Independent Review of Building Regulations and Fire Safety

About this consultation

Following the Grenfell Tower disaster, the Government has commissioned this Independent Review of Building Regulations and Fire Safety, led by Dame Judith Hackitt, which is now calling for evidence. Its terms of reference are found in Annex A and a list of regulatory system documents (not intended to be comprehensive) in Annex B.

Background

The review is interested in anything that may impact on the full lifecycle of a building, including any wider cultural issues which may impact on the focus given to maximising fire safety. It has particular focus on the regulatory system as it applies to multi occupancy high-rise residential buildings; however, it welcomes broader points on other types of buildings, if respondents wish to make them.

The review will examine the totality of the system including: the legal requirements; the roles and responsibilities of different individuals / organisations; compliance processes; competency; enforcement and sanctions; and quality assurance.

The Review Team is interested to hear from respondents about aspects of the current regulatory system that are working well and aspects that could be reformed to enhance fire safety.

Note: It reminds respondents to answer questions as broadly as possible and focus on making suggestions for improvements as well as identifying what currently works well. Also, to make use of a range of sources, such as published / unpublished reports and case studies, to underpin responses.

Proposed changes

We invite IOSH members to send us comments on the Independent Review’s call for evidence questions (listed below) or any other comments to consultation@iosh.com, to help inform an IOSH submission, by 26 September 2017.

IOSH members wishing to also respond individually to the Independent Review can do so by visiting here and responding by 13 October 2017.

Consultation questions

The overarching legal requirements

Q1 To what extent are the current building, housing and fire safety legislation and associated guidance clear and understood by those who need to follow them? In particular:

a) What parts are clear and well understood by those who need to follow them?; and, if appropriate
b) Where specifically do you think there are gaps, inconsistencies and/or overlaps (including between different parts of the legislation and guidance)?
c) What changes would be necessary to address these and what are the benefits of doing so?

Roles and responsibilities

Q2 Are the roles, responsibilities and accountabilities of different individuals (in relation to adhering to fire safety requirements or assessing compliance) at each key stage of the building process clear, effective and timely? In particular:

a) Where are responsibilities clear, effective and timely and well understood by those who need to adhere to them/assess them?; and, if appropriate
b) Where specifically do you think the regime is not effective?
c) What changes would be necessary to address these and what are the benefits of doing so?

Q3 Does the current system place a clear over-arching responsibility on named parties for maintaining/ ensuring fire safety requirements are met in a high-rise multi occupancy building? Where could this be made clearer? What would be the benefits of doing so?

Competencies of key players

Q4 What evidence is there that those with responsibility for:

a) Demonstrating compliance (with building regulations, housing & fire safety requirements) at various stages in the life cycle of a building;
b) Assessing compliance with those requirements

are appropriately trained and accredited and are adequately resourced to perform their role effectively (including whether there are enough qualified professionals in each key area)?

c) If gaps exist, how can they be addressed and what would be the benefits of doing so?

Enforcement and sanctions

Q5 Is the current checking and inspection regime adequately backed up through enforcement and sanctions? In particular:

a) Where does the regime already adequately drive compliance or ensure remedial action is always taken in a timely manner where needed?
b) Where does the system fail to do so? Are changes required to address this and what would be the benefits of doing so?

Tenants’ and residents’ voice in the current system

Q6 Is there an effective means for tenants and other residents to raise concerns about the fire safety of their buildings and to receive feedback? Where might changes be required to ensure tenants’/residents’ voices on fire safety can be heard in the future?

Quality assurance and testing of materials

Q7 Does the way building components are safety checked, certified and marketed in relation to building regulations requirements need to change? In particular:

a) Where is the system sufficiently robust and reliable in maximising fire safety and, if appropriate
b) Where specifically do you think there are weaknesses/gaps?
c) What changes would be necessary to address these and what would be the benefits of doing so?

Differentiation within the current regulatory system

Q8 What would be the advantages/disadvantages of creating a greater degree of differentiation in the regulatory system between high-rise multi occupancy residential buildings and other less complex types of residential/non-residential buildings?

Where specifically do you think further differentiation might assist in ensuring adequate fire safety and what would be the benefits of such changes?

International comparisons and other sectors

Q9 What examples exist from outside England of good practice in regulatory systems that aim to ensure fire safety in similar buildings? What aspects should be specifically considered and why?

Q10 What examples of good practice from regulatory regimes in other industries/sectors that are dependent on high quality safety environments are there that we could learn from? What key lessons are there for enhancing fire safety?