Identifying competence in Higher Risk Buildings

Michael Andrews, Chief Executive Officer at NAPIT, considers the many initiatives looking at Building Safety Reform following the Grenfell Tragedy and how they could impact the certification of installers.

No one can forget the tragedy which took place at Grenfell Tower in West London back in 2017. It took many lives and unmasked significant failings across the system of constructing, safeguarding and managing high-rise buildings. It resulted in Dame Judith Hackitt’s Independent Review of Building Regulations and Fire Safety, published in May 2018, which considered the accountability and statutory responsibilities for ensuring safe buildings.

The draft Building Safety Bill, was published in July 2020, and outlines how the Government intends to deliver the principles and recommendations of Dame Judith Hackitt’s Review, whilst outlining a new approach for managing risks across the design, construction, inspection and occupation of Higher Risk Buildings[1] (HRB’s) during construction and beyond. It includes proposals to establish a new Building Safety Regulator, the introduction of Gateways to ensure that building safety risks are considered at each stage of a building’s design and construction, the need for all HRBs to appoint an Accountable Person, a greater focus on resident engagement and information dissemination and allows for the introduction of Secondary Legislation to be prescriptive about the competence requirements of anyone undertaking work in HRB’s.

Alongside the draft Building Safety Bill, the Final Report of the Competence Steering Group for Building a Safer Future, ‘Setting the Bar- A New Competence Regime for Building a Safer Future’ has been published. The report focuses explicitly on the competence of installers working on and in HRB’s, amongst other things, and how best to ensure their competence and identify them. It includes the following recommendations:

  • • Recommendation 9: Reassess competence – For those involved with higher-risk buildings, there should be a robust system of reassessment so as to ensure that they have maintained their competence in relation to the work they are registered / certified to undertake and have a plan to develop new competences where necessary.
  • • Recommendation 10: Improve existing arrangements – Existing arrangements, for assessing and reassessing competence, in the main delivered through certification and professional registration, should be improved to include – as a minimum – the competences needed for working on higher-risk buildings.
  • • Recommendation 16: Mandatory registration/certification – Wherever appropriate, Government should mandate persons working on higher-risk buildings to be registered/ certified by a recognised professional/ certification body.

Furthermore, MHCLG have funded a piece of work: Built environment – Overarching framework for competence of individuals – Specification, a draft of which has been published for consultation which closes on the 20th October. This is an overarching competence framework for individuals covering the core knowledge, skills and behaviour required to work on or in buildings and is likely to have a significant impact on how the competence of individuals is assessed and verified.

Since inception NAPIT has recognised the need for individual competence and has chosen to assess multiple operatives within our registered businesses under our UKAS accredited certification schemes. The need for adequately competent and adequately supervised individuals undertaking work in buildings is imperative to Building Safety.

We are fully supportive of the work which MHCLG are currently doing to review the Minimum Technical Competency (MTC) documents which underpin the minimum knowledge, practical skills and experience requirements that will ensure that an organisation or individual has the appropriate skills to undertake work in a Competent Person Scheme (CPS) designated in Schedule 3 of the Building Regulations. This review is set to consider sector specific requirements for those undertaking work in HRBs.

We have played an active role in the discussions within industry about how best to determine and verify the competence of those working in HRBs. We fully support the proposal to require all installers working within HRB’s to have a core knowledge of fire safety within buildings and agree that requiring individuals to demonstrate their ability to work within HRBs, through regular third party assessments and CPD, is a positive step forward for the industry. We hope this can be realised within the MHCLG MTC review and start building a stronger industry- focused on safety and compliance.

The one sticking point I foresee is how to demonstrate and validate the competence of individuals who have been deemed competent to work in/on HRBs. Systems such as registers, or ID cards are meaningless on their own. They must be underpinned by the accredited processes of assessment, reassessment and inspection that can verify that the competence demonstrated by qualifications, knowledge and understanding are delivered in practice. For example, a CSCS card is designed to be granted to someone who has achieved a qualification, but as it is, it is not based on any form of further scrutiny so cannot be claimed as verifying an individual is working competently.

In this fast-moving and connected world, the authentication of competent individuals should be digitalised -without the need for a specific logo or card. Of course ensuring the identification of competent individuals is key to improving building safety but I firmly believe an online system, being fed into by all sectors who are assessing the technical competence of individuals to industry approved standards, overseen by third party accredited organisations is the way to go. We shall wait and see…

[1] Higher Risk Buildings are currently defined as those which are 18 metres tall or 6 stories- whichever is met first. The draft Building Safety Bill gives powers to the new Building Safety Regulator to amend this definition if deemed necessary.
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