Building standards - compliance plan manager role: development of scope

Appendix 3 Emerging standards and competences applicable to HRBs

1. Following publication of the Hackitt Review, a Competence Steering Group (CSG) for building a safe future was set up to improve the competence of those procuring, designing, constructing, inspecting, assessing, managing and maintaining higher risk residential buildings. Its final report Setting the Bar ^[19] details processes and frameworks intended to provide the foundation for a significant improvement in competence for construction work right across the sector.

2. Eleven Working Groups drew up their own sector-specific competence frameworks with the intention that they will be rolled out across the professions or trades without reference to particular building types. The competence standards have two aspects: first, an overarching competence framework developed as a suite of National Standards that will be common to all disciplines; and secondly, discipline-specific requirements.

3. Setting the Bar paved the way for a new system for harmonising and standardising the competences needed to determine compliant building safety outcomes in the UK’s built environment industry as a whole, and not just in HRBs.

4. The (then) Ministry for Housing, Communities and Local Government (MHCLG) commissioned the British Standards Institution (BSI) to take forward a programme to deliver a suite of National Standards under the direction of a newly established Built Environment Competence Standards (BECS) Strategy Group made up of government, industry and consumer interest groups.

5. BSI Flex 8670 establishes the overarching framework for behavioural and functional competences needed to improve both building safety outcomes and the dominant culture at work in the built environment sector. Additionally, three Publicly Available Specification (PAS) documents (including guidance) form the basis of the competence requirements for three new regulated roles – Principal Designer, Principal Contractor, and Building Safety Manager (the latter focused principally on the occupation and use phase of a building).

6. PAS 8671 for Principal Designers sets out ‘additional competences for working on HRBs’ covering the themes of legislative and regulatory framework compliance, management of design work compliance, and technical framework for compliance. These additional HRB competences are as follows:

• Analyse understanding of the legislative and regulatory framework related to designing HRBs, including in relation to prescribed procedures and information;
• Evaluate duties of other dutyholders in the context of HRB projects for the ways they could affect the Principal Designer’s duties and design work compliance;
• Evaluate the system of regulated procedures and information related to working on HRBs and their implications for the performance of the Principal Designer’s duties, including contributing to the golden thread⁶) of information, reporting safety occurrences to the Building Safety Regulator, and making competence and compliance declarations;
• Evaluate ways to establish and maintain throughout the construction phase a system for inspecting HRB design work for safety occurrences and promptly reporting safety occurrences;
• Create ways to instruct reporting persons about the system for mandatory safety occurrence reporting related to working on HRBs;
• Evaluate building safety risks in connection with the regulated system of mandatory safety occurrence reporting sufficient to report events related to structural safety, fire safety and other prescribed matters in HRBs;
• Evaluate the potential during inspections of design work throughout the construction phase for new building safety risks to emerge and for the assessed severity of potential impacts of all risks to change, including to become safety occurrences;
• Evaluate design work compliance sufficient to follow prescribed procedures for declaring compliance; and
• Understand information management systems sufficient to: i) contribute to the collation, accurate maintenance, and accessibility of digital records in the golden thread of information; and arrange the establishment and maintenance of the mandatory occurrence reporting system.

7. PAS 8672 for Principal Contractors also sets out ‘additional competences for HRBs’. At the highest level, Principal Contractors should have the skills, knowledge, experience and behaviour to:

• Contribute to the planning and development of the construction control plan;
• Understand the drivers of compliance with the applicable building regulations and record evidence of that compliance;
• Liaise with other dutyholders, including the Client and Principal Designer, and understand the regulatory obligations (including building regulations) in respect of signing-off key information, including the compliance of the “as-built” building;
• Coordinate matters and understand the drivers of compliance with regard to all those involved in the building work;
• Establish that all those working on the construction of HRBs, including contractors and building system providers, are aware of their duties and have the competence to carry out the construction activities for the safety of the building’s occupants;
• Maintain the construction control plan (which forms part of the golden thread of information) during the construction phase, detailing full and accurate records of all changes (including justifications) to the approved design;
• Establish an obligatory system for mandatory occurrence reporting on structural and fire safety, and other regulatory prescribed hazards, that enables the workforce to report potential occurrences which could cause a significant risk to life safety;
• Complete the construction control plan, sign-off the required documentation, including the compliance declaration, and contribute to the Fire and Emergency File;
• Contribute to an appropriate handover of information to the Accountable Person; and
• Undertake the additional duties for managing the construction phase of HRBs.

8. In addition, the PAS sets out discrete HRB competences covering the themes of managing building work, leadership, decision-making and change management, liaising with the client, other stakeholders and regulatory bodies, developing people and teams, and managing information.

9. Finally, the Building Safety Act 2022^[20] sets out how the Government intends to deliver the principles and recommendations of the Hackitt Review. It aims for greater accountability and responsibility for safety issues throughout the life cycle of buildings. It establishes a new regulatory regime for building safety and introduces more stringent building control requirements for HRBs. It also sets the scene for instituting a culture change and motivating compliance in the industry.