BIM4Housing Operations Working Group Meeting 31-03-2023
ALEX OLDMAN I’m the team leader of the Operations group, I work for Civica, we’re a software provider for social housing, amongst other things.
STEPHEN GORE I’m compliance manager for Swegon UK, so my background is fire safety. We have BIM models already. I was involved with BIM back in 2011 with the CIBSE/BIM steering group, after Paul Morell’s famous presentation which was the whole thing about government projects over £5 million using Level 2 BIM. And then either through Paul White or Paul McSoley I’ve ended up in this group.
ALEX OLDMAN Welcome to meeting 2 for BIM4housing Operations. What I want to do is two things, first of all just share with you news from the world that I operate in, which isn’t necessarily the same as the worlds that you operate in. (shares screen). A couple of things I wanted to mention from a sort of general industry new scanning perspective. The world I’m coming from is that of social housing/asset management, looking at what’s happening in the industry, then we’ll focus specifically on the areas that we’re interested in; golden thread, information models etc. The first thing is we’ve got a new minister in charge of the Department for Levelling Up, Community and Housing, Mr. Michael Gove. He’s now going to require qualifications. So, the suggestion is that using the framework of the forthcoming regulation of social housing (what is a bill at the moment) they’re going to require executive directors, board members, managers and senior managers in organisations to achieve professional qualifications.
Quite what that means, nobody is quite sure, but I’ve rushed off and become a member of the Chartered Institute of Housing in the last 3 weeks on the off chance that they might be able to help me with some qualifications along the way. The regulation of social housing bill will just be for social housing, not for private landlords, but it will be through that framework that it’s delivered. And the idea is targeting local authorities and housing associations in the provision of social housing with that requirement. So, Level 3 and Level 4 qualifications are going to be required. Again, we’re not quite sure what qualifications, but as long as we’re qualified it’s OK. So, I think the devil is in the detail at this point, but the idea is to make sure that we’re moving towards professional standards. I do like this idea because if we equate what’s happening here with, say, the world of finance, you can’t talk finance unless you’re talking to an independent financial advisor, or somebody who’s qualified with the relevant knowledge. And so if we’re talking about that as a building safety/fire safety, the provision of services generally for good quality of housing in the UK, then I think this can only be a god thing that we’re going to be working to common standards (even if it’s a low standard at the beginning.
Next up is a merger. This is particularly interesting because now is not a good time to be merging, for a variety of different reasons, but Sovereign and Network Homes is coming together to form a potentially 82,000 home organisation. That’s against the backdrop of several other mergers having been attempted in the last 6 months that have either stalled or bumped along the bottom before making tremendous progress. Also, the financing of the merger is more difficult, but perhaps organisations are seeking greater efficiencies by moving to larger scales. So, this in itself brings together some interesting ideas about what we do from a data perspective, this merged organisation, how might they exchange data. I think that’s common to the sort of information standards that we might be interested in talking about here, and just generally about the portability of data in our sector, because everything is very bespoke, perhaps to an individual project, let alone within an organisation within a social landlord.
This is another Gove initiative, in England and Wales Gove is rattling people’s sabres, especially developers, trying to get developers to agree to remediate problems on buildings, signing up to some sort of pact or accord to say that they’re going to be responsible for remediation of problems that have occurred. I’m not going to name and shame the organisations that have not signed up at the moment, several have indicated that they are intending to sign, but haven’t signed by the deadlines which were mid-March. The carrot is sign up and it will be good for you, the stick is if you don’t then you won’t be winning new development activity for social housing in the UK, so they’re going to stop the award of contracts to these organisations. Generally speaking, Mr. Gove’s arrival at the Department of Levelling Up has had a bit of a gear change for the industry and he’s certainly coming at it hard compared with some of his predecessors. However your politics may play, I think that’s only good for the sector, and I’m not saying I’m a Gove fan at all (unless he’s on the call, then in which case ‘Hello, Mr.Gove’).
The last thing I wanted to mention was next week the new register for buildings is going to be officially opened and the process by which data is going to be required to register buildings with the new regulator is a process starting in April and running through until October. So, from an information standards and governance perspective we need to be aware that organisations, Housing Associations and Local Authorities are going to need to be lodging sets of information with the regulator. Obviously there have been those that that have gone through the pilot process already, so they may have established those data requirements, but we're going to look out for some further guidance popping out early next week to talk. It may already be published this week, but I might have missed it, about what information is required to sign up for this register for the deadline which is now the 1st of October.
So, those the key points that I wanted to talk about, that’s just setting the scene a little bit. I’ll also mention that we’ve started the conference season, so there has been some conferences taking place and I wonder what activities you’re particularly involved with professionally within your organisations, what initiatives you've taken since the last time we met, and anything else that we need to be aware of that people might want to report about.
MIKE I had the privilege of attending the BSR conference last week, so I thought it would be good to give you some feedback from that, which aligns with many of the things you've just talked about, Alex, to be honest. So, competency again was very much picked on across the sector as a whole. Interestingly, one of the things that they will be looking at Gateway 2 applications will be the assessment of competencies of individuals submitting applications, so very much seeking to further emphasise the importance of the right people having made the right decisions. I think similar to what you just said, they weren't clear on what was required. They weren't stipulating any requirements, they were just saying you must demonstrate that you are competent. And that was a regular theme across the whole of the event was they weren’t looking to tell you what to do, they were looking to say you have to demonstrate that you've done the right thing. Initially I though that sounded very much like they’re not going to help you, but I think what they're specifically saying is we're the professionals, we're the competent people with the knowledge, we’ve got to demonstrate the right information to demonstrate that we're doing our jobs correctly.
ALEX OLDMAN Just reflecting back on that, I think that reflects well on the way that the Health and Safety Executive have been communicating the process going through the Gateways with the regulator about making it not prescribing what they're expected to see from us, but sort of letting us imagine what the standards might be.
GEORGE I think that also reflects what we've been doing over the last couple of years with the Golden Thread Initiative, because…if, for example, we ask Alistair to tell us what information is needed for some of the elements that he's an expert in, and then we get three or four other people in the room, we’ll find that there's different views. And therefore that's part of the challenge really, it’s down to the context in which something's being considered as to what information you need to know about it. And I think that that is a really important part of what this golden thread process needs to be. And I must admit I'm becoming a little bit, was talking with Andrew on Wednesday and there seems to be a view, and I think it’s understandable because everybody is under so much pressure, that as long as we’ve got a document in an electronic folder in the cloud somewhere that actually we've got it all sorted and the regulator is going to be happy with that.
MIKE Yeah, that was exactly what they were saying, and they didn't really give a monkeys where it was or what it was or how you were holding it. They just said as long as you can provide us with that information, that’s enough.
GEORGE But the question really, Mike, is what information. So, for example, I’m working through at the moment helping one of the councils and we’ve been going through the information they’ve got, and they’ve got quite a lot of good information, they’ve got their EWS reports done, they’ve got fire risk assessments done and a building safety case done as well. But when I then look at them, they're not at all aligned. So the scenarios that are being suggested in the EWS document are quite different to the ones that are in the building safety case.
MIKE And that’s really interesting to hear because, again, the feedback that was also provided was that since Gateway 1 has been applied to the planning applications, and obviously that’s been running for a while now. They said 56% of applications that have been submitted have had feedback from the regulator at this point already in those early stages and the vast majority of that feedback has been inconsistency in information that's being provided.
GEORGE That’s helpful. Obviously at one end of the scale we’ve got having a full digital twin, everything is interconnected and all that sort of stuff (I have to say, I’ve not yet seen one). The other end of the scale is just some electronic folders with PDFs in them. I think somewhere in the middle is probably where we need to get to, we won’t be able to do it immediately. Some RPs are further down that track than others. Kelly, for example, you’ve been doing a huge amount of work in that area, so you’ve probably got your information in quite a complete way, whereas other people are just starting on that journey. What’s concerning me at the moment is that people are sort of expecting that the regulator…and that’s the other confusion, but the way, there are two regulators. There’s the fire regulator and there’s the building safety regulator, both of which are asking for different levels of detail.
The thing is it’s not just a matter of getting through the approval because what's the likelihood of them actually turning down a safety case report and therefore putting people out on the street, as it were. The point is, if something happens then people are going to want to go into much more detail. There’s going to be a lot more forensic analysis to try and assign blame if an incident happens, and therefore I think we need to have an environment in place whereby the information that the specialists that we've been working with over the last couple of years, they're the ones that are probably going to be called in as expert witnesses to see whether housing associations and councils have actually done as much as they could have done to make the building safe.
ANDREW HOLLEY I just want to throw in this thing about inconsistencies, and I think it's important that we understand how the building regulator is going to look at things. It's right that an EWS assessment is different from a PAS 998O assessment is different from a fire risk assessment, because they are each got a defined way of working. The PAS is literally this is how you will do it, for the internal/external, so something like a PAS tends to combine a lot of things and look at it in a larger sense, but it’s still constrained by the way the PAS is written, you will write it like this and you will do that. I'm being trained by the CIOB as a building safety manager and actually the guys doing the course are extremely good.
The biggest thing I take from that overall, and this is solving the problem and seeing the picture the way the regulator is going to see it, which is the biggest thing to think of is your building is a system overall. Don’t think of it as, well, I’ve got a fire alarm panel certificate, I’ve got an EWS1 certificate, there you are Mr. Regulator, everything must be fine because all these certificates say they're fine because they interact, which is what we’ve been hearing about. Things like are the dampers in the right wall. Well, the walls fine, the dampers fine, but you put the two together and they don’t work. George and I were talking about, and it made me think about a repair that’s happening on one of my buildings where because of safety reasons someone wants to turn the front door round so it opens outwards, not inwards. I thought, actually, does that affect the AOV, is it how the air comes into the building, I’ll have to check that.
The point is the overall thing of thinking of the whole building as a system which has a series of products that work together, I think that’s the biggest thing to think of when we’re looking at these things together.
GEORGE That’s very helpful to me. That’s the way I’ve come out of the last couple of years. If you’re actually going to look at dampers you’ve got to look at it in the context of where they are and what they’re doing. And therefore just having a certificate to say that Swegon have provided an approved item and it’s been installed by somebody that's competent, does that really tell you in 5 years time that that’s the right thing. The other thing, I was talking to a fire risk assessor yesterday and he was saying that the challenge is that the fire risk assessment, the day after it’s been done, if some of the key assets in there fail…the fire risk assessment needs to be an ongoing thing. And that's true of the building safety case. So, the report itself is just a snapshot in time, but it's in place for five years perhaps.
ALASTAIR BROCKETT It’s the same with a car MOT. Everything is checked out and as soon as you leave the garage you hit a pothole and it effects your steering and you carry on for the next year until the MOT and the MOT says, mate, you’ve been driving a deathtrap for the last year because your steering has been damaged. You’re right about the fact that the fire risk assessment certificate is a snapshot in time, unfortunately it’s the best that we’ve got, and hopefully people will, like with a car, if you feel there’s something wrong with it you think I need to get this checked out. Hopefully people who are maintaining buildings don’t just do the once a year thing that they act on reports, even reports that maybe the residents are saying that there’s something not working here, an alarm keeps going off at 2 o’clock in the morning. Those are the obvious things, but even things like the fire door on floor 5 in the corridor keeps sticking, could someone see about this. It should be, in an ideal world, an ongoing system and, as Andrew just said, the buildings are a system and part of that system are the people who actually occupy the building, that everyone kind of has a responsibility. On the London Underground, if you see something, report it.
That, to a certain extent, maybe even the occupants have a duty of care to help in the running of the building. Let’s face it, we’re all human, we all have bad days and poor memories, and there’s things that fall in between the cracks. It’s down to the old adage, communication, working together, and hopefully then you reduce the probability of risks, of hazards. So, you’re right about the fire certificate, it is like an MOT, a snapshot, and it has to be addressed.
KELLY LEE I’ve got a question to throw out, actually. With regards to the system, yes, the building is a system, and I think it is around the good management of the building. We’ve already defined our golden thread, our asset information, done our modelling and are on that journey. What we’re doing at the moment is writing a in occupation golden thread management plan and I think that's what is going to support how we effectively manage our buildings. So, we are creating that on the basis of BS 9997 which is obviously what we're accredited to and helped us towards defining our safety case report and how we wanted to present that. And also it's going to incorporate all of those kind of changes to the building. So we've looked at the wider business and we've gone out and spoken to the whole business. So it's not just defining our asset information, it's how the business impacts that asset information. So we are putting together a document on how every department has an impact on the building, all the way from finance, not setting the correct budgets or allowing the right money, through to our IT teams who make changes in our system that will actually affect the data in our system, kind of removing parameters, adding parameters in.
So, putting all those kind of bits together, like our voids team going in and potentially changing things without informing us. So we're kind of creating this document that brings all of that understanding that the building is a system and we need to know everything. But one of the interesting things that have actually come up for us, so kind of throwing this out, we have a building where we're not the freeholder, but we're ultimately responsible because we've got a full repairing lease and we’re obviously trying to define the PAPAP’s within the building. We additionally have a managing agent that looks after an element of repair of the building, but the owner of the building is actually a church and they have no responsibility at all for communal repairs. Their church is part of our 18 metre building, however we've gone to a solicitor and in law in the Building Safety Act, they are not an AP because they have no responsibility for any communal repairs.
Now, we’ve challenged that obviously. We've actually had a meeting with the regulator to have a discussion around this because we're like the whole point of the Building Safety Act was so that all parties have a responsibility and it works as a system and you have those discussions. But actually we have got a party that could have a major impact, but because we have to classify them as a commercial unit, they're not an AP. They've got the normal landlord and tenant act, we can take action like that, but my concern is that we're going to have lots of buildings that are going to have commercial assets in them and they're not responsible under the Act. I'm really confused by that and i don’t know as a collective what we can do about it. We've had some conversations around the secondary legislation and they're still saying that commercial assets will sit outside of this. I just don't know if anybody else has had any legal advice or any thoughts on this, but it's kind of quite shocked me really.
GARETH FLETCHER We haven’t had some legal advice, but I’ve got some thoughts on it. There’s a difference between a building system and a different system within another industry as in the building system is very uncontrolled. You’re not gonna have full control over the environment, like you just mentioned with the church. I think there’s two things to consider is what is the impact of not having that control of a church, maybe it’s on your risk assessment, so how does that impact your fire risk assessment, your structural surveys. Trying to capture that within your system risk analysis, so things like the hazard or bow ties, and potentially what controls you could put in place around that, any service or maintenance you can do around the area. But I think it’s mainly understanding the impact of the uncontrolled areas of your system.
ANDREW HOLLEY as I see it there sounds like there’s 3 parts. There’s you, there’s the church as the owner, and there’s the church as the user of the commercial area. So, as owner they are just a financial owner, so they might be accountable because they might finance the work you do. So, there’s some link there, but you’re probably the principal accountable person because your job is to look after the building. I believe that the definition comes in is about how much control or influence they have. So, if they’re just the owner and go I hand it all over to you, they have very little control, therefore you’re the person with the control. So, it’s all about who has control and who can influence any safety issues. That covers them as owner, but when they are user of a commercial unit, even if it’s the same people (think of them as a separate person), the users of the building as part of the church, we’ve got buildings like that where we’ve got community centres used by other people. We ask them for their fire risk assessment and equally where we’ve got leased out ones, those housing associations are asking us for our links. So, I think you have to then work together, and that’s the point. It’s about proportion, so how much is their work or their activities proportionally affecting the building.
Effectively all our tenants and leaseholders in a building are also technically really appointable personal because they can effect how the building is, which is why we try and get control back by making sure that they do what they’re supposed to do, and we make sure that all our leaseholders know what to do in a fire, how to report it, they’re our eyes and ears in our own building. So, it’s all about getting them to understand that they are responsible. It’s tricky, but you have to give them responsibility for the areas they’re in, I suppose. They can’t dodge out of it, as owner maybe they could, but not as a user of the building.
KELLY LEE I’m totally ? 36mins 10secs with us having working relationships and understanding what they do, what we do, making sure that we have the right information in place. It’s just not what I expected that we would have people that have a large interest in the building that we couldn’t define as an AP, because that puts more onus on them that they have to understand their responsibilities within the Act rather than us potentially taking action against them through different regulations, rather than say the regulator looking at them, it’s just the responsibility of looking at us. It just seems a bit wrong, to me. I get the change in here is having that working relationship with everybody, I don’t have a concern with that, it’s just there should be that responsibility within the law on everybody that takes over part of that building. It includes customers, I totally get that, but when you’ve got somebody that’s potentially creating kind of a risk. A church, to me, is kind of a risk, underneath an 18 metre plus building. It just seems a bit weird they’re not bound by the same law as we’re going to be.
DAVE WILLIAMS I put a couple of things in the chat, because we’ve got some buildings with British Land where one of them in particular, we have responsibility for the internal communal areas, but they have responsibility for the external structure. So as far as we're concerned they're the principal accountable person. Whether they're going to agree with…we’re making sure we've got every legal document that we can possibly find and to make that point. But funnily enough, two adjacent buildings, we actually have responsibility for the external structure as well. So we consider ourselves a principal accountable person. Having said that, we can't actually make any changes to the structure without getting the OK from them. So it's quite weird, but it is what it is.
But the other thing is, even given that in some cases, but not the principal of accountable person, we still have to contribute to the safety case and to safety case report because they will be relying on us an accountable person from the perspective of claims, argued and evidence to provide them with the bits that we’re responsible for correctly. So we still don’t get away with just going, hey, we don’t have anything to do with the safety case report because we’re not the principal accountable person. As an accountable person we are still going to be responsible for elements. As an example of that we have a high-risk building which is part of a football stadium, so the principal accountable person who is responsible for the structure is actually the football club, but there is no way that football club will have any idea of how to do a safety case or get the evidence together and create the safety case report.
So in actual fact we’ve done all of that work. We’ve done the structural surveys, the fire surveys, the engineers reports, put together where all the information is on the building, ostensibly written a safety case report and will be managing the safety case because 99.9% of the data is within our domain, but still in theory we’re not going to be the principal accountable person because the football club manages the external structure of that building because it is part of the stadium. So, I agree with everyone that said that it isn’t a clear black and white line between a principal accountable person and an accountable person. It’s very much looking at what your original leases were where those responsibilities lie and then convincing the other party that they need to take on that role. But also I’ve included a link there https://buildingsafety.campaign.gov.uk/prepare-to-register-your-building/.In there, it does have a brief blurb about the difference between accountable and principal accountable persons.
GEORGE I was just going to ask what people’s perception is of the responsibility and the accountability and the liability that’s coming out of this, because obviously the whole point about the Building Safety Act was to take it away from a situation where people could just pass the parcel. The original idea was that it was going to be a named person that was going to be responsible, and that now seems to have changed to being the organisation can be accountable. I don’t think it’s necessary now to have it as an individual. I can understand the logic of that because obviously, even if somebody like the chief executive or director of asset management or something like that of an RP, what happens when that person moves? Where does the liability sit for something that was delivered during the previous person’s tenure? How do you actually go through and ensure that the new person that’s coming in knows what type of liability they were taking on?
I was talking about this with Andrew the other day obviously they’ve changed the building safety manager’s role as a formal role. What Andrew said was the principal accountable person is probably a senior person but they then delegate the responsibility down to technical people, and those technical people may well then delegate the responsibility out to consultants who have advised them. So, it seems to me that the line of responsibility doesn't seem to be there. What would you say, Paul? You’re involved in this from the CROSS perspective, do you think it’s clear?
PAUL BRAY …I don’t believe it’s as clear as it should be, the whole definition of a principal person is something that’s up for conjecture. I’m hoping that the regulator will make it clearer as we get closer to October. Let’s not wait until October before it gets clear. My original understanding of the term principal accountable person was as such when there is more than one person involved in responsibility for the management of a building, but I’m being given different definitions from different sources now and the principal accountable person can be one entity within one building, and the only entity, but that wasn’t my original understanding of that. I am shocked by what Kelly said about persons not being able to be accountable even though they’re part of that building and probably could be abrogating responsibility or some kind of liability within the control of that building.
It was interesting getting some of the updates from the building safety regulators meeting that occurred last week. From what I saw on Twitter it demonstrated that I don’t think the building safety regulator really knows too much about what’s going to be happening in the next few months and that’s concerning for us as we’re trying to put our safety cases together and making sure that we’ve got the right information. Have we got 6 months after October the 1st, or have we got 28 days to get everything together? That’s concerning me because that time is ticking away really quickly.
DAVE WILLIAMS Just echoing what George and Paul said. My understanding was originally it was going to be a named person and then as a result of the consultation they backed off on a named person, probably for the reasons that George pointed out like who would want that job, and those people would move around. So they changed it to become an organisational entity rather than a named person. They kept the original naming convention of calling it principal accountable person because the original idea was it was going to be an individual.
Going back to what Kelly said, particularly a lot of the onus they’ve got at the moment is around trying to tie down new developments and get that working, which is why most of the secondary legislation we’re expecting in April, a lot of that is being tied down to dealing with new developments rather than existing builds. But it will be a case of, in theory, you’ll get 6 months from April to get your house in order and be ready to meet the legislation and have your buildings all registered and stuff by October, which is a really tight turn around, given what we’ve seen dealing with the Fire Safety Act and what we needed to get done by January. I know a lot of people haven’t got all that done yet, let alone dealing with the Building Safety Act stuff.
I think that one of the things that needs to be considered, particularly with new developments, is making sure you’ve got those leases tied up so that when the thing is actually being built you’ve already tied down who is going to be the principal accountable person and who are just going to be accountable people, and what they’re responsible for providing to contribute to the safety case. That’s going to be a step change, and this is why we’re struggling with, particularly with buildings that were old section 106 or things like that, that that information was never put in place in the first place, so we’re retrospectively trying to convince people that they need to take on this role as principal accountable person, or even to get them to take on the role of an accountable person so that they supply us information on what they’re doing with that building, so that that informs our holistic safety case, and then feeds into the safety case report.
GEORGE I was just going to ask Mike and Calum, for example, who are probably more heavily involved in the delivery side of things, what do you think the practical sanction is going to be? At Gateway 2, for example, or Gateway 3, if the information isn’t adequate demonstrate that the building is safe, do you envisage a risk of delays?
MIKE The understanding from the conference was that the 12 week turnaround for a Gateway 2 approval will be met as long as the information provided is sufficient. So again, they’re being a little bit clever in that wording. So what they're saying is if we submit the right amount of information that shows that we've done our due diligence and met our legislationary requirements, then they will honour that 12 week. What they're saying is if you provide poor information or information that has gaps or weaknesses in it, they wouldn't commit to that 12 weeks, so it's in your best interest to do that.
I don't have a problem with that. I think it's very clever and I think what they're hinting at there is if you do everything well and you do things to the right level and you provide the information and the correct information, then they'll let you go and crack on with it. What they're probably going to do is identify difficult buildings. I think they’ll also probably start to identify, a sort of black list, people who they feel they’re more concerned about, and maybe focus their attention on those people, those clients and those developers, rather than maybe ones that they know are doing the right thing and making commitments to try and improve those things.
CALUM KERR From my point of view the 12 week period is not very helpful having 12 weeks from the end of a project where you’ve got maintenance to carry out. The amount of defects that could occur in that 12 week period, unless you do the standstill maintenance, is quite a concern. And I think we’ve probably gone back with those concerns to try and reduce that period. I’ve got no doubt we won’t have any success there.
GEORGE That’s at Gateway 3. And Gateway 2 as well?
CALUM KERR Well, it just seems excessively long periods, but I guess that’s borne out of the fact that we probably haven’t got enough staff at the moment to staff this up as well. We know that the amount of information that’s getting submitted, there’s no security management on that across the fire and rescue services at the moment. I don’t know if anybody is on LinkedIn connected up to Matt Hodges-Long who’s done some work to review that, those systems are quite shoddy at the moment. So, I think we’re on a hiding to nothing at the moment because we’re not getting much guidance, and if you’re found to have done something that’s maybe not quite right the onus is on us to pay the consequences of that.
GEORGE Yeah, the Tier 1 BIM4housing major contractors team have identified a couple of things in the last few weeks that I think are relevant. If I just show you. (shares screen). This thing about a major change, this comes around to the point about how complete the design needs to be before you start building. My understanding is that what they’re requiring is that things like sprinklers, smoke dampers, fire doors etc need to have been specified before construction starts because that needs to be then considered during the construction process. If you then change from one type of smoke damper to another then that would be expected to take up to 6 weeks to approve. So, that’s over and above the 12 weeks that you’re talking about there. It’s value engineering, so maybe it would discourage people from making changes, which largely is what I think most people think should be happening anyway. In any other industry, you wouldn’t start building it until you’ve completed the design.
MIKE George, just to pick up on that, I’m guessing your query was about at Gateway 2, prior to commencing construction. I think there was a little bit more movement on that at the conference last week. They were saying they’ve recognised that they will probably also look at conditional approvals on certain packages of work which they recognise they won’t be able to complete the design requirements until they’ve engaged with the supply chain at that point. Sprinklers was one of the ones that was raised.
I think what they’ll be looking for is let’s say you submit your Gateway 2 application and you have a sprinkler system, they would expect at Gateway 2 for you to say we are installing this sprinkler system, we’ll be complying with regulation x, y and z, this is our requirements, but the final details of the design will be completed by the specialist subcontractor when engaged. What I think they will then start to do is that they want that completed design information to be submitted, and as long as it's in line with those requirements and regulations, there shouldn't be any issues. What would be an issue is if that submitted design didn’t meet the criteria you’d set out at Gateway 2 and therefore they would raise concern about why changes have been made, not information that supports the approach you're taking.
GEORGE The knock-on impact of that though is that the problem comes from the design of the architecture, for example compartmentation, and where builders work holes go. So, if the selection of products is going to be left until after all of the drylining has already been installed and the prepared holes are already there, my understanding is it’s very common that the new M&E design goes through and breeches the compartmentation. So, that introduces a whole range of different issues that probably people like Hilti have to sort out.
MIKE Yeah, and I think they’re still looking to address that. I think they’re saying, look, at Gateway 2 we would expect you to have your compartmentation strategy and your fire requirements and your systems, but there may be a couple of specialist areas that will follow the principles and the design approach that you’re taking, but you may not have the drawings or information that substantiate fully that solution. When that information then comes along, that should follow everything you’ve previously agreed at Gateway 2. So there shouldn’t be any surprises, it’s more just information, your record drawings, I’m guessing, is what they’re seeking. What they’re looking not to accept is if, all of a sudden, you submit at Gateway 2 with your compartmentation strategy and then 6 months into the build you changed that, that's when they're gonna ask more questions. So they're gonna say, why have you changed your compartmentation strategy? What rationale did you have for that change? That's where I think you're going to raise more questions and queries.
STEPHEN GORE The risk always with this is that even if you haven't changed your strategy but you're just changing your supplier product, they're not interchangeable generally. So if you've already had holes precast for a smoke control damper from supplier A, even if your strategy hasn't changed, your classification requirements haven't changed, but you now buy from supplier B, the holes may no longer be suitable. And you can't just expect someone like Hilti to come up with some additional penetration seal solution because if it’s not tested then you’ve no longer got a compliant product, whether that’s from a smoke control or a compartmentation perspective. Most of the manufacturers, all their data should be available straight away in terms of things like hole sizes, wall materials, penetration seals, so there isn’t any information that you should be waiting for from a product manufacturer, they should have that already available now.
ALASTAIR BROCKETT Stephen makes a good point there because even when it gets down to smaller details because for decades, for example, fire stopping has always been regarded as just one of those things we’ll get done. For example, with any kind of dampers, even if they change the fire stopping it’s not necessarily the case that going from manufacturer A to manufacturer B is just a straight swap, because manufacturers do have different levels of approvals, different scopes of approval, and that even does come down to the type of hole, the size of hole. And certainly what we’re trying to alleviate is that we actually have, for example, an BIM for fire stopping programme which actually specifies the size of holes that you need for the type of service, so all of that is pre-planned and in place. And then if it just comes down to we want to change to some other supplier then that will have to be a consideration.
In my view, that would be down as almost a major change. The way I’ve been viewing this in terms of what is a major change and what’s not is the basic question: Can this have an ultimate effect on the safety case or safety of the occupants of the property? And if you’ve chosen the wrong fire stopping the wrong fire stopping and the fire stopping is not approved or tested for an application, well. The consequences are that it’s going to fail and you’re not going to achieve your compartmentation and therefore it then starts kicking up the chain.
GARETH FLETCHER I just wanted to know if it was a full fire risk analysis in place before Construction 4/Gateway 2? That’s something that could be reviewed if you had to change your supplier to understand the impact of the changes in your fire controls. We’ve been mainly working with landlords that are for buildings in occupational legacy buildings, so I wanted to know a bit more on the construction side.
GEORGE The fundamental point here, Gareth, is that the way the industry currently works they leave everything as late as they possible can to allow as much flexibility as they can and that is largely there to manage and reduce commercial risk. But actually everything that we’ve been told over the last 20 years is the earlier you make the decisions as to what products and materials go in the building you reduce the risk of failure. So, we’ve got a tension there between the commercial side of things that wants to leave things as late as possible and the other side which is trying to make the right decisions, as it were. I’m interested to just feel where the tensions are on that at the moment. Is there anybody else on the landlords side that would have a view on that? Perhaps not.
ALEX OLDMAN We’re having a discussion about buildings under construction, but let’s say that 99% of buildings already exist, so there’s a very small number actually being built at the moment. We’ve got thousands of high-risk buildings that need to go into this register and go through the process, which are existing buildings. I’m just wondering how this group can help with helping organisations who need to go through this registration process. Registration is something we have to deal with, but the issue is how we’re delivering occupied safe buildings. It’s all well and good talking about specifying things being built during the construction phase, but how are people approaching retro-buildings, going in and establishing what you’ve actually got deployed.
I'm fascinated by this general topic, how destructive are we being about our buildings. My journey towards BIM started just after the Grenfell Tower fire in that summer when I saw Brent O’Hanrahan, who is now running some building safety training programmes. Brent was then the Hyde Housing compliance manager or possible director of asset management, talking at the CIH conference saying the day after the Tower fire he’d been asked by the chief executive how many buildings had they got of that type and have they got that cladding on those buildings. His immediate reaction was I don’t know how many buildings I’ve got of any type, and I certainly don’t know anything about cladding. In the year after that they went out and established which buildings they had people in and started sampling some information systems and cladding systems and only later on in the process discovered that they’d been removing and sampling cladding for buildings that they didn’t own.
Which kicks us back to the responsibilities idea, looking at the accountable people and the principal accountable person, which I must admit is the first time I’ve heard PAPs being talked about. I suppose the question is how can we help, from the BIM angle, to talk about information standards for new build, which I think is a very big challenge, but potentially more easily controlled because we’ve got Gateways to go through, and existing buildings where we might not have information about stuff that’s built into the walls of buildings or buried under concrete.
ANDREW HOLLEY Yes, and there’s another thing. I had a similar question from my development officer who said if, in theory, we accept a new build that’s been built by someone else and we might be given it, effectively, to manage, what information etc do we need and what’s the process and how’s it going to work. So, I tried to explain some of the processes and at the same time asking, well, it depends where they are with the build process as well, none of which came back exactly because it was all theoretical, really. But what I had to throw in there as well was don’t forget also, just to make it even more confusing, the builder is going to be concentrating on the Building Safety Act. As soon as it gets through Gateway 3 and it gets handed over to us as landlord we then have to apply the fire safety order, and if that isn’t fed into the ERs so that the builder builds it right.
So, for instance, not terribly worrying but it’s something that should be done, you need a PIP box installed on the ground floor and you need fire signs telling you which flats are on what floors. Now, those things are not in the Building Safety Act as this is required for a building, it’s under the fire safety orders. So, are we missing some information that makes sure that on day one, yes, it’s passed the Building Safety Act, great, now hang on, I have to go and put a load of signs up before I can even open this building. Are all the steps or all the hurdles actually being covered. So, there’s another thing to throw in, does the Building Safety Act include all of the things that are in the fire safety order that are required as well, because there’ll be this argument where the builder will say, well, it passes building control. Yeah, but you haven’t done this and you haven’t done that, and I now need to do that and I haven’t got any money because you’re giving me a finished building, but you haven’t finished it.
ALEX OLDMAN For me, that’s the COBie, that’s the point at which COBie kicks in. It’s the construction to operations building information exchange, at that point we’re looping back going we need to know where are the signs, where’s the PID, and they might be going, well, we can’t hand over the building until we’ve done this.
GEORGE The key thing there, Alex, is what’s in that COBie file, because you can’t assume that what’s going to come out is going to be in the COBie because you need to define what’s going to be in the COBie, that’s why the asset information requirements are so critical. So, for example, signage, if you were asking for a building, Balfour Beatty wouldn’t typically provide you, in their COBie information, with signage. It's absolutely logical that it should be there, but unless you put it in then you wouldn't know. Exactly the same with attributes against elements as well, because COBie, in its most basic form, will just tell you who the manufacturer is, what the model number is, probably its life cycle, it might not even tell you where it is. It will probably give you a space, but spaces are quite big. So, if you don’t know where it is, but you certainly wouldn’t know, from standard COBie, what the fire rating of a door is because unless you actually specify in your AIR it won’t be included.
ANDREW HOLLEY We should be aiming from the beginning to number doors using a standard numbering format. But that's not necessarily in the Building Safety Act, again, that's something that we should be asking for up front so when we start we can go right, we know exactly what doors where, we know the name and the numbers, that’s useful because that's useful for all sorts of other stuff, and then put it all together. But you’re right, I think we need to ask for these things up front because they're pretty much free to free to provide if you ask for them upfront, and it's all part of the process. If you ask for it afterwards, they'll go, oh, no, we need to go round and find that. There are gaps, and this is where, as end users, on my side, I’m going to be saying am I going to receive all the information I’m expecting to receive. So I’ll have to ask for it at the early stage. And it’s tricky when I’m going to receive a building from someone.
I think when I’m looking at existing buildings I’ll probably have a budget for it. I'm going round at the moment putting floor level and floor location signs up, because we haven’t got them, therefore I’ve got a budget. But if I’m receiving a building that’s new I think my bosses would assume that everything would be there and I shouldn’t need to be starting to spend money on it straight away. So, I think being sure that everything, not just Building Safety Act, but fire safety order, which of course doesn’t apply until it’s occupied, and that’s the tricky bit and we have to remember that things like a SIB or PIB box in the ground floor isn’t necessarily part of the build, but we do need to ask for them, and signs and exits and stuff like that.
The plans, for instance, we might be given full set drawing plans, 200 billion bits of information on them electronically, but what the fire brigade need is a very basic drawing. So, while it’s being done we can say can we have similar layout plans, a bit like the fire alarm plans, simple, basic and clear ones that are suitable for the SIB box, because that’s required. So, there’s lots of other things that I think we need to fill gaps.
GEORGE On that point, from a BIM perspective I would say rather than ending up with another silo of drawings, that’s a matter of just layering or switching levels of detail off.
ANDREW HOLLEY yes, if it’s drawn with the right layers, that’s fine, you just switch off, but half the time you switch off fire alarm and you lose the whole lot. And actually what you want is the zone bit of the fire alarm, not the location of every detector.
MIKE I was just trying to follow on from Alex’s suggestion about how we try and move these things forward. So, good quality EIRs, good quality AIRs, good quality OIRs, all of those key information documents, if we get given them at the start of the project, then delivering all that information is very easy. There's no problem with us producing fire plans or segregated drawings or signage information. All of those things are well within our grasp and we can deliver that. And that can be in the form of physically modelled objects, or it can be in data or in COBie, any of those requirements we can do that. What we still typically find is that that information at the start of the projects isn't clear enough, and that's where half the problem starts is that initial information. However, I’ve spent many years in the ISOs and looking at those processes and the more and more you get to know them, the more and more you realise that they are actually very sensible in what they ask, and they are very sensible in the mechanisms to do the right thing. The challenges continue in the education to make people aware of why you need to go through those stepping stones to get the right information out at the end. So that, for me, is a real key one.
Common data environments, I still think there's a huge improved market in terms of common data environments making it very clear at the onset whether clients have a common data environment that they're using and, that horrible word that I never pronounce, the interoperability between common data environments to try and get them to talk to each other. Really, really important. The last one is the perception about differences between new and old buildings. For me, I don’t think it makes any difference. Newer buildings are probably easier because you're building information and you're collecting it in and you're starting from refresh. But you probably already have some existing information that you have to gain because, typically, there is a site with some information that already exists anyway. If you're re-cladding an existing building, it's just got different constraints, but they're the same I think regardless of…I think it's a mindset shift.
GEORGE I was just going to mention, as we discussed this morning, Nima, which is the new name for the UK BIM Alliance. Nima are running a stand at Digital Construction Week which is towards the end of May. Last year, we were able to secure some tables and we ran a live roundtable workshop where we had about 40 people come along and be working actively on a particular topic. I've put a proposal forward to them this year to try and do the same again. So, if you'd be interested, I know Alex came and ran the Operations one last time. If you’re interested or you’ve got colleagues that might be willing to come I’d like to throw that out there. We’ve also got an in-person event on the 12th of April in London that’s being organised by Cambridge University. It’s around the delivery of the Building Safety Act and the like, so if you’re interested you can come along to that.
ALEX OLDMAN Digital Construction week is the 17th & 18th of May at Excel in London. I would normally announce at this point the date of the next meeting, but I don't know if we've actually got that in the diary. Look out in your diaries for the next meeting date. it looks like we’ll get together at DCW or FireX or the Cambridge event.
GEORGE I was just going to ask if anybody is interested in looking at this area of aligning the risks and the hazard side of things. (shares screen). Looking at this safety case report you’ll see that we’ve got smoke in a flat breaking out, and the measures that are in place and the assets that are in place that are there to protect it. If we then go to the EWS report that has got similar types of breakdowns, but they're described differently. The point is they’ve got similar hazards. So, fire in a room, and this has been described differently, obviously, but it’s been decided because that consultant because that consultant has interpreted it that way. My though is what you would want as a landlord is to say this risk happens, therefore I want to know from my EWS report and for my building safety report and for my fire safety report, or for my fire risk assessment, whether the measures that are in place are going to be there protecting us. So, what’s the relationship, for example, between the smoke vent system and that. Would you agree that would be a useful thing to try and align? And if so would you be interested in spending an hour or so with me just going through and talking about that?
GARETH FLETCHER Yeah, I’d say it’s very useful, because a lot of things we work with, our landlords, they have FRAs, they have EWSs and other surveys as well. We are trying to capture that information within the hazard identification and then turn that into a building risk register that can be maintained over the life cycle of the building. So, I can see gains from being able to leverage the initial documents they have to do through statutory means for FRAs, then implementing that within the hazard analysis, either bow ties or hazard which has been mentioned by the building safety regulator. There’s obviously many other methods as well, but we’ll probably stick with them. So yeah, I think it’s very useful.
ANDREW HOLLEY I will help with it. I’m just thinking that’s similar to…the boards, for instance, will say what’s our most hazardous building, well, it depends which report you’re reading. So yeah, trying to pull things together is actually quite important.
GEORGE Yeah, because all three of them may reference a smoke vent, but they’ll use different terminology to describe it. It would make a lot more sense if a smoke vent fails, what’s the impact on the EWS view, the fire view and also the building safety view.
ADDENDUM
CHAT
Alastair Brockett
compare with an MOT.
Paul Bray
There is a requirement within the FSO and the BSA to review or revise the FSA and Safety Case if there are any changes, or reasons to believe it is not no longer valid.
Will Franks
The Safety Case is best understood as an iterative process, a living document.
Agree with points discussed so far around understanding the building as a holistic system.
Dave Williams
We have a similar situation Kelly with a couple of our buildings where one we consider ourselves the AP not the PAP as the other party has responsibility for the external structure even though we look after internal communal areas.
https://buildingsafety.campaign.gov.uk/prepare-to-register-your-building/
Gareth Fletcher
The clear lines of responsibility and accountability probably need to be outlined as part of the safety case.
Dave Williams
Hi all, not sure if this is of use, but this is a top level view of my programme plan which has over 100 tasks and growing.
Paul Bray
There is always an issue with getting the building right for signage etc. after contractors have finished working on site, whether new build or occupied, even when the discussions have gone ahead agreeing what the contractors will do or provide. The only way to confirm signage etc is correct is by walking the building as close to completion as possible.
Alex Oldman
DCW is 17/18 May at Excel (Docklands) London.