IMPROVING KNOWLEDGE

ASFP Training Manager Chris Sharman review the ASFP’s training and development activities throughout 2022

As I write this article we are looking forward to the IFE examinations taking place at the begining of October. For many, this will be the time they put their newfound knowledge from our classroom, online, or revision courses to the test. At the time of going to press I am sure many of you are keenly awaiting the results from this exam, and to you all we wish good luck. We would love feedback from you so please do let us know how you fare; it helps us to no end knowing where we may improve in supporting you taking your next steps on the competency pathway.

Twelve months ago, on 4th October 2021, I found myself at the Association’s office in Coventry for my first day in my new role with the ASFP, and in May of the following year we introduced the revised and updated online Introduction to Passive Fire Protection course. This was the first course where I was directly involved in creating the content, and I am, justifiably, very proud of what our team has produced.

The original online introductory course was created in partnership with an external consultant and at the time met the Association’s needs as providing a basic oversight to the world of passive fire protection. Having taken into account the ongoing changes in the construction industry it has become obvious that a more formal competency pathway is needed if we are to ensure best practices are observed at all levels of the industry. The ASFP have been very successful in recent years in promoting training and competency at the higher levels through the Foundation Course in Passive Fire Protection in conjunction with the IFE. It was felt that the introductory courses should follow the same format, hence the creation of a new package, this time run with external partners in direct conjunction with us rather than at arm’s length.

We worked with Milford and Marah, a very experienced training consultancy, to frame this training at the correct level, with us providing the technical content. This has led to the creation of a very well received course which, while continuing the previous offering’s modular setup, contains much improved content. This content features images, animations, audio, and video, all of which have been created in-house to enhance the learning experience and create what we believe is a truly industry leading course. Do not just take our word for it though, here are just a few of the comments we have received in response to the course;

“Animations and Infographics are excellent. Different voices keep the user’s interest.” Michal Skrna Hilti (GT. Britain) Ltd.

“Wow, what a difference between the previous online introduction and your new version…. graphics and visual aids are far better and clearer… and the verbal delivery is clear, concise, and engaging.” Martin Buckroyd – Rhodar

“I liked the video series, it was informative and covers good ground. A great introduction to passive fire safety. ...the quality and relevance of the images to what was being talked about was really good and served as good visual aids” Jack Colloff – TBA Firefly

What we have achieved in these last 12 months is beyond anything I would have imagined myself doing as recently as two or three years ago. I look forward to the next years with great interest as to where things in our Association and the wider construction industry may be going, and what part I will be playing in it.

For all that I have experienced over this last year, and for that which is yet to come, I thank you all! The ASFP would also like to thank the following for their assistance and support in the creation of the course; Kate and David from Milford and Marah, Hilti (Great Britain) Ltd, Swegon Actionair, Simon Watkins and the team from Etex Building Performance, FSi Ltd, TBA Firefly Ltd, Siderise Ltd, Rockwool Ltd, Global HSE Solutions Ltd, and of course, all of the ASFP Officers and Members for their contributions and support.

THE BUILDING SAFETY ACT CONSULTATIONS

ASFP Technical and Regulatory Affairs Officer Niall Rowan shares the Association’s views on recent consultations for secondary legislation being undertaken following publication of the Building Safety Act

Responding to Government

Following the granting of Royal Assent for the Building Safety Act (BSA) at the end of April 2022, the Department for Levelling Up Communities and Housing (DLUCH) has launched three tranches of consultation. These aim to steer the development of secondary legislation to enable further implementation of the Act. These are:

1. Consultation on implementing the new building control regime for higher-risk buildings and wider changes to the building regulations for all buildings 2. Consultation on the in-occupation regime for occupied higher-risk buildings 3. The Building Safety (Fees and Charges)

Regulations 202[3] and charging scheme

They can be accessed here: www.consult. levellingup.gov.uk/building-safetyconsultations.

The ASFP has responded to the first two consultations, which closed on 12 October. While many of the proposals are welcome and seem straightforward, we have a number of concerns which could be interpreted as a weakening of resolve to the commitments made by the Government following the Hackitt Review of Building Safety.

Role of Clients

Our first concern relates to the interrelationship between the client, the Principal Designer (PD) and the Principal Contractor (PC). The BSA puts a lot of responsibility on the client. ASFP has learned that the regulation was deliberately framed this way as it was considered that many of the poor buildings constructed are as a result of ‘poor clients’. Whatever the rights and wrongs of that statement we believe, as do many others, that many clients are not able to undertake the tasks and responsibilities put on them by the Act.

It is proposed that the client has to ‘provide building information to every designer and contractor on the project and have arrangements to ensure information is provided to designers and contractors to make them aware that the project includes any higher-risk building work; and, cooperate and share information with other relevant dutyholders.’ We believe that this is the role of the PD/PC, not the client and that most clients would not be able to do this.

Competence Requirements

In respect of competence requirements, the consultation states that non competent persons can be used if they are suitably supervised: ‘It is recognised that competent individuals may be supported by other individuals who may not be fully competent (such as labourers or apprentices)’.

ASFP believes that the installation of safety critical products and systems such as fire protection measures should not be left in the hands of labourers, even if supervised. We believe that they should possess the necessary Skills, Knowledge, Experience and Behaviour (SKEB) as determined by the appropriate competency framework. The use of unskilled labour and its inconsistent supervision is a major cause of poor quality installed fire protection.

Another concern we have over competency is the statement: ‘We propose that building regulations require that where any person ceases to satisfy the competence requirements: If they are the Principal Designer or the Principal Contractor, they must notify the client……; If they are a designer working on the design, they must notify the Principal Designer……..; If they are a contractor undertaking building work, they must notify the Principal Contractor…. and, in any other case, they must notify the person who asked them to carry out the work’. This statement is fine, but at no point does it propose or require that those who have lost their competence tell the Building Safety Regulator (BSR) or other Building Control organisation. It is all kept ‘in house’ on the side of those undertaking the work and working on the project ie, the client, PD, PC etc. This is a clear conflict of interest.

The Role of Design and Build in Gateway Two

The ASFP has major concerns over the following information required for the building control approval application (‘Gateway two application’) for higher-risk buildings: ‘A design and build approach document setting out the proposed standards to be used’. The whole principle of Gateway Two is that full plans are submitted with detailed fire safety design. Gateway Two is supposed to end design and build, not facilitate it. Design and build is one of the biggest causes of poor quality passive fire protection (PFP), in particular firestopping arrangements in buildings. The ASFP along with many others believes it should be consigned to history.

In further discussions with DLUCH, they claim that Gateway Two is still ‘full plans’ and that the ‘proposed standards to be used’ refers to the use of Approved Document B (AD-B) to the Building Regulations, or BS9999, BS9991 etc as the guidance used by designers. We remain sceptical because in no other part of the consultations can we find any reference to ‘full plans’.

Our scepticism is backed up by building control approval applications for new higher-risk buildings following a staged approach. The statement below is no real change from what we have now: ‘The detailed plans and design and build approach document covering work up to the specified stage must, however, be accompanied by outline plans for the whole building’.

Use of Competent Person Schemes

The consultation asks if competent person scheme work should be reflected in building control approval applications. Whilst this might be suitable for some trades, eg electricians, and it reflects current practice, we believe that for safety critical systems and products, e.g. passive fire protection, competent persons schemes should not be included because these use self-certification.

If the installation of such systems is undertaken by third party certificated installers, then the ability to vary the inspection required for building control approval, as negotiated with the BSR, is worth pursuing. But a separate regime for safety critical installations is not spelt out and so this is of concern.

Types of Changes to Building Control Approval Applications

The consultation provides a list of subjects which require consideration by the BSR. However, there is nothing on passive fire protection. ASFP believes that changes to the