and longwinded and one that we need to do.

GEORGE What was interesting about what you said there for me is that you used the word simple, and you’re quite right, I think people are looking at the golden thread in a rather simplistic way. Certainly I did when I started on this journey 3 or 4 years ago because I thought that you could have a specification for a product, let’s say a door set, and then a manufacturer who would then be providing that and then an installer that would be installing it.

Obviously there are people far me experienced than me on this who understand that the manufacturer is probably four manufacturers because you’ve got a manufacturer of the door blank, manufacturers of the door closers and the ironmongery and in most cases what happens is that the designers put together a specification that goes out to an organisation that is a fabricator. And it’s the fabricator that actually assembles the door set from a series of approved components from the individual manufacturers and that brings a level of complexity - it is a proper true supply chain. Jack, I think most of your work is on existing buildings that you’ve personally been doing, so you’ve not been touched so much by this. Lucy, do you have a view on this?

LUCY CRAIG Relating to is the golden thread achievable right now? Or relating to just generally?

GEORGE No, if we keep the focus just for the moment on fire doors. Not that fire doors are the be all and end all, at all, but it’s a very topical area and one that is causing a lot of people a lot of stress.

LUCY CRAIG I work very much in examples, but I was talking about something the other day where we’ve got a problem with one of our projects, as an example if you relate to competence and people making the right decisions along the chain of events. We’ve got an issue where there is a standardised riser door product that we’ve procured from a very well known riser door company that has smoke seals on it, but the fire strategy doesn’t want smoke seals on the door because detection is outside the door. But those procuring the product just procured the general product that was available from this manufacturer and as a consequence the fire strategy now doesn’t work. So, if you look at that as an overall issue, comprehensively as you go through the process with all of the interfaces and consequences of a product, we’ve provided an over-specced product that now compromises the fire strategy.

And it’s like at what point in time was that decision missed or changed? The golden thread, for example, might record all of those actions, but will it pick up the incompetencies on the way? Most people think if they’ve over-specced a product it’s a good thing, but actually in this instance it’s a bad thing. In my mind there’s really a lot of work to go to breakdown the design development of a project and making sure that every project has the right people involved in every element of the procurement of every item or the selection at the beginning, specification. Paul White, we’ve worked on a lot of projects and how many specs do you look at on our projects have got the specification writers have thrown the kitchen sink at what they want, but actually that doesn’t provide them with a safe system at the end of it.

And actually there is a whole raft of work done around competency and getting the right things for buildings that I think is really far away from being in a good place, so that makes that journey even harder. We can’t buy the design correctly at the moment, so we can’t ? 29mins 42secs build it or procure it.

GEORGE One of the things I’ve encountered with this is the specification is a far more complex document or set of information than most people realise until you actually look at one. Again, I’m speaking from my naive and non-expert perspective, but the specification for a door, that can run into 40-50 pages.

LUCY CRAIG Yeah, and invariably if you look at the detail of it it’s all quite bespoke to that projects needs. So actually then it’s very difficult to try and standardise something that satisfies all the nuances, whether it’s security acoustics, fire or whatever falls within it, it’s very challenging. But what you’ll find in the specs, there will just be generic clauses about BS’ of different standards.

GEORGE That’s the thing I find baffling because actually it’s a performance specification, typically, and as you say you’ve probably got references to dozens of British Standards and ISO standards and things like that. So the person who is actually reading that, I was looking at it in a simplistic way of saying, OK, you’re a maintenance organisation and you need to go and replace a door that’s been vandalised and obviously you want to do the right thing so you want to go back to the specification. You don’t want to just buy an identical product, even if you have the record of that identical product, because that may not have been satisfying the specification anyway. But let’s say it is, you go back to the specification and it’s incredibly difficult to actually interpret what that is.

LUCY CRAIG It’s covering the designer for anything that they might have forgotten without actually specifying anything in particular. I was trying to think when we were having this conversation the other day is that there is an element of there needs to be specialists involved earlier in the design process, but I don’t think right now door manufacturers would be wanting to get involved in projects and take responsibility for all of it. Because ultimately you’re requiring those specialists to come in early and consider all the things they wouldn’t normally consider like fire strategy, and make sure they interpret the acoustics of fire security and take responsibility for their selection. Whereas what normally happens is they just advise and then they expect the designer to know, but in reality the designer is just taking their word for it. So the process isn’t quite there yet and the desire for others to take that responsibility early maybe isn’t there.

GEORGE Just to reinforce what Lucy said, in conversation with architects who’ve shown me the specification that they’ve generated from NBS Chorus, I’ve asked them to explain to me what that specification actually means, and they’ve said I don’t know, because I’m not a specialist in fire doors or whatever. So therefore they’re using the specification, and I’m not saying this to be critical of the architect, it’s the fact that they don’t know enough about all of the detailed standards of fire doors, for example. What they’re doing is they’re relying (as Lucy just said) on the specialist to interpret that specification in the context of the fire plan and in the context of the other considerations and then come up with a solution.

LUCY CRAIG Which they have no liability for in the contract. So all they’ll be liable for is the order that they’ve placed, they’ve won’t be liable for the other elements that have made the decisions for why it’s there. So there is a gap.

PAUL WHITE In support of what Lucy is saying, actually there is very little point in having a specification because there is actually no design document. So because there is no actual design document nobody really knows and Lucy is absolutely right because one of the things I always ask is who is actually responsible for the design of this project and everybody looks over their shoulder. And everybody contractually is putting this selection and design problem further and further down the chain and what people need to realise is if the architect has drawn something that they want then surely the next person, which would probably be the consultant, then designs that and argues with the architect and says I’m sorry you can’t have a brown one in this instance because there’s not one that’s been fire tested, you’ve got to have a green one.

I know that’s a very simplistic example, but you can’t just write down a whole load of numbers and then just pass it down the chain because it’s too late, there is no design and it’s all being designed on the hoof and at the moment I’m not seeing anything changing. I don’t know whether on the HRBs, the gateway 2 is going to change this…I believe it has to, but I don’t know that the Regulator has got enough skills to know that the design is still not right. And even with the fire strategy, some of it doesn’t even mention fire doors to be fair, and a fire strategy, it will just say you need fire doors. And the whole thing, nobody is thinking about it at the right stage, it’s like everybody is very keen to start making stuff but nobody actually has a plan and a design to start from.

ALASTAIR BROCKETT The initial point I was going to make is in regards to you mentioned about fire doors being an assembly of components. It doesn’t have to be because the architect or whoever can actually specify a pre-hung door set. I remember quite a while ago discussing with my German colleagues about fire doors and when I described, at that time, fire doors being a procurement of a blank, a couple of lengths of 4 x2s, buying a packet of hinges, and the look in these guys eyes, they were incredulous - sorry, you do what?! I said yeah, that’s how we do it in GB, and over there they had an established market of pre-hung fire doors which were basically bought in a shrink pack and just placed in the opening in the wall and you then had a factory assembled frame door and it was just slotted in by a manufacturer recommended installer.

And the whole thing was then certified, it came with a certification document which could then be passed on to the client. Everything was done in the factory, the gaps were all pre-checked and it was all certified and signed-off and it was just then down to the site to put it in. It’s the same in this country, you can buy pre-hung fire door sets, so you’re point about buying a blank and buying bits of timber, hinges, and assembling a door, there are ways around that if the specification states that they use a pre-hung door set then that’s going to get around some of the problem.

GEORGE That’s actually the challenge that I’ve come across. The fabricator is a manufacturer, they are completing the complete door set in a factory. So they’re a manufacturer, it’s just that they’re not the original, they don’t manufacturer everything, and no manufacturer manufacturer’s everything.

ALASTAIR BROCKETT But the same point, if they have test and approval and even if they’ve go to the point of getting a door UKCA marked then under the AVCP system that they have. I’m referring to, for example, our own products, when we manufacturer sealants we have to have those raw materials supplied by certain factories, we can’t go shopping from month to month. Here’s an example, a few years ago there was a fire in a BASF factory from which we get one of our raw material components for our white mastic. We couldn’t shop around because of the restrictions of our CE marking and our ETA, we can’t just change, and so the manufacturers of these door sets, if they have an approval like a UK CE mark on the door, they’re restricted by their ABCP inspection system.

They can’t go shopping around and say we can get cheaper hinges elsewhere because of the approval which comes from the test is only for that particular set of hinges which they buy in. So from a specifiers point of view, the specifier says I’m only going to use a UKCA pre-hung door set, then he knows that whilst the manufacturer of the door set supplies that there is traceability on the hinges, on the ironmongery and all the way back.

GEORGE Absolutely. I’ve learned a huge amount more about doors than I ever really wanted to know, but it’s because every time I think I’ve got a handle on it another little window, another door opens. What there are, there are people like Halspan, or Distinction Doors who are part of our community, they either manufacture door blanks and also the frames and they’re the ones who pay Warringtonfire to have the tests certificates done. I’ve seen a 240 page document that goes through all of the tests that Warringtonfire carry out, these document are typically confidential because they don’t want their competitors to see how the tests have been done for their particular products.

They do supply them as a complete door set, but the majority of their business is through fabricators and it’s the fabricators, who also work from factories, who will then take the specification. So there are approved fabricators for Halspan and Halspan will then provide them with the detailed specification of what the tests were, what the approved products were, whoever the manufacturer of the door closers are. And then it will be up to the fabricator to look at the specification of that particular contract and they will then provide a completed door set that satisfies that specification. In that particular case they then have got approved installers. It probably isn’t the same with M&E, I imagine that relatively simple devices like dampers, you’d probably manufacturer the whole thing, wouldn’t you, Stephen?

STEPHEN GORE Yeah, typically if you’re making…typically actuators would probably be bought in, but the mechanical side of it is generally done by one manufacturer.

GEORGE Yeah, but an AOV, for example, SE Controls, for example, they’re a manufacturer but they are assembling products from different manufacturers.

PAUL WHITE But that’s the same thing, they’ve got their mechanical product that they put together and then they put an actuator on it, they’re just two pieces and there should be evidence that those two pieces have been tested together. And that’s the point, it’s the same thing as you’ve just described with the doors, you get this large amount of information but you can only put together this closer and this handle. And that’s the bit that gets missed because somebody just orders the blanks and then orders the handles separately and then puts them together onsite because they don’t realise the responsibility they’re taking.

GEORGE Yeah, I think that hopefully is now becoming less because people like Bex, for example, you require a certificate on every door, don’t you?

LUCY CRAIG The reason I was getting at is it’s not necessarily the competence of the supply chain necessarily to make something that they want to sell, it’s about the product onsite. Stephen Gore, if you provide a product onsite and you supply it to one of our MEP supply chain they’ll have a contractor purchase review, we’ll have a contract with them, but then the selection of that product can be variably quite…it’s not necessary always to designers, it kind of falls between two lines of responsibility of the trade or the designer and really it should be the designer. But if that isn’t fit for purpose in the location it has been installed, we’re not going to go off to you, Stephen, are we? We’re going to go after that installer and they’re going to go actually it should have been WSP or something and this is where it all falls down.

And then you go back to Paul White’s looked at WSP specs and WSP have the kitchen sink in the specification which doesn’t necessarily tell anyone what it wants. To make the Building Safety Act work the roles and responsibilities need to be clear and between every party involved and what they are liable for, and liability is an important thing here because it means that they are culpable for it, not they’ve just got their finger in the pie and it’s a bit muddied. And that needs to be consistent for all products and not varied, because you can’t have a trade contractor who is doing installation on the backend of a project selecting the damper products that may not fit with the system it’s preferred for.

Because that selection as an example, like doors, has other influences beyond just an isolated does it go on and off, there’s more to it. I’m identifying we’re not clear on the roles and responsibilities and certainly the building contracts like JCT aren’t helping things really because it’s just flipping risk without much thought and I don’t think the Building Safety Act really addresses that either.

ALASTAIR BROCKETT To pick up on Lucy’s point, my understanding of the Building Safety Act is that if you want to get through gateway 2 to allow you to put a spade in the ground then you’re going to have to convince the Building Safety Regulator that you’ve met all requirements, that you’ve got a compliant design. Now if he looks at a design and he sees a detail in the BIM model with just FDFDFD at the walls, he could be within his rights to turn around and say well, what type? What have you got in there? Have you specified something that’s CE marked? Or have you got something specified there that somebody is going to rock up to a little backstreet metal basher and procure something?

He may turn around and say I reject this application at gateway 2, do not pass go, do not collect £200, reapply again. And this is after taking three months struggling through the BIM design trying to figure out is this a compliant design. My understanding is that upfront specification and upfront detail really behoves the architect and the client to ensure that they’ve got that specification right and enough detail for the Building Safety Regulator to make his decision.

GEORGE I think one of the key things there is that the specification itself, we have to use slightly different terminology which certainly Lucy’s colleague Paul McSoley and Paul and Stephen Gore have been working on and that is the difference between a descriptive specification and a prescriptive specification. The prescriptive specification, my understanding is that that actually is what it is, it’s not how it’s going to perform, it’s actually clearer. Am I right, Paul?

PAUL WHITE Yes, if a product has a classification in theory as long as you buy the product with the correct classification to go in the correct substrate, you in theory can’t be wrong. Now the point is that a lot of different products will require different sized holes and things like that and slightly different installation methods, but you’re right, the classification would work. I think the short term issue with getting through gateway 2 is that if somebody waves one of these existing specifications at somebody and says I’ve put all of these standards in, then the Regulator is not necessarily going to be clever enough to realise that that isn’t enough.

GEORGE Can I just show people that may not be aware, because I got an architect to do this for me. (shares screen). This is a specification, this is simply putting a door in a wall. This is coming out of NBS Chorus, it’s 31 pages and this is going through the detail of the wall. Now, this is the operations group so would an FM manager that has to replace a door, how are they going to interpret all of this? I don’t think it’s possible.

PAUL WHITE I think that’s the point, George, this is a kitchen sink specification of the nth degree, the point is it’s meaningless because there is way too much information. And this is the problem in terms of an FM manufacturer going to replace a door, unfortunately they’re going to have to find an expert because they’re going to have to consider everything and specify the correct door because at that point they have a design responsibility. What we’re seeing is that most people don’t realise the level of responsibility they’re taking by just changing things and I don’t think they realise the responsibility they’re taking by not fixing things, but because they have no experience of it.

GEORGE But, for example, you’ve got a housing association that’s got a particular problem where a tenant, the entrance door to their flat’s been smashed in so the asset team have got to make it good as quickly as possible. They can obviously put something temporary in there to provide some sort of security, but it’s not the case that they’d be able to so easily go back to the original supplier. It seems to me to be a quite complex thing.

PAUL WHITE This is your chicken and egg situation where you’re absolutely right, at the moment it’s impossible. So therefore you’ve got to find somebody who is a designer who’s got to go and look at that and do it properly. Hopefully going ahead with the golden thread they’ll just be able to go, oh, it’s one of these doors and then they go and buy one and then put it in. And this is the whole issue that we’ve got at the moment is that everything has been let go so far that it’s impossible to do it without using some sort of expert who is capable and competent of actually making a correct design decision.

ALASTAIR BROCKETT That specification you put up, whilst the stuff that we’re involved with doesn’t venture into that level of detail, just as an example the other day a specialist contractor came to me and gave me a specification: I need a 60 minute fire stop product that’s going to give me 45 db that’s going to be able to use this and it’s one-sided installation etc. I replied with you need this product, this is what you need and that fulfils all of that specification. So, whilst that specification, it’s a different kind fo filed describing timbers etc, a prescriptive specification can potentially cut through all of that by saying I need one of these and that’s it. It goes back to the point you made earlier, Paul, a specifier or designer will have a list of prerequisites or parameters in terms of what a particular application needs to meet in terms of performance from various other approved document requirements. And for some manufacturers they will have enough detail to be the expert to say actually we’ve got something that ticks all of those boxes, if you specify this thing, particularly by name, this will meet all of your requirements.

GEORGE I absolutely agree and I think it’s that intermediary step that we’ve got to figure a way of doing, arriving at that prescriptive specification. And I think that’s really what the Building Safety Act and the gateways and gateway 2 is actually requiring. Understandably designers have been concerned about doing that because if they are prescriptive then that could be causing them problems with the procurement rules (particularly EU). But I think we’re overriding that now where products do have to be selected, and quite frankly if they’re not selected by gateway 2 the organisation has got a real problem. And the change control process requires them to, particularly on safety critical products, need 6-8 weeks for an approval. You’ve got to inform the Regulator of changing out, for example, Swegon’s dampers.

PAUL WHITE I think one of the issues that lies with that is you’re right, some of these things are major changes and some of these things are notifiable changes. The notifiable changes mean you tell somebody and then nobody picks it up until the end and realises actually it was a major change. I’m not sure that that’s going to solve the problem, it still comes down to if the design is right to start with then you can build the building quickly and if it isn’t you’re going to get held up all along the line.

GEORGE We’ve got a couple of things happening next week and the week after that I wanted to make you aware of. Firstly, these are questions that came up in the summer exactly from what we’ve just been talking about there: how do we prevent the incorrect design selection and installation of fire safety products. We had the workshops, we’ve produced a document from the suggestions that people have made. This is the next question: how do we make sure that the asset information continues through the process. Also, how do we make sure that the safety case information is not just a snapshot in time, that it’s a building safety management system.

And also how do we ensure that the contractor design portion, meaning that M&E gets done after all the partitioning is installed. We produced this document which is the summary of that work, so these are the contributions that people have made which has been quite well received. Next week we’ve got 2 sessions of new people looking at these as well, we’ve got between 20-30 people on each of those sessions. The purpose of this is to flush this out because these are the questions that we’ve been talking about this morning. So if you’re not already engaged in that let us know and you can join.

RICHARD Two of them are on the 6th of December and two of them are on the 14th December. Put in the chat that you’re interested and which question and we’ll get you out an invite.

GEORGE Also if you’ve any suggestions as to how best we can disseminate that information. We’re going to send it back to the HSE and DLUHC so that they can see the observations and thoughts that are coming out of the community. But if you’ve got any suggestions as to how we get that out that would be appreciated.

RICHARD Yeah, and as George mentioned that, watch this space next week. Wednesday, you may see something quite interesting.

GEORGE (shares screen).If I also show you, this is the work in progress that has been done. This is coming out of healthcare, the NHS, but it’s the same sort of format, but this time it’s for fire dampers, fire stopping, cavity barriers. We’re being given the opportunity of doing the same for residential products. Would you agree this is really good stuff?

STEPHEN GORE I can give you some better pictures of dampers.

GEORGE Absolutely. I’m going to make this available to you because what we actually want is something in context because you sending me some photographs of dampers isn’t going to help me at all. But if you’ve got something that is contextual that would be fantastic. And if anyone else has some suggestions, this is a work in progress but it’s being shared with us because the people who are authoring it have been impressed with the work that we’ve done on the fire doors.

PAUL WHITE I went fairly comprehensively through the draft, but I don’t know whether the pictures are relevant necessarily.

GEORGE Do we want to pick up on what we did last week? Richard, do you want to explain what happened at the event?

RICHARD We had a big event last week which some of you came to, with a distinguished panel including George, Chris Waterman who advises members of the DLUHC committee, Dave Williams and Howard Hall. We started off the process a couple of months ago with four questions which became five, during meetings questions were refined and added to and we’ve now got seven questions which we went through at the meeting. We’re going to be producing a document with an insane amount of input so it will take quite a while to produce. During the meeting we got through three or four of the questions, so I don’t know if it’s worth having a quick run through of what we didn’t get through at the meeting today.

Let’s look at question 5, this was for the HSE and BSR. The definition of a higher-risk building is different from the construction phase to the operational phase. This creates complexity with the golden thread information gathered during the construction phase as it is not always relevant to the operational phase leading to more complex document and data structures. It’s too early to tell how challenging this might be, however has this issue been considered as part of the definition process? Has anybody got any views on that question?

GEORGE Mustafa, you’re with Clarion. I just wondered, are you still working with Jack on the existing stuff?


GEORGE So, would you have a view on the way existing buildings are being considered as HRBs? Because it’s not just the height of the building, it’s also how the building is being used.

MUSTAFA ALHASHIMI To be fair, it is the height of the building, I don’t even understand this question. How is it going to be different from construction to operational phase? The height of the building does not change during the construction phase, there is planning and design before that.

GEORGE Yeah, higher-risk building isn’t simply the height of the building though, is it? An HRB, there’s a number of different definitions.

PAUL WHITE I think it has to have residential, but the point is that statement doesn’t seem right to me either and I think that’s Mustafa’s point. Can we see the two definitions? Because I can’t understand why they would be different.

STEPHEN GORE Aren’t there some buildings that are considered HRBs in construction but not operations? I think hospitals are one of them, if they meet the height and some of the other requirements.

PAUL WHITE I now hospitals count as HRBs, but I don’t know why they would be different in construction to operation.

STEPHEN GORE I don’t, but I think it was something that came up in some training with HAL the other day, they sat under one but not the other.

GEORGE We didn’t write the question, it actually came out of one of the working groups.

PAUL WHITE I think it would be worth actually stating what the two definitions were next to that question so that we might understand the question a bit better.

RICHARD Yeah, because if you’re not understanding it the HSE and the BSP are not going to understand it, probably.

GEORGE OK, I think we need to track down where that question originated from, Richard.

RICHARD I’m not sure the next one is actually relevant here. The secondary legislation brought in different categories of work: Category A, Category B and scheme and exempt works. Category A works are subject to the building control approval, as are some Category B. Anything that is not Category A is Category B, unless it’s scheme or exempt works. This is not very clear. Likewise, when remedial works are carried out on an existing building, does this ‘flip’ the building from existing building status? Is there further guidance to clarify this?

GEORGE Yeah, it’s almost tied in to the previous question.

RICHARD Is it? This is more about, the second part of the question is about…obviously if it flips from being an existing building then that is more onerous. In a couple of the meetings, this was a very big point because nobody had a clue.

STEPHEN GORE I’ve just found some notes, going back to question 5. Hospitals that meet the requirements of HRBs are HRBs through construction, but not operations because they then fall under work place regulation and the health and social care regulation. Hospitals and care homes I think, if they meet the requirements of an HRB they are an HRB in construction, but not in operation because they then fall under a different regulation.

PAUL WHITE From our point of view it still means that during construction they’ve got to meet all rules an HRB would.

GEORGE So care homes, for example, are very relevant for a lot of our members.

PAUL WHITE We’re about to introduce quite a lot of information in 9991 on that…George, right at the very beginning you mentioned something about risk.

RICHARD I mentioned about risk in terms of including it in the fire doors guidance.

PAUL WHITE Just a philosophical point. I think we need some means of risk assessing these, I think it’s very building specific and it’s very space specific and I’m very worried about putting out anything that’s generic because guess what, it will just be used without any consideration.

RICHARD This is why we didn’t initially include it. We tried to keep it very much down to the inspection and the inspection regimen, rather than going to deep end or off at a tangent. But we have been discussing this with a number of quite significant people in that field and I think we’ve arrived at a place where we can do it generically but flexibly, if that makes sense.

PAUL WHITE Yeah, I’m still concerned that basically you’ll get your fire damper test inspection report and right at the bottom it will say whatever you said in this document which says something along the lines of because of this, that and the other this is all right. And the point is this will just become a standard clause that everybody will put in their report so they don’t have to do anything. So, just be really careful. Unless this is underwritten by a chartered engineer or something like that I think you need to be very careful because people will just use it because somebody has written it down once and that’s it, and nobody will do anything. Potentially people aren’t assessing the risk, they’re just falling behind something that somebody said.

RICHARD I actually agree with you. Everybody remember if you’re interested in any of those questions happening on the 6th and the 14th then put your name in the chat.


Dave Williams

The roadmap is quite interesting (and possibly overly ambitious).Building Safety Regulator Strategic Plan 2023-2026 (