Response 174010773

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Part 1

1.1. Do you agree that the roles and responsibilities of verifiers (including their key activities) must be clearly defined and recorded, including the expected level of resources and skills needed to undertake verification activity, and the actual level?

Please select one item
Yes
No
Unsure

1.2. Do you agree that verifiers must place a greater emphasis on inspection and testing throughout construction and at completion?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
If they are provided with all of the test data it may suffice in lieu of actual testing being carried out during site works, however, we are aware that what is tested in a lab may differ on site due to a large number of possible unknowns/alterations/building tolerances.
Also, if the verify has to do more during inspection then more Building Standards officers/inspectors will be required, there aren't enough personnel at present to carry out all the checks necessary if more is to be added to their plates.

1.3. Do you agree that verifiers must place a strong focus on safety critical elements such as structure (for example wall ties, lateral restraint) and fire safety (for example fire protection, fire-stopping, cavity barriers)?

Please select one item
Yes
No
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1.4. Do you agree that local authorities should not be able to act as verifier for their own “higher risk” building work due to possible conflicts of interest?

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Yes
No
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Please provide any comments in the box below.
It is always better for another 'pair of eyes' to be passed over anything, especially high profile or higher risk projects.

1.5. Do you agree that local authorities should still be able to act as verifier for their own lower risk work?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
So long as a check is put in so that another person or persons from within the organisation, outwith the original design team is able to review the proposals. As per the SER Certification scheme, any designs carried out by the Verifier cannot be certified by them, it must be certified by an independent external body.

1.6. Do you agree that the roles and responsibilities of building owners and developers (including their key activities) must be clearly defined within the Building Standards system and recorded including the expected level of resources and skills needed to assure themselves and verifiers of compliance, and the actual level?

Please select one item
Yes
No
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Please provide any comments in the box below.
Whilst this will most likely be stated somewhere it would be better if it were clearly stated in such a way as to avoid the possibility of building owners/developers 'ignoring' there responsibilities because it wasn't clear.

1.7. Do you agree that the building owners and developers must, to ensure compliance, place a greater emphasis on inspection and testing throughout construction and at completion, with focus on the safety critical elements?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
A lot of the time these days there isn't a Clerk of Works on site. Additionally the Structural Engineer, where there commission includes site inspections, are normally only on site once a month at site progress meetings. Important things can be boxed in/hidden between inspections. The testing issue is maybe not as important, we would have to rely more on test information being available at design stage. However, it is all to do with cost and most people don't appreciate/understand that a fee quote is higher because there are lots of things that need to be justified/done to comply with the Building Regs. They are just going to want the cheapest quote, which may not always be the best quote/cover all elements.

1.8. Do you agree with the requirement for a Compliance Plan, to be provided by the owner or developer, to demonstrate their approach to compliance from initial design, through detailed design and construction, and leading to their final sign-off and certification of the completed building?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
on the one hand yes on the other no. Would it end up being a 'tick-box' exercise that would get 'lost' in an O&M manual?

1.9. Do you agree that the building owner or developer should be required to appoint a competent professional person, with the appropriate experience and qualifications, to act on their behalf in order to assure them of compliance when they submit the completion certificate?

Please select one item
Yes
No
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1.10. Do you agree that mandatory pre-application discussions and pre-commencement of construction discussions should be introduced for higher risk buildings?

Please select one item
Yes
No
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1.11. Do you agree that amendments to warrant should differentiate between minor changes, major changes, and staged warrants?

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Yes
No
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Please provide any comments in the box below.
Maybe. would this add another degree of potential complexity?

1.12. Do you agree that the construction procedures and guidance should be reviewed and that mandatory notifications are introduced, including notification of progress on higher risk projects?

Please select one item
Yes
No
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1.13. Do you agree that verifiers should carry out ad-hoc (unannounced) progress inspections and be able to require disruptive surveys when mandatory notifications are not made to them?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
Although as noted in an answer above, more Building Standards officers will be required to carry out this function, we are aware that there aren't enough officers to go around at the moment.

1.14. Do you agree that verifiers should record safety critical building standards non-compliances and feedback at a national level to drive improvements?

Please select one item
Yes
No
Unsure

1.15. Do you agree that verifiers should be notified of minor changes in design as the project progresses, on the understanding that they are to be covered by an amendment to warrant before the completion certificate is submitted?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
If they are all minor changes then it shouldn't be an issue, it would only be if the change becomes something that is a major alteration to what a warrant was granted for that they should be advised in advance.
Of course, if there are a number of minor changes that could constitute a major change then maybe, but, who decides how many minor changes would mean it was a major change? Does that then become a 'headache' to police/manage?

1.16. Do you agree that the completion certificate for a higher risk building should have sub-sets for safety critical aspects, and be accompanied by as-built drawings and the completed Compliance Plan?

Please select one item
Yes
No
Unsure

1.17. Do you agree that the procedures for the temporary occupation or use of a building should be strengthened for example requiring a declaration of compliance and monitoring of the expiry dates?

Please select one item
Yes
No
Unsure

1.18. Do you agree that restrictions to the occupation or use of existing buildings should be considered when significant alterations are being carried out to higher risk buildings?

Please select one item
Yes
No
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1.19. Do you agree that local authorities should be more pro-active in enforcing building regulations and monitor construction regularly?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
Although as noted above, there are not enough building warrant/standards officers to go around at the moment, more would need to be employed to allow this to be done.

1.20. Do you agree that local authorities should have a building standards enforcement policy in place that is based on national guidance?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
Is it not already based on national guidance? The national guidance should allow for changes that any council needs to make due to the potential type of projects/frequency for that type of project. Highlands & Islands Council has a lot of rural areas as opposed to Glasgow City Council which is mainly urban, what would apply more to HIC would not necessarily apply to GCC and vice versa.

1.21. Do you agree that national guidance on building standards enforcement should include what enforcement related actions local authorities should carry out and the level of resources and skills they should have to do so?

Please select one item
Yes
No
Unsure

1.22. Do you agree the penalties and levels of fines associated with serious failures in compliance should be increased?

Please select one item
Yes
No
Unsure

Fire Safety

2.1. Do you agree that the guidance should be developed to make clear that there is more than one way of achieving compliance with the mandatory functional standards?

Please select one item
Yes
No
Unsure

2.2. Do you agree that the annexes in the Technical Handbooks for residential care buildings, hospitals and enclosed shopping centres should be published separately?

Please select one item
Yes
No
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Please provide any comments in the box below.
It should all be together to ensure that a section isnt missed.

2.3. Do you agree that an additional Technical Handbook for simple domestic detached and semi-detached dwellings (up to 3 storeys) should be introduced as a means of compliance with fire, and all applicable building standards and sections of the Handbooks?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
Possibly. It would certainly make it easier to deal with 'simpler' residential buildings as opposed to multi-storey buildings if there was a different (but similar) set of regs for them.

2.4. Do you agree that a national “hub” approach should be developed to share expertise and skills and be responsible for verifying fully performance based “fire safety engineering designs”?

Please select one item
Yes
No
Unsure

2.5. Do you agree that consideration should be given to a certification scheme for fire engineering?

Please select one item
Yes
No
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Please provide any comments in the box below.
Whos remit would this fall under?

2.6. Do you agree that the reference to British Standards Reaction to Fire Tests should be removed from the Technical Handbook?

Please select one item
Yes
No
Unsure

2.7. Do you agree that only A1 and A2 materials, using the European Harmonised “reaction to fire tests”, should be required for external walls or insulation exposed in a cavity of a high rise building (domestic and non-domestic) with a storey at a height of more than 11m above ground?

Please select one item
Yes
No
Unsure

2.8. Do you agree that only A1 and A2 materials, using the European Harmonised “reaction to fire tests”, should be required for external walls or insulation exposed in a cavity of entertainment and assembly buildings, residential care homes and hospitals of any height?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
Probably, I would need more information on this.

2.9. Do you agree that BS 8414 (and BR135) may still be used as an alternative method of providing evidence to show compliance?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
I haven't used those codes specifically so cannot confirm one way or the other.

2.10. Do you agree fire service activated evacuation sounders should be required in each flat in new domestic buildings which have a storey at a height of more than 18m above ground level?

Please select one item
Yes
No
Unsure
Please provide any comments in the box below.
Probably, this would have to be reviewed in line with the whole package as it were when considering sprinklers, sounders, etc.

2.11. Do you agree that two stairways should be required for new domestic buildings which have a storey at a height of more than 18m above ground level?

Please select one item
Yes
No
Unsure

2.12. Do you agree that new HMOs used for “care” 24/7 should be included in the list of buildings with a mandatory requirement for automatic fire suppression systems?

Please select one item
Yes
No
Unsure

2.13. Do you agree that new HMOs with 10 or more occupants should be included in the list of buildings with a mandatory requirement for automatic fire suppression systems?

Please select one item
Yes
No
Unsure

2.14. Do you agree that new flats should be included in the list of buildings with a mandatory requirement for automatic fire suppression systems?

Please select one item
Yes
No
Unsure

Miscellaneous

3.1. Do you agree that protected lobbies need not be provided to shared residential accommodation with only one escape stair?

Please select one item
Yes
No
Unsure

3.2. Do you agree that exempt type 16 of building regulations should be reviewed in respect of the criteria for the erection of a temporary building and the temporary use of a building?

Please select one item
Yes
No
Unsure

4.1. Do you agree with the areas identified for further consideration?

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Yes
No
Unsure

4.2. Do you consider there are other areas of the building standards system that require further consideration?

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Yes
No
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Impact Assessments

5.1. Are there any proposals in this consultation which impact or have implications on ‘equality groups’? Choose from the following options:

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Yes
No
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5.2. Are there any proposals in this consultation which impact or have implications on ‘equality groups’? Choose from the following options:

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Yes
No
Unsure

5.3. Do any of the proposals in this consultation have any financial, regulatory or resource implications for you and/or your business (if applicable)? Choose from the following options:

Please select one item
Yes
No
Unsure

5.4. Do any of the proposals in this consultation have any financial, regulatory or resource implications for you and/or your business (if applicable)? Choose from the following options:

Please select one item
Yes
No
Unsure
Structure of building standards and supporting guidance
It could potentially increase the amount of time we have to spend on the project in design/detailing. This would in turn increase our fee quotes, would Clients want to pick up these costs?

About you

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Fiona Drew

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