The future of building control

In March 2007, DCLG (Department of Communities and Local Government) released its initial proposals document on the future of building control in the UK. Views are sought, so here are John Gelder's!

Practices operating across jurisdictions in the UK find the business of coming to grips with the building regulations guidance or deemed-to-satisfy material (Approved Documents and their ilk) unnecessarily difficult – there are different systems for England & Wales, Scotland, Northern Ireland, Isle of Man, and so on. They aren’t all that different technically – all derive from the E&W Approved Documents, but with a time lag and different structures – so this is just annoying.

The solution is simple – a genuine national set of guidance (not to be confused with BSI’s Unified Building Code proposals). The USA and Australia both have such systems in place: the IBC (International Building Code, and its sister codes, e.g. International Property Maintenance Code) and BCA (Building Code of Australia) respectively. Regulations in each jurisdiction simply invoke the national set. In the USA [www.iccsafe.org], 47 states use the IBC, but many state and local codes remain in force. In Australia [www.abcb.gov.au], variations between jurisdictions are dealt with in an ever-diminishing set of appendices. There would be very few such variations in the UK.

This proposal would also make our life at NBS simpler, and would facilitate the production of compliance specifications, of which more later.

Domestic

Some Parts are split into domestic and non-domestic – this should be done for all Parts. This would reveal the paucity of information dealing with non-domestic projects, which would be a bit of an eye-opener! And it would simplify things for those working on domestic projects – they wouldn’t have to work out what guidance applies and what doesn’t. Again, Australia’s BCA is published in this fashion (in two loose-leaf binders, to facilitate maintenance), and the USA has its IRC (International Residential Code), so it can be done.

Code checking

Automated code checkers are a coming thing. Singapore has one in place, for its prescriptive codes anyway [www.corenet.gov.sg], Norway has one [www.byggsok.no] and the USA is proposing one [www.iccsafe.org/SMARTcodes]. The UK should be looking into this, especially given that much of the expertise is based here. A prerequisite is that the project documents are in a standard format, so they can be interrogated by the software. If this format is ifc-compliant, then there are other advantages for the project, e.g. use of simulation and clash checking software is enabled.

Referenced documents

Many British Standards and other documents are referenced from within the guidance. One suggestion already made, by others, is that such documents should be available online at no cost, just as the guidance documents themselves are. Otherwise one’s ability to comply is dictated by one’s ability to pay – a real problem for domestic projects, for example.

Unfortunately the cited documents are not all current, and in some cases have been withdrawn and superseded. DCLG confuses things even more by sometimes listing, in the lists of references, and even in the text, both the withdrawn version and the document that supersedes it. For specifiers (and NBS) this creates a dilemma – does the specification cite the current edition (as the courts would expect) or the edition cited in the guidance to the regulations? The guidance states that the relevant version is the one listed at the end of the document, but that a revised version may be used provided ‘it continues to address the relevant requirements of the Regulations’. How are specifiers to determine this? And if the revised version does address relevant requirements, why isn’t it (and only it) cited, thereby removing any ambiguity?

The BCA faced similar difficulties, resolved when the Australian Building Codes Board and Standards Australia signed a memorandum of understanding. This requires: ABCB staff to sit on committees for standards which are to be cited in the BCA; a guarantee that such standards will be adopted by the BCA; a promise to limit the scope of such standards to regulatory matters; a promise to cite only current standards in the BCA; and an undertaking to issue such standards and the associated amendments to the BCA at the same (fixed) times each year. All sensible stuff.

Compliance specifications

The various UK building regulations each address the nature of the documents to be submitted to building control, and each have quite different requirements. Complicating things are LABC guidelines and the requirements of individual authorities. A sensible national standard set of requirements would be helpful. These would stipulate that a ‘compliance specification’ be submitted, along with drawings and the like, and would define the requisite breadth and depth of these documents.

One problem with the project documents (drawings and specification) being submitted is that they are not aligned to the attribute-based structure of the Approved Documents (fire, structure etc). The specification is aligned instead to CAWS (i.e. systems and trades), for example, and its scope is geared to construction rather than compliance. There are three solutions:

Structure the compliance specification (at least) to match the ADs.
Map between the project documents and the ADs, so the BCOs know where to look for compliance information.
Restructure the ADs to match the project specification.

For the first, NBS might be able to tag items in its master specification to enable this to be done – this would take some time, maybe as part of the Next Generation NBS project. For the second, NBS could relatively quickly create a mapping template, which could be delivered online. For the third, NBS could offer this structure online, on its Building Regulations website [www.theNBS.com/BuildingRegs], but again this would take some time. All would require input from DCLG and/or LABC.

Having got an approved design, we must ensure that it’s built – which requires on-site enforcement of the project documents, discussed in NBS Journal 08. Perhaps ‘approved’ architects and other contract administrators could take on some of the BCO’s enforcement role, as alternative neutral third parties?

Scope

The building regulations might be extended to include maintenance and operation such that a building continues to comply with the regulations in force at the time it was erected.

It would also be helpful if the building regulations served as a one-stop-shop on the regulation of the design, construction, use and demolition of buildings, collecting and/or referring to all other relevant harmonized (e.g. two-part) regulations.

If you have any views on this issue, the DCLG would like to hear them. Email comments to enquiries.BR@communities.gsi.gov.uk.

John Gelder, Editor

Written May 2007