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Response to Dame Judith Hackitts Final Report

Posted by wilkinsoncc on July 30, 2018 at 7:55 PM Comments comments (0)

Response to Dame Judith Hackitt’s Final Report

Following the publication of Dame Judith Hackitt’s Final Report, ‘Building a Safer Future: Independent Review of Building Regulations and Fire Safety’, the Government asked to hear views as to how these recommendations should be taken forwards.

We have today responded to the report and provide a summary of that response below.

Recommendation 1.1

We do not agree with this recommendation as we feel that the system should apply to all buildings, and a two-tier system will cause confusion. Whilst we note the scope of Dame Hackitt’s report was framed by Grenfell, but we do not agree that statistics show an increased risk with height. If we review past tragedies such as Summerland, Woolworths, Bradford & Kings Cross , none of these were High Rise buildings. Additionally, far more people die every year in low rise domestic buildings than in High Rise buildings – a fact previously confirmed by the National Fire statistics.

A 10 Storey limit could have other unintended consequences and encourage developers to demolish existing buildings over this height or abandon plans to build them in favour of 9 ¾ storey buildings to avoid the additional burden. This would fly completely in the face of the wishes of existing residents who want their buildings to be safe not to be demolished and rehomed.

If a definition of high risk is to be applied we would consider that it is probably better to link it to the possibility of multiple fatalities, therefore the application of increased burden could apply to any building with an excess of 60 or 220 persons in line with the limitations in ADB.

We would also advise against the term High Risk buildings as this has significant negative connotations in the minds of the public. Possibly the use of High Occupation or Increased Dependency may be better terms.

Recommendation 1.2

We support the setting up of the JCA, but would advise that the JCA should be a separate enforcement body and repository for notices and data rather than being a service provider.

Recommendation 1.3

We strongly agree with the provision of a new user manual.

Recommendation 1.4

We have no comment to make on this recommendation, other than to suggest that it is separate from the BCB service provision – thereby enabling concerns to be raised about BCB’s.

Recommendation 2.1 & 2.2

We agree that these should be clearly mandated to explain responsibilities and that CDM is a good basis for these.

Recommendation 2.3

We agree that these should be provided for all high-risk buildings. We would also like to see simpler versions provided for all building Projects

Recommendation 2.4

We believe that there should be a single system with tiered requirements for detail rather than multiple systems.

Recommendation 2.5

We agree that the LPA should be required to notify the JCA – however we believe this should apply to all building work covered by planning permission. The notification should confirm that a BCB has been appointed and is overseeing the scheme and that the BCB has/will consult with the fire service. Until a copy of that consultation is deposited with the LPA an unconditional planning approval cannot be given.

It should be remembered that internal works notifiable under Building Regs and CDM may be exempt from Planning Permission and this would make the first Gateway redundant on a scheme to say replace all the kitchens and fire doors in a block.

Recommendation 2.6

We absolutely agree that works should not commence prior to a full plans approval. This is probably the single most important of all the report’s recommendations in our opinion. However, the JCA should not be a service provider and instead the requirement should be that a BCB provides a copy of the full plans approval to the JCA, otherwise we would be concerned that the JCA would be overwhelmed.

We would like to see this extended to all projects and additionally that the JCA gets a copy of the F10 and construction phase risk assessments. This is because the construction phase can be the highest risk especially if occupants remain in place. We believe that this would also be useful on minor projects such as domestic extensions.

The CITB app has produced a simple way for small builders to comply with CDM and the https://www.buildingregs4plans.co.uk/index.php website could easily be adapted to enable builders to produce simple compliant plans and specifications, which would not cause undue burden.

Recommendation 2.7

We agree that buildings should not be occupied until a final certificate, O&M, demonstrable records and the FRA are in place. The JCA should have an obligation to enforce if this cannot be evidenced.

Recommendation 2.8

As above we consider that the Gateway points should apply to all building projects. There should be optional boxes for the situations where Planning, Building Regs & CDM apply different definitions, but the concept should be universal.

Recommendation 2.9

We agree that there should be a clearer change management process for all buildings. Any change to the previous approval should be considered by the BCB and notified to the JCA where significant.

Recommendation 2.10

As previously stated all works should be notified to the JCA. To suggest that only a JCA incorporating LABC should oversee the works would mean that something as simple as a resident rewiring a kitchen or installing a power-shower would require the involvement of the JCA. This is likely to result in either severe delay, additional cost or more likely both. If instead the CP had to provide a detailed plan showing any fire safety features, specifications of work, risk assessments and evidence of the completed works there is no reason in our opinion why self-certification could not continue.

Recommendation 2.11

We do not agree with this recommendation as previously explained. AI’s are already prevented from having a financial or design interest in a project. LABC do not have such limitations and are already marketing additional products such as SAP calculations which they submit to themselves for approval https://www.labc.co.uk/consultancy-services. Regardless of the outcome of the review we would ask that it is made clear that it is not acceptable for any BCB to submit documents to itself for review, even if that is produced within a group structure. It should also at the very least be recognised that LABC are conflicted by being employed by the owners of their own buildings and not independent in the way that’s being presented. Indeed, both Lakanal House and Grenfell exposed this clear conflict of interest. Therefore, we would urge that the JCA should be a separate national body, recruiting its own staff/experts to avoid any risk of conflict.

Recommendation 2.12

We make no comment on this recommendation

Recommendation 2.13

We strongly support this recommendation. We also feel that having the JCA independent of LABC would result in greater consistency as we would expect that organisations flouting Building Regulations would typically also be flouting CDM & Fire Safety and even planning approval.

Recommendation 2.14

We agree that the first work on an existing “high risk” building (Subject to how that is defined) should trigger a safety case review if that is not already in place.

However, we would also propose an alternate proposal that all building works should trigger consequential improvements whereby 10% of a projects value should be ring fenced to addressing any deficiencies in fire safety. This could easily be addressed by reviewing the existing FRA and money spent on upgrades. For example, a proposal to replace the windows in a block would trigger a requirement to spend at least 10% upgrading any existing non-compliant fire doors, or installing smoke detectors, or some similar upgrade. This concept already exists in AD L and would create a culture whereby all building work considers the safety case first.

Recommendations 3.1, 3.2, 3.3, 3.4 3.5, 3.6, 3.7, 3.8,

We agree with these proposals in full (but note previous comments about the composition of the JCA)

Recommendations 4.1, 4.2, 4.3 , 4.4, 4.5, 4.6

We agree with these proposal’s but additionally feel that all buildings should display a summary A-F style FRA in the same way as an EPC is displayed. This is likely to drive owners to want to improve ratings. It could also be used to prevent the sale or rental of buildings falling below a minimum (Say E) rating.

Recommendations 5.1, 5.2, 5.3, 5.4

We agree with these proposals

Recommendation 6.1

We agree with the concept, but the emphasis should be reversed, and the Government must validate guidance produced by industry. The creation of the flawed BCA guidance note 16 on cladding shows how confusing industry generated guidance can be.

We would also see that this is part of the function of the JCA rather than “Government”. We strongly recommend the JCA provide FAQ’s and possibly live chat to help point BCB (or designers) to the correct interpretation.

We are aware that previous civil servants have deliberately acted to make it difficult to get advice, guidance and determinations with the consequence that there is inconsistency in interpretation and even competition on interpretation which does have the capacity to drive standards to the lowest level.

Recommendations 6.2, 6.3

We agree with these proposal’s and are working to produce an easy to use app and would be more than happy to demonstrate this further.

Recommendations 7.1, 7.2,7.3, 7.4, 7.5, 7.6, 8.1, 8.2, 8.3 , 8.4

We agree with these recommendations but would go further. We believe all products should be capable of being scanned by smart phone with GPS recording to confirm the exact details, batch numbers, the installers signature/qualification, and the location the product is installed in the building. 

Recommendation 9.1, 9.2, 9.3, 10.1

These recommendations are outside our scope of expertise and we make no comment

Resources Generally

In addition to the recommendations made above we have significant concerns about the current levels of resources and competencies of BCB. Despite claims from LABC that they have the resources it is our opinion that the system is already over stretched.

We are also concerned that it is assumed that AI’s will offer support to LA services. In most cases AI’s left employment by LA as they did not want to work in the public sector, we cannot see them returning to that sector. It is also likely that the nature of LA procurement will mean that SME would be unable to compete with larger organisations to provide this back up. Its likely that organisations such as Capita, Interserve etc will see this as an opportunity to add to their existing service provision to LA. This would result in the unintended consequence of outsourcing BCB functions and could risk another “Carillion” collapse.

Conclusion

Overall, we feel that the report is a significant move forward building on the 2009 Future of Building Control Implementation Plan, and BD2510  Scoping report on MOT tests for buildings.However, it is important that we do not wait another 10 years before actioning the recommendations.

Our prime concerns are the role of the JCA, the confusion a two-track system would create, and resources generally. We have set out alternate solutions on these issues and would be happy to discuss them further if the opportunity arises.

The Regs: Take care when building over drains and sewers

Posted by wilkinsoncc on July 30, 2018 at 8:30 AM Comments comments (0)


Geoff Wilkinson looks at problems arising from failure to identify where drains run

One of the most frequent problems we see with small projects arises from the failure to check whether or not there are drains running beneath the footprint of a proposed building or extension.

Building Regulation H4 requires that when building within 3m of a public sewer, or within 1m of a public lateral drain, you’ll need water authority approval before work begins. Even if the drain is not a public sewer or shared drain, failure to identify the location of the drain can still cause major issues if there is a conflict between the line of the drain and the line of the structure above.

Failure to identify the depth of the drain can also cause problems. A shallow drain might be too shallow to enable drainage from the new project to function correctly, or it might clash with the floor slab. Equally, a deep drain might require significantly deeper foundations than were originally assumed or priced for.

The RIBA Plan of Work for small projects places the production of drainage plans in Stage 4, but this is too late if the drains are found to clash with the building – which can require a full reapplication to be made for planning permission.

Instead I would recommend that a search for the location of drainage should be conducted at Stage 2, when the feasibility of the project is considered, and prior to obtaining a planning consent that may simply not be buildable.

Access points on a sewer may need to be relocated as part of the works and included in the design

It should be remembered that the Building Regulations state that in some soils, such as sands or silt, buildings must not be constructed over or within 3m of a drain unless special measures are in place.

Additional restrictions apply if the drain is a rising main, constructed of brick (a traditional Victorian culvert, for example), or if it is damaged or in poor condition.

Buildings and extensions should not be constructed over a manhole or inspection point on a sewer. Access points on a sewer may need to be relocated as part of the works and included in the design. The extension must also maintain a 3m zone to enable the sewer to be reconstructed in the future if the water authority deem it necessary, and that zone should also be accessible to a mechanical excavator, depending on the depth of the drain.

Building Regulations also restrict the length of drain or sewer that can be built over to a maximum length of 6m.

Lastly, if the drain is greater than 225mm in diameter or greater than 3m in depth, then again special consent will be required, which could affect the viability of the project.

In most cases applying for permission is simple and can be done using a self-certification questionnaire online, although some water authorities are much more helpful than others and a simple national system would help remove regional variations. If you aren’t able to self-certify, you can instead apply for an approved build-over agreement, which should be supplied to the Building Control body prior to the works commencing.

If a build-over agreement is required, then a number of important restrictions are likely to apply. These vary by water authority, but typically include:

  • All new works must be done in like-for-like materials and comply with the requirements of the latest version of ‘Sewers for Adoption’, in conjunction with ‘Protocol on Design and Construction of Adoption of Sewers in England and Wales’. For example, plastic drainage may not be acceptable if the existing drain is manufactured in clay.
  • The proposed works must not transmit any additional loads to the sewer, and foundations must be taken below the invert (internal pipe base) level.
  • It is your responsibility to check and verify the invert levels and position of the public sewer prior to works on site.
  • Any sewers that are up to 1.1m deep from ground level to invert must maintain a minimum 150mm gap away from the foundations.
  • Any sewers where the invert level is more than 1.1m below ground level must run at least 500mm away from the foundations.
  • If the invert level is more than 2m below finished ground level, any proposed foundations must be at least 1m from the sewer.
  • Piled foundations must be a minimum of twice the pile diameter or 1.5m (whichever is greater) from the outside of the pile to the outside of the sewer.
  • Driven piles are not permitted within 15m of a public sewer.

So: don’t leave it too late in the project to check where the drains run; ideally, pick it up during the initial site survey.

This article originally appeared in the May issue of AJ Specification

https://www.architectsjournal.co.uk/opinion/the-regs-take-care-when-building-over-drains-and-sewers/10032498.article


Illustration (C) Thames Water Utilities Ltd https://developers.thameswater.co.uk/Domestic-and-small-commercial/Building-near-pipes/Building-over-or-near-a-sewer

The Regs: How to get a highly glazed extension to comply with Building Regulations

Posted by wilkinsoncc on June 15, 2018 at 11:15 AM Comments comments (0)

The Regs: How to get a highly glazed extension to comply with Building Regulations


If you have ever wondered how an architect got that glass box extension past building control, then Geoff Wilkinson has the answer



There has been a huge trend in demand for extensions that join internal living spaces to the garden by way of large areas of glazing and ever larger opening bi-fold doors. However this sleek and transparent look desired by homeowners can be at odds with Building Regulations Part L, which sets targets for the building envelope’s energy efficiency.

Part L limits the total area of openings or glazed elements, such as windows, roof windows and doors, to a maximum of 25 per cent of the extension’s floor area. A small extension with a set of patio doors and a lantern light can easily use up this 25 per cent allowance.

An extension that exceeds the allowance is generally referred to as an ‘over-glazed extension’, but they can also be known as sun rooms, orangeries or even glass-box extensions.

Architects will find that, where the 25 per cent rule is exceeded, building control will either reject the plans or request further justification for the over-glazing. So how do you get an over-glazed extension to comply?

Well, although the extension is not compliant on an individual element basis, it could still pass L1B regulations using one of the alternative methods set out in the approved document.

The first thing to do is to deduct the total area of any windows or doors that, as a result of the extension works, no longer exist or are no longer exposed. This is because the heat lost through these elements is no longer being lost. In many cases you will find that this is all you need to do, and a quick schedule of openings versus covered openings may be all that you need.

For example: if an extension has a floor area of 30m² and is covering an existing patio door with an area of 4m² then the extension is allowed to have 6m² (25 per cent rule) plus 4m² (existing openings rule) making an allowable area of 10m². Submit that with your Building Regs application and it’s likely to sail through the checking process.

But if this still isn’t enough then the next option is to demonstrate that the proposed extension is no less compliant than if an extension of the same size and shape was built according to the 25 per cent limit. For example, you could increase the thermal resistance (U-value) of the walls, floor, roof, or glazing elements above the default values in order to increase the area of glass.

From experience I can say that in most cases the heat loss though the glazing will dominate, so start there. Given that the default U-values for walls, floors and roof should all be in the range 0.16-0.28W/m2K, there is not much you can do to significantly improve these. However, the notional glazing has a U-value of 1.6-1.8W/m2K and means that high-performance, gas-filled, low-e-coated glass could see the U-value tumble to 0.9 or better, allowing you more than 40 per cent glazing. Take out some covered-up openings and a 50 per cent glazing ratio is easy to achieve.

But if the extension is very highly glazed (more than 50 per cent), you may need to use the Standard Assessment Procedure (SAP). These calculations should be carried out by an accredited SAP assessor, and demonstrate that the calculated carbon dioxide (CO2) emission rate from the dwelling with its proposed extension would be no greater than the dwelling and a notional fully compliant extension of the same size and shape. This method allows you to keep almost 100 per cent glazing by upgrading existing elements and services within the original part of the house instead – for example, by installing a more efficient heating and hot water system, or increasing the insulation within the existing roof space.

The SAP method allows you to keep almost 100 per cent glazing by upgrading existing elements within the original part of the house

The building control officer may well confuse matters by asking for ‘excess glazing calculations’, ‘SAP calculations’, ‘heat loss calculations’ or ‘thermal calculations’, but in truth all four terms mean the same thing. If you are not qualified to carry out these calculations yourself then I would recommend Googling ‘heat loss calculations for over-glazed extensions’ and you will find a number of consultants that can produce them for you.

In many cases it’s only a couple of hours work for them and a budget of £250 can usually cover it – a small price to pay for that award-winning, highly glazed look on your project.

This Article first appeared in Architects Journal https://www.architectsjournal.co.uk/opinion/the-regs-how-to-get-a-highly-glazed-extension-to-comply-with-building-regulations/10022424.article

Chloes Wedding

Posted by wilkinsoncc on May 31, 2018 at 7:55 PM Comments comments (0)

Congratulations to our longest serving employee Chloe Still on her marriage to Dave Prentice on 24th May 2018.

The Wedding took place in the fantastic venue at the Lost Village of Dode and even featured both a Owl and a Magician.

We wish them both the very best for thier future together



Dont get your fingers burnt on a kitchen project

Posted by wilkinsoncc on May 29, 2018 at 8:40 AM Comments comments (0)

The Regs: Don’t get your fingers burnt on a kitchen project

Geoff Wilkinson looks at the potential pitfalls of kitchen, utility and bathroom schemes

Work to a kitchen, utility room or bathroom can seem like the simplest of projects an architect can deal with, but they can be a minefield if you aren’t sure when you need Building Regulation approval.

A very simple refresh with new units and fittings does not generally require approval, however moving sanitary fittings such as the sink or toilet or carrying out electrical works as part of a refit may do so.



Source: Agnese Sanvito

Whitehill Farm, Dunstable, by Hampson Williams Architects

If a bathroom or kitchen is to be provided in a room where there wasn’t one before or you are knocking down a wall (loadbearing or not), Building Regulations approval is likely to be required to ensure the room will have adequate ventilation and drainage, and meet requirements in respect of structural stability and electrical and fire safety. If in doubt always check with a building control body – either the local authority or an approved inspector. Here’s a quick guide to some of the pitfalls to look out for:

Part A Apart from the obvious issues of removing a structural wall, if you are changing the use of a room (eg installing a large bath or jacuzzi in a bedroom) this could increase the load on the floor structure and require strengthening the floor.

Part B Making an open-plan space by removing doors or walls between the kitchen and other rooms, particularly to a staircase, will affect means of escape. Additional precautions in other parts of the property may be needed, such as escape windows, interlinked smoke and heat detection, additional fire resistance or even sprinklers.

Part F When inserting or removing an internal wall, care should be taken not to make ventilation worse. Any new kitchen, a toilet with no openable window; a bath/shower room or utility room should be provided with a mechanical extract fan. The type of room will determine how much ventilation is required. Part F says that where a kitchen previously had only a recirculating fan this can be retained/replaced if it is made no worse. However, I would always recommend fitting an extractor to deal with condensation.

• Kitchen: 30l/s if over the hob and 60l/s if placed elsewhere

• Bath/shower: 15l/s with overrun

• Toilet: 6l/s with overrun

• Utility room: 30l/s

Part H Replacing existing fittings on a like-for-like basis is not controlled. However, if the installation of the fittings will extend or make new connections to a drainage stack or an underground drain, the above-ground wastes and drains are controllable.

Part L If you install or replace a window or external door as part of the works, it will need to comply with Part L Heat Loss in all cases. It may also need to comply with Part A Structure if the opening is made wider; Part K Safety Glazing if the glass is at low level; and possibly Part B Fire Spread if the glass is within 1m of the boundary, for example.

Part J This obviously applies if you install a new boiler, but also if you move the boiler to another location or even if you leave the boiler where it is but extend the flue. Also, if hiding a boiler in a cupboard, take care to ensure there is adequate ventilation and access for servicing.

Part M Another area where you may get caught out is simply moving a ground-floor toilet, since most houses constructed after 1999 will have a ground-floor toilet installed, which has been designed to cater for any visiting wheelchair users. During any refitting, this toilet should not be removed and the accessibility of the toilet should not be made any worse, as it would then be inadequate for future wheelchair users.

Part P Electrical work may be non-notifiable unless a new circuit is provided. For example, installing a new built-in cooker or prefabricated modular lighting is non-notifiable unless a new circuit is required. Even so, be wary of affecting:

• structure (depth of chases in walls, notches in floor and roof joists)

• fire safety (fire resistance of penetrations through floors and walls)

• sound (service penetrations on party walls)

• replacing energy-efficient lighting with inefficient lighting

If a new circuit is being installed or it is within a wet zone (eg adjacent to a bath or shower) then it will require approval or self-certification under Part P.

This article originally appeared in the https://www.architectsjournal.co.uk/opinion/the-regs-dont-get-your-fingers-burnt-on-a-kitchen-project/10031324.article#" target="_blank" rel="nofollow">April issue of AJ Specification


Combustible Cladding Policy

Posted by wilkinsoncc on May 21, 2018 at 8:55 AM Comments comments (0)

The Hackitt report was published last week and like many we were shocked at its conclusions, and importantly its lack of them in relation to cladding.

Given the clear case for action on combustible cladding and the ease with which an amendment could be made by issuing a corrigenda amendment to Approved Document B, we cannot understand why Dame Hackitt did not make this move a top priority.


As it stand there are no changes to the guidance in the Approved Documents and designers and contractors could continue to use Desk Top Studies to justify the use of untested cladding systems. This simply cannot be right.


We note that LABC have produced guidance saying they will continue to accept not only method 3 desktop studies but even method 4 studies subject to certain restrictions. This is all the more concerning as Dame Hackitt has suggested that only LABC should continue to approve High Rise buildings effectively banning Approved Inspectors working on them. This despite both Grenfell Tower and Lakanal House being Local Authority projects.


Over the next few weeks we will be making a series of posts reviewing the Hackitt report and setting out what we believe to be a better and more logical solution to the problems with the current system.


However in the meantime whilst we can continue to deal with High Rise Buildings (and in the longer term on buildings between 18m and 10 storeys) WCCL are today announcing the following policy.


1) We will advise clients to adopt the following strategy set out in BS 9991 2015 as though it supersedes the Approved Document - e.g.


• The external surfaces of walls should meet the provisions in Figure 17.

• In a building with a storey 18 m or more above ground level, any cladding material, insulation product, filler material (not including gaskets, sealants and similar), etc., used in the external wall construction should be of limited combustibility.

• Cavity barriers should be provided in accordance with Clause 19.

• External balconies that are enclosed should be constructed and separated from other enclosed balconies with compartmentation and fire-resisting construction in accordance with Annex D.


2) Where clients wish to use combustible construction despite our advice, then the external walls must meet the performance criteria given in BRE Report BR 135 for cladding systems. We will require full scale test data from BS 8414-1 or BS 8414-2 for the exact system to be used. We will not accept any variation from those test results and or desk top studies in any form to justify the use of combustible materials in systems that have not been tested.


We appreciate that this policy may result in losing projects to other BCB who do not take this approach and that this approach may be challenged by those producing combustible cladding products. However, pending the full outcome of the Grenfell Inquiry and revised updated guidance being issued by MHCLG we do not believe that it is appropriate to do nothing. We therefore call upon all BCB and those involved in construction to adopt the same consistent approach and to provide reassurance to those living and working in high rise buildings that cladding is safe.




Hackitt Report

Posted by wilkinsoncc on May 8, 2018 at 5:45 AM Comments comments (0)

The much awaited Hackitt Report into the future of Building Control is due to be published soon.


In this blog we look at the changes to the system that we would like to see in the recommendations.


  1. Approved Inspectors have no powers of enforcement unlike Local Authorities. This needs to be reviewed and either powers given to Approved Inspectors or a new National Enforcement Body set up to ensure a level playing field. In addition powers should be introduced to enable on the spot fines and stop notices to be issued in line with the way the HSE currently enforce CDM regulations.
  2. There needs to be consistency on service delivery and a single overarching licencing body should be provided to licence and oversee both public and private sector BCB - a sort of OFFWAT for Building Control. The current Licensing body for Approved Inspectors (CICAIR) would be well placed to undertake this role, however would need additional resources and enforcement powers.
  3. A Golden Thread is required to preserve the original design intent throughout and making sure any changes go through a formal review. The current system of Building Notices should be withdrawn and replaced with a requirement for outline Building Control Approval to be in place prior to works commencing on site. This stage would require that plans showing basic fire safety measures (in line with Reg 38 guidance) are submitted, the fire service consulted where applicable and agreed in principle prior to works commencing
  4. All projects should have a single designated person to take responsibility for co-ordinating Building Regulations compliance. This role already exists on the statute books and is known as an Appointed Person. However this section of the Sustainable and Secure Buildings Act has never been enacted
  5. To ensure that there are no conflict the Appointed Person should ensure that all BCB are assessed prior to appointment and that they have the necessary resources and experience for the nature of the project. Additionally there must be no conflicts of interest and the BCB should not have any design or financial interest in the scheme - for example the BCB should not own the building and should not directly or indirectly (for example as part of a group of companies) be involved in designing the scheme.
  6. Building Control fees ideally would be set against a national fee scale to help prevent competition on price, and should be paid in advance (eg at application stage) to ensure that there is no conflict of interest and no pressure to sign off non-conforming works in order to receive payment.
  7. The regulations themselves need to be simplified and Government should take a greater role in determining interpretation rather than leaving it to industry. For example the BCA Guide 18 that allowed the use of desktop studies should not have been produced and instead Government should have stepped in to clarify the correct interpretation. This can be done through the use of an smart phone App to improve access to the regulations and a FAQ section allowing questions to be posted and replied to.
  8. We would like to see the guidance on Cladding clarified to permit only systems that are either Limited Combustibility or have been tested in the exact combination to be used. It will also be necessary to improve the collection of data to show what materials have been installed and where, for example in the event of a future product failure it should not be necessary to undertake removal and destructive testing as was the case at Grenfell. This could be achieved by manufacturers bar coding products and builders using smart phone technology to GPS position and record exactly what product and batch was used on what building – again uploaded to a national database. Where BIM is used this would also flag up instantaneously any deviations in design or product substitution and ensure the Golden Thread is maintained.
  9. British Standard Fire Tests should be reviewed to ensure that the current assumptions on fire growth (Eg time and temperature) accurately represent the increased use of plastics within buildings.
  10. The Regulations on controllable works need further clarification, as even minor works such as installing cabling can breach fire separating or compartment walls, replacement doors can also reduce fire protection, and these elements need to be captured either through self certification by competent contractors or by formal Approval.
  11. The current regulations do not require retrospective improvements for fire safety - so a tall building that does not have sprinklers can continue to be non-complaint as long as works are not made worse. We would like to see the introduction of consequential improvements for fire safety measures (these already exist for thermal upgrades). This would require that a % of the cost of any project is spent on upgrading fire safety measures and would encourage owners to implement improvements recommended within Fire Risk Assessments. For example if 2% was applied as a bench mark then on a £1M project £20'000 would need to be spent on improving fire doors or fitting sprinklers if these didn’t already comply.
  12. In addition it needs to be made clear that Building Control approval is a minimum standard and not a get out of jail free card. Building Regulation Approval is similar to a MOT certificate – it looks at ensuring the minimum safeguards on the day of the inspection. The culture of industry needs to change and instead of trying to design down to the minimum standards of Fire Safety (or even below them), designers and building owners should compete & innovate to become the safest building. The use of Euro NCAP markings on cars have encouraged motor manufacturers to exceed minimum MOT standards introducing additional air bags, collision detection etc. Elsewhere similar marking systems have encouraged improvements in Energy Efficient buildings and appliances and even in food safety standards. We would like to see the introduction of a mandatory Fire Safety Marking scheme based on the current FRA process requiring a summary to be displayed on all buildings.
  13. We would also like to see a requirement for FRA to be deposited up to a national database accessible to the Fire Service so that they can see that they are up to date and that the recommendations and risk levels can be monitored and enforced as necessary.


Many of these ideas are hardly new and most have been around since the Future of Building Control Implementation Plan published in 2009 a report that has still not been implemented by either the coalition or the current Government.

Guest Blog

Posted by wilkinsoncc on April 16, 2018 at 6:15 AM Comments comments (0)

Just moved home or about to renovate your living and kitchen space? The trend for opening up a property – removing walls to get that amazing feeling of space, as well as making your mark on your home or a new house – continues to grow. However, going open-plan can be a Building Regulations minefield; there are various issues you may come up against, but the key focus is always fire safety. As you weigh up your design options, here are some tips to help you to create a safe and legally compliant open space.

What are the main Building Regulations issues for open-plan spaces?

The main issues associated with open-plan areas are fire safety and safe escape.

For example, is your staircase separated from your open-plan space by a fire door to allow a safe passage out of the building from other parts of the house? Is the kitchen – which is, of course, a fire risk area – closed off by a fire door? What about ventilation? One of the most common questions I’m asked when it comes to open-plan spaces is how to work around the issue of the kitchen fire door, which many people don’t want to install.

You might hear about friends or neighbours who plan to get their Building Regulations Certificate and then remove the fire doors the regulations stipulated they must have, but which they never really wanted. Be aware that this is not only illegal, it’s also unsafe: the regulations are designed to save your life.

So before you get swept away in the excitement of your new, open-plan space, it’s important for your architect to consult with Building Control sooner rather than later to ensure your design is actually achievable. (More on Building Control inspectors shortly.)

If you’re still deciding on your design, take a look at lots of open-plan kitchens for more ideas.

Is there a fire escape route?

One of the major questions your architect and Building Control officer will ask is, ‘Will it be safe to escape in the event of fire?’ It’s an issue nobody should take lightly, and even though dealing with it often makes open-plan spaces more difficult, it’s nevertheless important to stick to these rules.

For example, a staircase providing an escape route from upstairs rooms wouldn’t generally be allowed to go through the kitchen. This is because the kitchen is considered a fire risk, and therefore no escape route should lead through it. Staircases are escape routes as well, and usually all rooms need a 30-minute separation – in other words fire doors – around them on the ground floor. The only way an escape route could lead through a kitchen is if you have a mist system installed, or sprinklers.

In this open-plan space, no doors are needed between the kitchen and reception rooms. Why? Because there’s a ‘secondary escape’. Read on for more about these.

Is there a secondary fire escape?

In order to create an open-plan living/kitchen/dining area like this one (the living area is where the photo has been taken from), you’ll need to have an alternative fire escape, or what Building Regulations terms a ‘secondary escape’, from these areas.

These escapes could be doors into the garden, or even windows, provided they are of a minimum size. If this is the case, you may not need to separate your kitchen from your diner and your living space with doors.

Do you need a sprinkler system?

Sprinklers, already touched upon earlier, are probably something most homeowners want to avoid having to install, especially as they can be expensive.

However, since Building Regulations states there must be a safe passage through open-plan spaces adjacent to stairs, this could be the only solution for this kind of layout, as escape routes are made safer if a fine water mist is ‘sprinkled’ in the event of fire, allowing for more time to escape.

You need to consider sprinklers when:

  • your design means you’ll need to go through a kitchen from a staircase to your entrance door or a bedroom.
  • you want a completely open-plan layout, for example in a loft. The sprinklers then usually take the function of doors and walls to separate rooms.
  • you have very long corridors in your house and no secondary means of escape.

Is there sufficient kitchen ventilation?

In open-plan kitchens, mechanical ventilation needs to be installed for the kitchen extractor. A recirculating design is not sufficient, because not only do extractors get rid of smells, CO2 and other harmful gases, they also remove water vapour, which is created when you cook. Without correct extraction, mould can grow, just as it would in a bathroom without ventilation.

A side point here, back on the topic of doors: at the rear of this open-plan kitchen, there are double doors closing it off from the hallway, staircase and front door, which in the event of a fire in the kitchen provide a safe exit from the staircase. If you want to install glazed doors in a situation like this – as here – you’ll need to ensure the glass is fire-rated.

Is the glazing safe?

Any glazing below 800mm needs to comply with safety standards and to meet Building Regulations requirements. This would apply, for example, to secondary escape route doors, such as the external glass patio doors pictured here (as well as the internal doors pictured previously).

Fire-rated glass must have confirmation from your supplier that it meets required safety standards, and there should also be a sticker on the glass to prove it. The sticker is key, as without it you have no proof the glass is safe, and you wouldn’t get a Building Control Certificate.

How do I ensure split-level open spaces comply?

If your open-plan space is not all on one level, don’t worry. As long as the steps from one level to another are like your stairs, and therefore not considered a ‘trip hazard’ (as a barely noticeable threshold would be), you will be fine.

With higher than usual spaces, safe fire escape routes are different. The same rules apply, but they can be challenged with the help of a fire consultant’s report. This includes calculations to prove that, for example, the escape route can be longer because there is more void above, which needs longer to fill with smoke (meaning it’s OK if people need more time to escape).

If you have such a space or would like to create one, I’d always suggest using an approved inspector, which means a private company can give you a Building Control Certificate. This type of inspector is, in my experience, more likely to be flexible with interpreting the regulations, while of course keeping your safety in mind as a priority at all times.

Can I have sliding doors?

How often do you close the door to your kitchen in an otherwise open-plan space? Probably rarely or never. Since, however, a fire door is required, and the cost of a fire shutter or sprinklers is much higher, let’s consider pocket sliding doors. This solves both of these issues – you are still safe and legal, and by sliding the door into the wall, the sense of open space remains.

New regulations do allow sliding doors into kitchens in open-plan spaces. (Previously they were not allowed at all.) A few years ago, such doors needed to be self-closing, but the regulations have been adapted. However, if the door is glass, as seen in this room, it must also be fire-safe as described earlier

First publish on Houzz

Michael Schienke 18 December 2015

Houzz UK Contributor. Chartered Architect, director and founder at Vorbild Architecture Limited. The company was established in 2007 and specialises in a "one stop shop" services including land search, budget advice, planning application in the UK and France / Monaco, interior design, tender package, site supervision, contract management and full architectural and interior design services, as well as specialist services like : site and property search, feng shui consultation, client supply sourcing, furniture design and sourcing and landscape design.



20 Questions that need answers in light of Grenfell Fire

Posted by wilkinsoncc on June 26, 2017 at 1:45 AM Comments comments (0)

20 Questions that should be answered quickly in the light of the Grenfell Disaster

(originally posted on twitter on 16th June 2017 by our MD Geoff Wilkinson @geoffwilkinson)


1: Can we see the Architects plans & specifications?

2: Were these approved?

3: Were the fire service consulted?

4: Can we see a copy of the consultation respons?

5: How many site inspections were made?

6: Can we see records of those inspections?

7: Were the approved materials used or was there a "value engineering exercise"?

8: Did the contractor rely only on the minimum statutory inspections or did they employ their own clerk of works to inspect?

10: Was the fire risk assessment updated as a result of the works?

11: Can we see a copy of the fire risk assessment?

12: What recommendations did the fire risk assessor make?

13: Were those recommendations acted upon?

14: Was any further work (e.g. Gas main) carried out after the building control sign off?

15: If so did that work require approval?

16: When was the last fire risk assessment carried out?

17: When were fire doors last checked?

18: When were emergency lights last tested?

19: When were smoke control systems last tested?

20: Can a sample of the cladding be taken off and tested urgently and publicly?


What should landlords do in response to Grenfell Tower Tragedy

Posted by wilkinsoncc on June 25, 2017 at 3:55 AM Comments comments (0)

Advice on what to do to reassure residents

Here is the current guidance for landlords in light of emerging findings from Grenfell Tower


  • Check that the fire risk assessment has been carried out within the previous 12 months and that the recommendations within the action plan of the assessment have been completed;
  • Check that there have been no material changes (to the building, the fire safety measures or the occupancy) that could, potentially, undermine the validity of the fire risk assessment. For example installation of replacement windows, cabling, gas safety works.
  • Engage with your residents to ensure they fully understand the emergency fire procedures in the building, particularly the meaning of “stay put”. Ensure that fire procedure notices are accurate. The Fire Service are currently advising that Stay Put remains the correct advice in most cases unless major defects are highlighted in the risk assessment.
  • Check that there are no combustible materials (eg storage of refuse, barbeques) in the vicinity of the cladding. Ensure that there are measures to prevent combustible materials in such locations (eg by temporary barriers or instructions to residents). Instruct residents that they must not have any barbeques on any balcony.
  • Check that all flat entrance doors, and doors that open onto escape corridors and stairways, are fire-resisting and effectively self-closing against any resistance of a latch (or, for example, in the case of plant rooms or cupboards, are kept locked shut.
  • Check all walls that separate flats, plant and store rooms, etc from escape routes to ensure there are no obvious routes for fire or smoke spread (eg, holes where services, such as pipes and cables, pass through walls).
  • Check that any smoke control systems including automatically opening windows, roof lights, and associated fire detection systems, are operating correctly
  • Check all facilities provided for fire-fighters, including fire-fighting lifts and dry or wet rising mains are fully operational and have been tested. If you have ANY concerns you should contact your local fire and rescue service, who will, if they have not already done so, carry out an inspection to ensure functionality.
  • Ensure that there is sufficient roadway access and hardstanding for firefighting vehicles attending incidents and to be set up to fight any fire externally. Consider installing bollards to prevent inconsiderate parking
  • Check that insulation or other materials that form the façade meet all relevant standards - consider sending a sample of the panel and insulation for testing - especially if the block exceeds 18m in height.

If you discover that the cladding and insulation are of the same type used in Grenfell or fail the test then there are some emergency measures that you should immediately implement to ensure the safety of residents, pending replacement of the cladding

Notify Fire and Rescue Service.

Inform your local fire and rescue service fire safety/protection department. Failure to do so may put fire-fighters as well as residents at risk.   The fire and rescue service will carry out an urgent inspection with the ‘responsible person’ to ensure that they are identifying and introducing appropriate interim measures, as set out below. The fire service will carry out a further inspection once the interim measures have been completed:If the building is protected by an automatic sprinkler system (or equivalent fire suppression system) you might not need to take any further interim measures before replacement of the cladding.

If the building is not protected by a suitable suppression system you must consider the need for interim measures. The measures adopted need to be based on an assessment of the risk by a competent person, but the following must, at least, be considered:

  1. Residents to be advised to ensure all smoke alarms are present and working in their flat; to report concerns about fire safety measures in the building (eg presence of combustible materials in escape routes) to their landlord and, understand the purpose of any interim measures being taken.
  2. Closure of car parks in which a vehicle fire could impinge on cladding.
  3. Provision of a temporary communal fire alarm system, comprising smoke detectors in circulation areas and plant rooms, and fire detectors (possibly heat detectors, rather than smoke detectors) in conjunction with fire alarm sounders in each flat. This will enable the entire block to be evacuated simultaneously in the event of fire. This option is unlikely to be suitable for tall blocks, in which a large number of people would need to use escape routes at the same time. The system may comprise a wireless system, using radio to link devices.
  4. Provision of a fire watch by appropriately trained patrolling security officers/wardens.
  5. In the case of the most serious risk, consideration must be given to moving all residents out of the block until satisfactory remedial work has been done.




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