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BAFE Respond to Government Building Safety Regulatory System Consultation
Friday 26th July 2019
Building a safer future: proposals for reform of the building safety regulatory system
BAFE, the independent register of quality fire safety service providers, have officially responded to the Government’s Building a safer future: proposals for reform of the building safety regulatory system consultation.
Stephen Adams, BAFE Chief Executive, discussed the following main points in the response submitted:
1. BAFE recognise that the consultation concerns high-rise residential buildings (HRRBs) as a starting point, but strongly recommend that this is rapidly extended to a wider range of high risk premises including care homes, multiple occupancy dwellings for vulnerable adults, hospitals and student accommodation.
2. BAFE stress the need for the Fire Risk assessment to be the critical factor in assessing risk and the need for overarching responsibility in buildings with multiple use.
3. BAFE note the importance of fire safety planning at all stages of design and construction and the need to ensure that there is no compromise on materials and competence of installation.
4. The proposals for the introduction of an accountable person for the safety of the building is generally welcomed. However, there are concerns about:
a. Will they or the Building Safety manager have the necessary skills to carry out all building safety monitoring and control, thus requiring a range of competent sub-contractors. This makes the role one of co-ordination as well as management.
b. How does the functional responsibility chain work with owners, owners’ agents, landlords etc especially where the building has multiple uses, both residential and commercial.
c. Balance the different priorities for safety, resident’s needs, security etc. What happens if there is a dispute – what takes precedence?
d. Ensuring that the Fire and Rescue Services retain their statutory role for enforcement and that there is no lack of clarity with them offering other services.
5. BAFE stressed the importance of ensuring that existing building stock is prioritised for the introduction of controls. There has been too much stress placed upon new construction, which is a tiny proportion of the built environment. The concept of the golden thread of information and the role of the building safety co-ordinator and the duty holder for fire safety can only work properly in existing buildings if they have enforcement capability to ensure that they have access to all records and an up to date fire risk assessment.
6. The discussion of Building Information Modelling (BIM) provides a strong route to delivering a record of all aspects of building monitoring. However, it must ensure that there is a strong enough fire content and that it can be used for existing building stock.
7. BAFE recognise the importance of involving the residents in all aspects of building safety, especially giving them access to the Fire Risk Assessor and reports.
8. BAFE has participated in a number of the Grenfell Working Groups and consider it a vital necessity that the recommendations are taken to legislators and acted upon. This is especially true regarding fire safety and ongoing use during the life of the building, both of which have been overlooked by emphasis on the construction phase.
9. There should be an industry led Competence steering group, which must include representatives from the fire industry.
10. BAFE strongly recommended that third party certification of installation and maintenance for fire safety services is recognised and mandatory provision made, especially for fire risk assessments.
11. BAFE also described the importance of including the certification of companies that provide these services, as well as the individuals carrying out the work, as they are the ones responsible for trades work, training, provision of equipment and having the appropriate insurances. It is the companies that are specified to carry out these works, not individual trades people.
12. There should be mandatory standards for third party certification to ensure that they are rigorous and kept up to date.
13. Enforcement is a key issue and the potential for third party certification to be a statutory defence to demonstrate due diligence should be considered. Certain aspects, such as competence for fire risk assessors must be mandated.
The public consultation Building a safer future: proposals for reform of the building safety regulatory system closes 31st July 2019 11:45pm. BAFE strongly encourage everyone to respond to this (either as an individual or company) to express your views on the system. Further information can be found on the gov.uk website: https://www.gov.uk/government/consultations/building-a-safer-future-proposals-for-reform-of-the-building-safety-regulatory-system
Legal obligations nationwide require the appointed responsible person for fire safety for non-domestic premises to have adequate fire protection.