Other countries have responded to tragic fires with strong and prescriptive regulatory changes that meaningfully reduce the risk of such tragedies happening again. We are concerned, however, that Dame Judith’s interim report ducks this challenge, instead relying on industry to bring about a “cultural change”.
Admonishing industry and exhorting it to produce a cultural change – and “within 12 months” – is not a serious solution, nor does it reflect the urgency that the public interest warrants. Change is necessary, but new behaviours and practices must be compelled through clear ex ante regulation. Cultural shifts will follow suit, not lead.
Testing, testing, testing
Another area of concern is the interim report’s seeming unwillingness to let go of the “test and study” approach to compliance.
Large-scale testing has a role to play in some scenarios, though in our view, not when it comes to mid- and high-rise buildings or sensitive and high-occupancy buildings like schools and hospitals.
There are simply too many variables and potential deviations from real-world practice to rely on testing to keep these types of buildings safe along their life time.
Why is large-scale testing for these buildings not appropriate? At the most fundamental level, large-scale tests such as the BS 8414 do not reflect real-life experience, as they are based on near-perfect installation that is almost never achieved in practice and do not consider the natural deterioration of systems over time.
In many cases, including the DCLG’s post-Grenfell tests, they incorporate design details – such as the number of fire barriers, framing of the combustion chamber, or the absence of windows or ventilation openings – that just do not correspond to real-world construction.
Even testing proponents note that “…even relatively minor design changes — such as the size of gap between façade cladding panels – can have a notable impact on the overall fire performance of a façade system” (though this is only relevant in relation to combustible materials).
Despite these shortcomings, the Hackitt interim report urges building owners to rely on the findings of DCLG’s recent series of BS 8414 tests to understand if their current façade is fire safe. Unfortunately, she did not refer landlords explicitly to DCLG’s advice that “an obvious option to ensure that the cladding system adequately resists external fire spread, is to replace the system with one where all of the elements of the wall are of limited combustibility”.
That the interim report keeps the door open to desktop studies is even more worrisome.
Why? These studies involve paying consultants to project the behaviour of façade systems in a fire based on their own opinions. No other European country allows such studies as a route to compliance, and they have no place in a rigorous, safety-focused regulatory framework.
Already, key organisations such as the NHBC, the leading warranty and insurance provider and standards setter for UK house-building, no longer accept the continued use of these studies.
A better approach
Public safety requires more than tweaking at the margins of a fundamentally flawed system. We believe that a simple and effective way to safeguard lives and property would be to require that all mid- and high-rise as well as sensitive and high-occupancy buildings be clad and insulated only with non-combustible (Euroclass A1 and A2) materials. Doing so would bring England, Wales, and Northern Ireland into league with best practices elsewhere in Europe, where it’s simply not allowed to install combustible materials on tall building facades.
Taking this approach would eliminate entirely the need to conduct expensive large-scale tests. It would sweep away the ambiguity and uncertainty that large-scale testing and desktop studies inevitably entail, and provide a solid foundation for protecting public safety.
Why take the risk to do otherwise?
It's gratifying to see that Clive Betts MP, Chairman of the Communities and Local Government Committee, agrees on this question, as he writes in his 9 January 2018 letter to Dame Judith, that “…it cannot be right to continue to permit the use of combustible materials on high-rise buildings”. The Royal Institute of British Architects and the Association of British Insurers have also called for Dame Judith to recommend banning combustible materials on tall buildings.
Ultimately, the Government must seize this opportunity to safeguard public safety and building resilience. The stakes are too high and risks too great to tweak at the margins when a thorough-going overhaul is required. The people deserve better than the “status-quo plus” approach embodied in the interim report.
