Building standards - managing fire risks associated with use of external wall systems: research

6. Interviews with Local Authority Verifiers

83. Following the review of the case studies, the authors conducted interviews with local authorities to clarify the steps they took and decisions they made. The questions put to the local authorities and their responses are summarised below. Lessons that can be learned, and knowledge and/or scope gaps are summarised in the discussion that follows.

Questionnaire

1. What percentage of time reviewing a Building Warrant application is given to external wall systems, including materials and fire barriers.

2. What was the internal process if there is a variation between tested construction contained in the fire testing documentation supplied by the Building Warrant applicant and the proposed external wall design?

3. How was the internal process and discussions leading to the conclusion for Question 2 recorded?

4. What was the decision making process for Building Warrant approval without the Building Warrant applicant submitting product datasheets and/or specifications as part of the application?

5. In your view, would the Building Warrant application process benefit from a separate building warrant stage* focusing on the detailed design of external wall systems (including fire/cavity barriers on external wall system)?

6. What is the procedure for requesting and reviewing product datasheets/specification documents for the external wall systems? Would the guidance tool flow chart in Appendix A assist the verifier in this process?

7. What would be the anticipated % increase in workload to allow the process mentioned in Question 6 to be integrated in the Building Warrant process?

8. For the case reviewed, what was the focus of the inspection work?

9. We think it would be useful to state the focus and intention for any inspection work carried out by the verifier for clarity on what has been covered by the inspection. Do you see any issue in noting this limitation in any inspection report?

10. Does your department have verifiers who are competent to inspect the external wall build up, including cavity/fire barriers on the external wall system*?

*Please note that the purpose of the inspection is not to solve the workmanship issues, but merely to spot the workmanship issues to allow the contractor the opportunity to remediate the issue to meet the approved Building Warrant design information and to reflect the manufacturer’s product literature.

11. If yes, what would be the anticipated % increase in workload to allow the process of inspecting external wall systems to be integrated in the Building Warrant process?

12. Please note that Questions 8-11 are not meant to put the responsibility of checking the workmanship on the verifier. Quality of workmanship is a key consideration in external wall systems. If your department do not have verifiers who are competent to inspect the external wall build up, would you be open to accepting reports of inspections carried out by others (employed by the building warrant applicant) and what qualifications would you expect them to hold?

13. As part of the completion certification submission, we are of the view it would be useful for the Building Warrant applicant to submit final external wall design datasheets/specifications/drawings (including fire/cavity barriers), any external wall inspection reports, and how these meet or differ from the performance criteria of the approved Building Warrant submission. This is to avoid any ambiguity on the final design. What issues, if any, do you foresee with this additional requirement from a verifier perspective?

14. Do you have any suggestions which you feel would help in developing this guidance? This could for example include steps/information that you feel is missing or that need particular focus, or any problems you foresee with this guidance, or problems which may exist currently?

Case Study 1 Interview

84. The local authority verifier working on the project is no longer with the department. The interview below was conducted with a different local authority verifier to understand the approval process/procedures related to external wall system.

85. Response to Question 1. It is not possible to allocate the percentage of time. The local authority verifier didn’t take a record of this. The time spent is dependent on the complexity of the external wall. More time is normally spent when the external wall comprises combustible elements of structure or materials.

86. Response to Question 2. Where variations are present, the local authority verifier will follow up with questions to the building warrant applicant. Specification is crucial in the Building Warrant application process. The European Regulation, which came into force a few years ago, does not allow product placement during the tendering process. Therefore, contractors cannot specify products in their tender. This complicates the process where products specified in the Building Warrant application process differs from the as built design.

87. Response to Question 3. Within the department, there are lots of internal discussions between officers for the local authority verifier to share ideas and experience to determine the suitability of specified products in the Building Warrant application process. However, these are not recorded. For experienced local authority verifiers, the decision is obtained from experience on past products that they reviewed/looked at in detailed before. For less experienced local authority verifiers, they are encouraged to do their own research and seek guidance from more experienced local authority verifier. The department have a digital record of major building case studies. This only records any consultants reports for any major buildings so that any local authority verifiers can refer to them.

88. Response to Question 4. If the product noted on the drawings is new or not familiar to the local authority verifier, the local authority verifier will ask for the product specification to be provided as part of the Building Warrant application process. However, if the product was previously researched in detail by the local authority verifier in his/her previous applications, the local authority verifier may not ask for the product specification if he/she has strong confidence in determining their suitability based on past experience.

89. Follow on response to Question 4 (post interview). The project was dealt with by a local authority verifier with many years’ experience and who had familiarity with similar projects. Therefore, when it comes to matters such as the request or retention of data sheets for particular named products, that is not always requested where it is apparent or already known by knowledge and experience that the product can be suitable in common timber kit situations such as this project. Internet checking and cross referencing is often done by staff on this too in these situations. Whist local authority verifiers can’t unfortunately cross reference with the now retired local authority verifier, that experience will also have been used in the context of this case being a low rise flatted development, where for instance the lowest class of Reaction to Fire is permissible. There is clearly some query over the use of HPL/ products and local authority verifier have not been able to fully go through all drawings and documents to bottom out where it was being used or not, but in the context of Class E, a basic check on the named product can be seen that it is not untested and can achieve performance above E.

90. Follow on response to Question 4 (post interview). On the matter of the drawings not specifying the rating of cavity barriers, the local authority verifier does understand the comment, however at the same them when looking at the specified Tenmat product, it can achieve up to 120 minutes and is in common use. Similarly for the Rockwool barrier product, its use is common in timber kit situations and therefore known to an experienced officer.

91. Response to Question 5. Yes. The preference is for staged warrant applications for large projects. This includes the potential for external wall systems to form part of the staged warrant that deals specifically with façade design. This will allow a local authority verifier to focus on the task at hand.

92. Response to Question 6. Yes, the guidance tool will create consistency in the design team submitting the right information at the right time across different councils in Scotland. The current problem is the lack of consistency in the information submitted by building warrant applicants. Building warrant applicants sometimes resist when more information is requested by local authority verifiers. They use the basis of the information being requested was not mentioned in their past projects with other local authorities.

93. Response to Question 7. There would be no % increase in workload as the local authority verifiers will have to go through the same process in reviewing the drawings and specifications. The guidance tool will benefit the building warrant applicants for the following reasons:

• Submission of the correct information
• If done correctly and truthfully by the Building Warrant applicant, there will be less questioning by the local authority verifier.

94. Response to Question 8. This depends on the skills and knowledge of the local authority verifier. For more experienced local authority verifiers, there will be fewer comments unless they spot issues on site. This may be followed up by further visits. The department adopt the Construction Compliance Notification Plan (CCNP/) when setting out the key stages of inspections during the construction stage. For high rise/complex projects, there will be more inspections than small or medium size projects. There is currently no inspection dedicated for external wall systems. Depending on the construction sequence, the inspection of this may be included as part of the inspection of other passive fire protection systems.

95. Response to Question 9. Any inspection record is kept internally in the department’s digital archive. The lack of inspection reporting for the case study concerned may be due to the COVID/-19 pandemic and the department stepping back on-site inspections. Evidence/photos may be relied upon instead. Any issues identified during the inspections are communicated with the design team and the design team sometimes send photos as evidence on how things were resolved.

96. Follow on response to Question 9 (post interview). Specific inspections might occur simply because of the point in the construction process, such as drain tests or foundation inspections, but as work progresses there can be a multitude of matters looked at during a given inspection. Local authority verifiers’ role under reasonable inquiry is to highlight contraventions of the Building Regulations where the local authority verifier sees them and so the inspection logs generally report on the progress of work. If contraventions are noted by the local authority verifier, then they should be specific as to the areas of construction involved. Ultimately, if the local authority verifier does not observe contraventions, there are no further comments. It is not local authority verifiers’ role to log compliance by having specified areas or checklists completed as to what was seen. That role remains as the legal duty of the owner/developer/relevant person and it is these parties who should have detailed logs of inspections of all construction to prove compliance where required.

97. Response to Question 10. Yes. The department has a project size/experience matrix that tabulates the size of projects and the level of experience required of a local authority verifier to work on the project. For less experienced local authority verifiers, they will work on smaller projects and build up their experience towards larger projects.

98. Response to Question 11. As covered in the answer to Question 8, this is already part of the process. However, if it is proposed to have inspections dedicated to external wall systems, this will require more resources. Response to Question 12. The department would take any report on board. However, this wouldn’t change anything or the current process as the department cannot rely on the inspection reports prepared by others.

99. Response to Question 12 (post interview). The report states: “the applicant may wish to appoint a qualified third party acting for the applicant (such as a Clerk of Works) to carry out site inspections on the behalf of the local authorities.” No such provision exists in the current regulatory system for this approach. A more accurate reflection may well be to read: that the relevant person could appoint a qualified third party who could present their findings/records to the verifier under “reasonable enquiry” for consideration by the verifier”? The Compliance Manager?

100. Response to Question 13. In 2005, the responsibility of signing the completion certificate was moved from the verifier to agent/developer/contractors. Any variation to the Building Warrant approved specification and design should go through the amendment to warrant process. Therefore, there should be no issue with this process in theory. However, the issue is on whether the sub-contractors or contractors would view their own installation/work as a variation that would trigger the need for amendment to warrant. There is currently no independent body to keep check on this.

101. Response to Question 14. No response provided.

102. Response to Question 14 (post interview). The report makes statements that are designed to make the approvals process more robust and reliable. However, comments made are also going to add to the burden on agents and time on assessments and processing of building warrant applications. For examples, details being approved at the Building Warrant stage without products being specified e.g. “mineral wool insulation by others”, leading to a lack of oversight. The ask by a verifier on an agent to specify a particular product becomes too prescriptive and has been resisted by many agents in the past. The performance specifications route avoids restrictions on applicants. The proposed system would lead to greater need for amendments of warrant purely for a change in a product used on site that achieves the same levels of fire safety.

Case Study 2

103. The interview below was conducted with the original local authority verifier working on the project to understand the approval process/procedures related to external wall system.

104. Response to Question 1. Section 2: Fire has more time than other sections devoted to it, perhaps half the overall BW/ time spent on fire, of that the prominent sections are 2.7, 2.9, and 2.14. So maybe 10% overall, but this is difficult to quantity and will be different for each project.

105. Response to Question 2. Put it back to the applicant to change the design or change the product. If the manufacturer says they are comfortable with the proposal, the department would have an internal discussion to gather colleagues’ experience with this/similar products and its use in this system.

106. Response to Question 3. No formal record made, the only record would be that the comment is removed from the next iteration of the Building Warrant report.

107. Response to Question 4. Based on performance criteria stated on detail drawings. If it’s a product the case officer is familiar with they probably wouldn’t request a data sheet. For unfamiliar materials they would do an internet search then request data sheets from applicant.

108. Response to Question 5. A separate stage would result in external wall systems having more time spent on it, which is a good thing. More time would be available to scrutinise the materials/design. It would result in an extended Building Warrant process (additional 20 days) which may not be as good for the applicant.

109. Response to Question 6. Request details from applicant or find data sheets online for materials noted on detail drawings. The flow chart would make it clearer for case officers and for training junior case officers, and applicants will know what will be asked of them. Step-by-step guide will help to prevent things from being missed. Appendix B would help the local authority verifier to decide how they deal with designs that don’t comply and when they need a fire engineer to assist via 3^rd Party check.

110. Response to Question 7. Probably not a lot of additional work because the Appendix A and B flow charts reflect what case officers will be doing anyway, even if only in their heads. As above, formalising the process will prevent things being missed.

111. Response to Question 8. Generally speaking they would do a walk-around from ground to confirm that fire barriers are being installed in line with the fire strategy elevation plans. For this project, they did the walk around but spent most time internally looking at stair locations, for this project the fire stopping company had installed the stopping with a tag on site and a report with photos. The focus for this project was stair locations and lobby protection, and protection to structure. Most of the time the inspections are focussed on keeping an eye out for anything obviously not right. Time constraints is the most difficult challenge, as case officers don’t have the time to look at everything (not that it is their responsibility).

112. Response to Question 9. Inspections are general look-around, there isn’t a specific focus. Stating a specific focus might suggest that the inspection covered more than actually happened. It’s a say-what-you-see approach. The record would say “walkaround of Block A, Stair1, Flat 2, Floor 4, etc”.

113. Response to Question 10. Yes.

114. Response to Question 11. Difficult to quantify. Would expect at least 1 full day on site additional per project, which the department don’t have time for. If there are issues the case officer would need to come back too, so the increase would be significant.

115. Response to Questions 8 to 11 (post interview). Our site inspections records are concise notes that (primarily) focus on highlighting faults identified on site. There is currently no expectation on staff to provide a detailed record of what was inspected where matters are satisfactory. In some cases, photographs of the construction or other records are checked/sampled on site to achieve reasonable inquiry.

116. Response to Question 12. The case officer would be open to this, subject to the qualification level of the third party, and if completely independent. Either an approved certification scheme like SER/ structural engineers register or Gas Safe register would be a suitable approach. Alternatively, Chartered Engineer or Chartered Surveyor would be fine. This would have to be a photographic record with comments, and the case officer would still want to do a spot-check inspection on site to confirm the report aligns with what they can see on site.

117. Response to Question 13. Not many issues as long as the information is targeted. Some of those items might be picked up on site anyway e.g. insulation that has branding all over it. The case officer would see this idea as a positive to increase confidence in the design and reassure the case officer that the changes are suitable.

118. Response to Question 14. Perhaps a more simplified version of the information required at application stage will help the applicants and make life easier for the local authority verifiers. The guidance should include links to the publicly available information regarding the information that each local authority requires at the Building Warrant stage.

Case Study 3

119. The local authority verifier working on the project is no longer with the department. The interview below was conducted with a different local authority verifier to understand the approval process/procedures related to external wall system.

120. Response to Question 1. This is not possible to quantify. For traditional construction such as brick/masonry walls, there will not be much enquiry or time spent on these. However, for new construction such as panel construction, a local authority verifier would look more closely to key elements such as separating walls/floors interface with the panel construction. There is a need to strike a balance in time spent reviewing/requesting information for the Building Warrant to be approved.

121. Response to Question 2. The first step is to review how closely the design aligns with the product tested. If there is a big variation, a local authority verifier would request the product to be replaced with a different product which the test matches closely to the design. Any variation that is beyond the expertise of the department, the department would approach the technical team of the product manufacturer or a 3^rd party experts with the decision making process.

122. Response to Question 3. Any input from 3^rd party experts is recorded in email correspondence. For input from the product manufacturer, this is recorded by short notes. These record of email correspondence or short notes are for the department internal use and focus on the decision making process for Building Regulations purposes.

123. Response to Question 4. For common products, a local authority verifier would not ask for any datasheets or specifications e.g. tried and tested products which have received approval previously and are known to comply. However, the decision of what is a common product is dependent on the experience of the individual officer. The challenge is for the individual officer to keep up to date to the technology/development of the product.

124. Follow on response to Question 4 (post interview). When common materials have been specified with a known performance, product data sheets may not always be requested. All local authority verifiers have completed a competency assessment, where they are members of a professional organisation, they are required to complete and record their continuous professional development, this includes keeping up to date with current construction practices. Local authority verifier provide each officer with access to online Construction Indexes allowing them to research and review products.

125. Response to Question 5. For large buildings, it is normally the case that there will be a separate staged warrant dealing with façade design/external envelope. There is no need to prescriptively require a separate stage for external wall systems. The concern is that focusing only on particular elements may result in other elements of the design being overlooked. The preference is to have a single stage warrant so that everything is looked at holistically prior construction. With staged warrants, it is often the case that work progresses beyond the staged approval which increases the risk of non-compliance.

126. Follow on response to Question 5 (post interview). A holistic approach must be taken when designing and verifying compliance with the fire regulations. The construction of separating floors and walls, particularly the junction details with the external walls are equally important to the overall fire performance of the design. These should not be considered separately. Most large-scale developments include staged applications, a stage specifically for fire only could be beneficial.

127. Response to Question 6. Yes, the guidance tool will create consistency in the design team submitting the right information at the right time across different councils in Scotland.

128. Response to Question 7. The flow chart is hard to follow and a local authority verifier would spend lots of time to understand the flow chart. In order for the verifier not to spend more time dealing with the flow chart, there should be simple template/tick box at the front before the flow chart to summarise the conclusion and information submitted by the building warrant applicant for the verifier to focus on. The flow chart is to aid the building warrant applicant.

129. Response to Question 8. The record keeping for inspection work is not consistent as the 2003 act puts the onus on completion certificate applicants. The inspection responsibility for local authorities was reduced since then up until 2012 when the Oxgangs school case happened followed by the Grenfell Tower fire incident. The department is waiting for guidance from the Scottish Government on the extent of reasonable enquiries for inspection work, as this will dictate the extend of workload/focus of the inspections.

130. Response to Question 9. No issue with this proposal.

131. Response to Question 10. Yes.

132. Response to Question 11. This is dependent on Scottish Government clarification on what extent the reasonable enquiry would cover for site inspections and the scope of responsibility with forthcoming Compliance Plan Managers for high risk buildings.

133. Response to Question 12. The department is in favour of reports from Clerks of Works acting for the applicant with early engagement with local authority verifiers. This will provide confidence on supervision and inspections in addition to local authority verifiers’ own inspections.

134. Response to Question 13. The issue of the final/as built external wall design/specifications/drawings not necessarily matching up with the approved Building Warrant information could be originated from Building Warrant detailed specifications being reviewed at a stage that is too early in the construction stage. Where material shortages arise (as with recent years), product substitutions happen without necessarily being made aware to the department. The suggested solution for this would be:

135.

• Step 1 - Approve the performance criteria during the Building Warrant approval stage as opposed to detailed specifications.
• Step 2 – Work with the Compliance Plan Manager through the Construction Compliance Notification Plan to submit the proposed as built design/specification/drawings that meet the performance criteria several weeks before the construction work starts.
• Step 3 – Provide formal approval by the local authority verifier if the proposed design/specification/drawings meet the approved performance criteria.

This should minimise any inconsistency for the final as built external wall design and as built information by reducing the risk of product substitution going unnoticed.

136. Response to Question 14. The guidance tool is difficult to follow. It may suit the design team as an aid for them to package the correct information for Building Warrant submission. The suggestion is to have a template (tick box) to summarise the conclusion and information submitted by the building warrant applicant at the front before the flow chart. The verifier then focuses on the tick box and information submitted.

Case Study 4

137. The interview below was conducted with the original local authority verifier working on the project to understand the approval process/procedures related to external wall system.

138. Response to Question 1. Depends on how familiar the case officer is with the proposed systems, could maybe range from 5% for familiar systems to 15% for unfamiliar systems. Traditional masonry build wouldn’t have much time spent on it, the focus would be that cavity barriers are provided in line with walls. Rainscreen cladding systems would have more time spent on them by the department. Current code guidance requires non-combustible materials which simplifies the department’s work in assessing materials.

139. Response to Question 2. In the first instance they would refuse the proposals if they were caught, but the officer is not confident they would catch the differences every time. For example, fire barriers installed in configurations different to the tested arrangement noted on the data sheets might not be caught for fire barrier products the base officer feels familiar with, but this might be caught with unfamiliar products they are seeing for the first time as they would read the data sheet fresh. Where the manufacturer confirms that the proposed use of their product is suitable, they would accept this for lower rise (low risk) buildings but for higher rise (and therefore higher risk) buildings they would expect the team to specify a different product. From experience, materials on site observed to be different to the approved process have been the first notification the department receive about material substitutions. The department would request data sheets for these materials if observed and this hasn’t (from immediate memory) lead to materials being removed.

140. Response to Question 3. Emails from suppliers would be saved electronically, but this may not always happen. If it isn’t a high risk building and the change is not viewed as a high risk change the emails probably wouldn’t get recorded. The process for saving information has improved recently due to an improved IT/ system (previously an email could take 5 minutes to save and the current system is a simple drag-and-drop system that saves information in seconds). Data sheets and electronic submissions in the electronic file are stored now, previous hard copy system is no longer used.

141. Response to Question 4. Previously, data sheets for common materials would not have been saved but would have been reviewed. Current applications have all information saved except those the case officer feels comfortable with e.g. mineral wool. More experienced case officers would likely request fewer data sheets as they feel they are familiar with them.

142. Response to Question 5. Don’t see how this would be helpful, as there is already a specific package for external wall systems.

143. Response to Question 6. The flow chart is a good idea, although more experienced staff would likely feel they don’t need it. The best use would be to prevent things being missed and achieve consistency in the queries asked. This would be most useful for the applicant so that they cover all of the required information and design details. For case officers this would be useful as an aide memoir that they’ve requested all of the appropriate information and as an educational tool for junior surveyors.

144. Response to Question 7. This information should be checked anyway, so don’t anticipate extra workload. If each wall type were to be reviewed as suggested this would add time. The review by the department would include less scrutiny for traditional construction so this would be project specific.

145. Response to Question 8. Inspections were once a fortnight for a year, but not recorded. Items were discussed with the contractor on site to reduce time spent with paper trail. Fire stopping and structural fire protection were the main focus of site inspections. External wall systems inspections were limited to from-ground observations that cavity barriers were being installed.

146. Response to Question 9. No issue with this, the department have been asked to specifically state what they have and haven’t seen. The recorded information is still high level though, e.g. “inspected fire collars in Block A”. Not all dialogue on site is recorded. If could be that contractors are advised to mitigate an observed issue and no record is made if this is resolved by the next site inspection. This is considered reasonable by the department as the responsibility for construction quality sits with the site agent. CCNP/ for high rise buildings would state the specific items they want to see, such as fire/cavity barriers and the timing for these.

147. Response to Question 10. Yes, the case officer would like to get to site early to pick up any obvious issues at the start.

148. Response to Question 11. Impossible to put a % on it, would be case specific and higher for rainscreen cladding than blockwork/masonry. Clearly 100% inspection is not achievable.

149. Response to Questions 8 to 11 (post interview). Our site inspections records are concise notes that (primarily) focus on highlighting faults identified on site. There is currently no expectation on staff to provide a detailed record of what was inspected where matters are satisfactory. In some cases, photographs of the construction or other records are checked/sampled on site to achieve reasonable inquiry.

150. Response to Question 12. Yes they’d be open to this, as long as the third party are independent from the contractor. In the past they’ve accepted independent contractors fixing already-constructed details and correcting new issues they identify.

151. Response to Question 13. Currently this would be an amendment to warrant, comparable perhaps to engineers form Q system. This process would be useful as a catch-all.

152. Response to Question 14. The 20-day turnaround for applications would be difficult to achieve if there are lots of data sheets to be reviewed. The Compliance Plan Manager might smooth the whole process and improve certainty by considering the external wall systems design earlier.

Case Study 5

153. The local authority verifier working on the project is no longer with the department. The interview below was conducted with a different local authority verifier to understand the approval process/procedures related to external wall system.

154. Response to Question 1. Can’t quantify as it depends on complexity of the external wall systems and whether they include known products. Also consideration is given to building height and building risk (LABSS/ risk assessment document) i.e. lower risk buildings and known products would have less time spent on them, and more time would be spent on high rise projects’ external wall systems due to higher risk. Time spent will also depend on quality of submission, well laid out concise information would require less time.

155. Response to Question 2. The proposal would be refused and put back to the applicant team to be amended appropriately. Any deviations from tested arrangement would need to be raised with the test body for comment. It would not be sufficient to rely on the manufacturer’s opinion as they have a conflict of interest in terms of selling their product.

156. Response to Question 3. The deviation would remain in the objections list in the report from local authority verifier, and significant emails would be saved in file e.g. comments from manufacturers and test houses. Previously the recording electronically has not been perfect due to the system being slow, but recent IT/ system upgrade has improved speed which improve the department’s electronic recording. Where discussions internally are required, these are recorded on an internal document with 3-4 team members including the conclusions. The conclusions of the internal discussions are communicated to the applicant team in the local authority verifier’s report, when closed out the next iteration of the report would have that objection/comment removed.

157. Response to Question 4. This is down to individual case officer’s experience and familiarity with the products. Often the data sheets have dozens of pages and it isn’t made clear where the relevant fire classification information can be found. Common data sheets aren’t always saved so the information provided for this research project might be inaccurately leading to the conclusion that information is missing.

158. Response to Question 5. This would result in better scrutiny of the information provided. The drawback is the additional administrative steps, but overall would improve quality so on balance this would be positive.

159. Response to Question 6. The guidance would assist with quality of submissions if provided to agents. The department would request that specific reference to the place on each data sheet where the fire classification can be found e.g. “see page 21 for fire classification”. Appendix A and Appendix B will help the Compliance Plan Manager with their role, and it would also serve as a checklist for local authority verifiers.

160. Response to Question 7. As with all new processes, there will be an initial increase in time/work. Eventually, agents will know what information will be requested by the department which will assist with the process. It should be noted that information needs to be targeted too, not a 100 page product sales literature.

161. Response to Question 8. Can’t be certain as the case officer no longer works with the department, but there are inspection notes on file (not provided to officer for case study review). The notes appear to refer to open drain testing, little if any inspections done with cladding, probably focussing on handrails, glass and windows, fire doors, fire stopping/collars, wind and water tightness. Any inspections of external wall systems are therefore likely to have been a from-ground observation that fire/cavity barriers are being installed.

162. Response to Question 8 (post interview). There are blank site inspection records in our files that I cannot explain. However, our records tended to focus on faults noted on site rather than what has been built correctly. In recent years, as part of our reporting and recording process and to speed up the reviews of information being submitted as part of a BW/ application, we ask agents to provide a written response to the matters that we have raised in our reports. This also helps track why a matter has been accepted.

163. Response to Question 9. Department are wary of recording large amounts of inspection information, as the impression could be that the department are covering more during their inspections than is the case. The responsibility for construction quality is the site agent’s and not the department’s so any notes are intended to be spot-checks with limited scope and breadth.

164. Response to Question 10. Yes.

165. Response to Question 11. This would be a large % increase and couldn’t give a precise number. However, the number of locations given for Appendix C is significantly more than is currently looked at by the department on their inspections.

166. Response to Question 12. Yes the department would be comfortable with this approach. They would expect an accreditation scheme or insurance led scheme regarding suppliers. The qualifications would need to be Chartered Surveyor or Chartered Engineer or similar. The supplier would need appropriate PI/ cover and the department would still want to visit site for a spot-check inspection to corroborate the findings of the third party inspector.

167. Response to Question 13. Yes, but the industry needs to be accountable. This proposal would introduce greater scrutiny, and the Building Warrant application fee structure would need to be appropriate and updated. In the short term there would be increased timescales but this would be an improvement in the longer term as all involved in the process become better educated and there would be a more formal record.

168. Response to Question 14. The 20-day turnaround for applications would be difficult to achieve if there are lots of data sheets to be reviewed. The Compliance Plan Manager might smooth the whole process by considering the external wall systems design earlier. There would be improved certainty that the approved designs are reflected on site. The guidance on number/location of inspection points to those carrying out site inspections will assist with clarifying to all (including those outside of the Building Warrant process) the extent of site inspections being carried out, at present the feeling is that the public and senior officers within government/the department do not have a good grasp of this.

169. Response to Question 14 (post interview). Stages A and B of the ‘Guidance Tool’ appear to be an alternative way of presenting the manner in which verifiers carry out their function therefore, I am not sure of the value adopting this approach would add. However, I am sure prior to the adoption of any such proposals discussion would be held with a broader group of verifiers to determine whether it would deliver the outcomes intended. The introduction of the Compliance Plan, whilst adding additional burdens, will help raise the consistency in the checking process both pre and post granting of a building warrant.

170. Response to Question 14 (post interview). It appears from comments made throughout the report that a more forensic record of assessments/decisions prior to granting of building warrants and on-site inspections are expected to be kept. This has not been the case previously in my opinion. The local authority verifier’s Building Standards service works within the requirements of the performance framework and operating framework, has been audited as part of the BSD/ improvement plan and internally as part of our BSI registration. At no time before now have our site inspection records been questioned to this extent and there are no records of non-conformities in our audit reports. If this is the expectation going forward there will be a dramatic increase in the time needed to assess applications and keep such detailed records during the construction process.

Summary of Responses

171. Interviewees were not able to give an estimation of time spent on reviewing external wall systems as this is not recorded. Less time would need to be spent on systems the case officer feels familiar with than unfamiliar systems. Less time would be spent reviewing traditional masonry systems, on these systems the focus would be fire barrier locations.

172. External wall system designs that differ from the tested construction are rejected in the first instance and the applicant is asked to resubmit with appropriate evidence/design. For low rise buildings (i.e. lower risk) the manufacturer’s view may be considered for a minor deviation from the tested configuration.

173. Internal discussions where there are deviations from the tested construction and proposed arrangement are not recorded in any formal way. Advice/information from expert 3^rd parties is saved electronically.

174. The decision to approve materials without data sheets related to fire performance is up to the experience of the case officer. If the proposed product is one they have dealt with many times in the past they may not insist on a data sheet being provided. Less experienced case officers are more likely to request data sheets.

175. A separate Building Warrant stage tends to be made for external wall systems on large projects, opinion was split on whether this should be the case for all projects. It was acknowledged that more time spent on a specific Building Warrant stage for external wall systems would introduce more administration and overall time for the building warrant process.

176. The guidance tool would assist with quality of building warrant submissions, as the applicant will be aware of the information that will be requested of them. The tool will also be useful in the development of junior case officers and as an aide-memoir to more experienced case officers.

177. It was felt that there would be an initial increase in workload for local authorities to understand the Guidance Tool, but that the Guidance Tool is a formalised version of local authorities’ intrinsic process.

178. The focus of site inspections was different for each case study, but there was no specific site visit noted specifically to deal with external wall systems.

179. Some respondents were concerned that stating the focus of the site inspection will give a false impression of a full inspection, whereas their role is to carry out spot checks. The responsibility for construction quality is the site agent’s and verifiers are wary of unintentionally taking on responsibility.

180. All interviewees felt that their department has verifiers who are competent to inspect the external wall build-ups, including cavity/fire barriers in the external wall system.

181. The interviewees felt that there would be a significant increase in workload if the site inspections were to be integrated into the building warrant process, but were not able to give a specific time. The time spent would naturally vary from project to project based on differences in size, and number and design of different wall types.

182. Interviewees were mostly comfortable to accept the checking of quality of workmanship to be carried out by others, provided they were appropriately certified/experienced. This may require an accreditation scheme to be created by the Scottish Government. Interviewees noted that this would not completely replace site inspections by local authority verifiers, who would still carry out spot-check style inspections. One interviewee also pointed out that there is no mechanism in the current regulatory framework for others to carry out site inspections on behalf of local authorities; and that this process would need to involve the third party presenting their findings to the local authority verifier to fit within the current regulatory framework instead of directly replacing inspections by local authority verifiers.

183. The introduction of a final external wall design compared to the Building Warrant design would introduce additional time to the Building Warrant process, the current way of dealing with this would be an amendment to warrant.

184. The Guidance Tool is useful but difficult to understand, requests for a simplified version and/or tick-box to confirm that the design team have followed the steps.