Energy Efficient Scotland: recommendations from quality assurance short life working group

Chapter 1: Quality

Robust Consumer Protection and Enforcement Across the board there will be robust consumer protection that focuses on high standards of quality, customer care, competence, skills, training and health and safety. The Programme standards will be robustly enforced.

Quality: Underpinning Energy Efficient Scotland

Trust in Energy Efficient Scotland and demonstrable realisation of the Programme's potential benefits for all of its customers are crucial to the Programme's success. As the principles set out, consistently high levels of customer care, a focus on good workmanship and ensuring that only the most appropriate measures are installed in each building will form the basis of the quality assurance framework, and effective enforcement of these standards will build trust and consumer confidence in the Programme . The SLWG wanted to ensure that the Programme's quality standards are robust and that they underpin all of the work completed as part of Energy Efficient Scotland. As such, quality intersects with all other topics considered by the SLWG and was therefore the first topic to be explored.

The Short Life Working Group perspective

The subject of quality was a recurring theme throughout all five meetings, with the main opportunities identified as follows:

• Industry are likely to find it difficult to fully commit to the Programme without certainty on investment and delivery timescales. Energy Efficient Scotland provides a long-term vision until 2040, but it will be crucial to have clarity on the Programme delivery mechanisms. This will provide a level of comfort to ensure industry buy-in and allow industry to make the commitment required to participate in the Programme;

• We must learn lessons from previous programmes such as the Green Deal to ensure that Energy Efficient Scotland becomes a high quality, trusted brand;

• As certain measures, such as External Wall Insulation (EWI), are currently not recognised as a distinct trade, this has led to no formalised training taking place in Scotland. Energy Efficient Scotland provides an opportunity to address this to ensure work is completed by appropriately-trained and competent suppliers;

• Installers' understanding of what is technically appropriate e.g. which materials should be used for a particular property, is crucial to the maintenance of quality standards.

Recommendations

The recommendations outlined in this section seek to address the issues raised and opportunities identified, from the quality of the technical execution and the long-term impact it has on the building fabric to timeliness of the work done and customer care.

Recommendation 1. There should be Quality Assurance criteria developed which detail the key mandatory requirements for suppliers wishing to participate in Energy Efficient Scotland.

The requirements should include:

• Skills and competencies broken down by measure and building type;
• Quality management;
• Customer care;
• Fair work practices;
• A Code of Conduct;
• Workmanship guarantees;
• Contractual arrangements with customers;

These should be integrated, where possible, with existing quality assurance measures as provided by trade and professional bodies and should be fair, proportionate and not cost prohibitive where possible. However, where it is identified that these existing models do not satisfy the high quality standards and customer care requirements of Energy Efficient Scotland, Programme-specific criteria should be developed to ensure that robust quality assurance is in place.

Recommendation 2. There should be a Quality Mark for Energy Efficient Scotland and suppliers wishing to take part in the Programme will have to demonstrate that they meet all of the requirements (set out in Recommendation 1) through a robust vetting and verification process to achieve the Quality Mark. All approved suppliers should be listed on a publicly available Directory and where possible the use of operative ID cards should be considered.

In addition to verifying that suppliers meet the criteria set out at Recommendation 1 the vetting process must include checks and verification of:

• Credit and trading history of the business; and
• Criminal convictions of Directors, other senior management staff and operatives;

The Quality Mark should be licensed for use only by approved suppliers and only those using the Mark should be listed in the Directory.

The publicly available Directory should be maintained centrally so that it is easily identifiable by consumers. Further work will need to be undertaken to identify how this might be implemented and ensure that the Directory is successfully marketed to consumers and this is explored further in Chapter 3: Consumer Protection.

If suppliers are found to be non-compliant with any aspect of the criteria e.g. through ongoing independent inspections, they should be subject to sanctions which could include closer monitoring of their work and, ultimately, removal of the Quality Mark and their place on the Directory.

An Energy Efficient Scotland operatives Identification card could display the Quality Mark and thereby clearly demonstrate approved supplier status to consumers. However, this should be balanced with the myriad other card schemes which currently exist, such as Gas Safe and Construction Skills Certification Scheme (CSCS), and will be considered as part of quality assurance criteria research (outlined at in Recommendation 1).

Recommendation 3. The verification process must not place an undue administrative or financial burden on SMEs, particularly micro-businesses.

The quality assurance criteria (Recommendation 1) should allow suppliers to achieve the Quality Mark, regardless of company size or the location of their base of operations, including remote, rural and island areas. An option to allow suppliers a set period of time (6 to 12 months) to complete any required elements of the criteria should be considered whilst exploring how quality standards can be maintained under the Programme in this set timeframe. This would ensure that suppliers are not locked out of the Programme, while providing them with an opportunity to upskill staff.

Recommendation 4. Define what success looks like in terms of quality for the building, consumer and funder, and set specifications for the final output of work.

What success looks like for a particular building could be based on pre-determined building archetypes and should include both technical and social outputs e.g. quality of workmanship, reduction in energy usage and bills as well as improvement of thermal comfort.

Target outcomes should also take the householder's circumstances into account. For example, in a setting where householders cannot afford to maintain a warm home, the energy efficiency improvements might not lead to a saving in energy bills but may improve the thermal comfort of the residents. Furthermore, implications of the installed measures for indoor air quality should be carefully considered as unintended consequences, resulting in poor occupant health, can arise if there is a lack of ventilation or due to materials used .

The quality specifications for the final output of work should ideally apply to all work completed under Energy Efficient Scotland where an approved supplier is used, regardless of funding source. However, this will be dependent on the Programme delivery mechanism and this will be explored in more detail in due course. Therefore, we recommend that, in the meantime, the quality specifications apply to all work where public funding is made available and an approved installer is used.

Energy efficiency solutions should also be sufficiently monitored and evaluated to demonstrate their performance to help build consumer confidence in measures applied. Solutions should align with definitions of success and could therefore assist in building trust in the Programme, which will also be complemented by the implementation of independent inspections, suggested in Recommendation 6.

Monitoring and evaluation of Energy Efficient Scotland is being developed as part of a dedicated work stream which will consider evidence from the delivery of Scotland's Energy Efficiency Programme and Energy Efficient Scotland pilot projects [8] as well as schemes such as Home Energy Efficiency programmes for Scotland: Area-Based Schemes (HEEPS: ABS) and Warmer Homes Scotland.

Recommendation 5. A new designer role should be considered to ensure that that a whole building approach is taken and that only the most appropriate improvements are applied in practice.

The designer could be responsible for the technical specification of improvements that could be made to a building as a whole, including connectivity and smart technology integration. Where a designer may be required (outlined in Recommendation 8) they would be expected to take ultimate responsibility for the retrofit work undertaken in the property.

This level of intervention is unlikely to be required in all circumstances and this could be determined on a risk, cost, property type or measure-based approach. As the specifics of the role are developed, the criteria for when a designer should be engaged should be identified.

Recommendation 6. Independent inspections of installations must be carried out as part of Energy Efficient Scotland to ensure quality standards are being consistently met.

The nature and rates of inspections should be clearly defined, related to expected outcomes (Recommendation 4), and focussed on the technical quality of the work undertaken. As outlined at Recommendation 2, the independent inspections should also be linked to the approved use of the Quality Mark and help to identify where sanctions need to be applied. The rate at which inspections are carried out for a particular supplier could vary over time and could be related to the length of time that supplier has been on the Energy Efficient Scotland Directory and/or their performance (Recommendation 2).

There should also be a consideration for the frequency of inspections depending on the type of retrofit. For example, External Wall Insulation could require a follow-up inspection after a period of 5 to 10 years as it may take time before any associated problems become evident. This will allow suppliers to build up a body of evidence on their quality, performance and competence and for the monitoring of wider Programme outcomes.

The development of inspections under the Programme could be done with input from organisations already carrying out inspections of building work such as Warmworks Scotland, Changeworks, Pennington Choices, Historic Environment Scotland and local authorities. Monitoring outcomes should be aligned with the wider Energy Efficient Scotland review period and if the inspections show that outcomes are not being achieved, a process should be put in place to address this.

As the delivery mechanism for the Programme is still being developed, further work should be undertaken to explore who would be best placed to conduct these independent inspections, whether there could be a central point of inspection record collection, how this could be used to inform future Programme development and how will this be linked with the ongoing vetting and verification of Directory suppliers (Recommendation 2). In any case, the Group expect the inspection regime and Quality Mark to have real teeth and to be very robust with any supplier that failed inspections on a systematic basis being likely to lose their Quality Mark on a temporary or permanent basis.

The Chair of the Working Group, Ian Cuthbert has joined the Scottish Government on secondment from Energy Saving Trust to lead on developing the quality assurance criteria needed for Energy Efficient Scotland. This work will factor in all of the recommendations in this chapter and will overlap with the work being done by the Energy Skills Partnership (see next section).