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Building standards - compliance plan manager role: development of scope

To develop proposals for the Compliance Plan Manager (CPM) role on high risk buildings in Scotland and further develop the scope of the role.


3. CPM Competences and Pre-requisites

1. This chapter outlines the views of the PBG and interviewed stakeholders on the competences, prior experience and qualifications needed by the CPM, including the relative importance of qualifications in relation to competences and experiences. These findings, supported by the desk research and two virtual meetings with the Professional Body Group (PBG) guiding this work, have directly informed the corresponding sections of the CPM Role Document (chapter 6).

2. This chapter also discusses possible pathways into the role and the appetite for a bespoke scheme to aid that process.

3.1 Competences

1. PBG members made the point that the CPM role would appear to require broad and deep skills and knowledge relating to a range of technical standards, with the challenge that those skills might be hard to find in the same place and in the same person. Stakeholders subsequently interviewed for the research echoed that, with examples of perceived requirements set out below. It is important to bear in mind of course that the CPM role will be focused on compliance in relation to the building regulations rather than aspects such as contract law, quality of work etc.

2. Stakeholders feel strongly that the CPM should have strong knowledge of building regulations and knowledge of design, construction, use of buildings and building typologies. This knowledge, it is felt, should go beyond how buildings are put together, to cover detailed understanding of building materials and their combinations, and procedures relating to achieving compliance. It will be important to consider this requirement in relation to what the verifier is required to check, to ensure the ask of the CPM does not go above and beyond what is required.

“The CPM needs to have extensive familiarity with construction and building regulations... They need to know how to deal with contractors in such a way that they can get access to [information] at the right times to be able to sign off aspects of work. They will need to be organised and use a checklist for projects – this could be started with a template and adapted as per the needs of the project.”

Industry professional

“The CPM needs knowledge of different manufacturers, fire testing, and an understanding of how products work together and how combinations impact the building… They need to be able to access resources where they can get additional information that they may not know.”

Local authority verifier

3. Several interviewees highlighted the importance of CPMs understanding the relationship between suppliers and contractors, and possessing inter-personal skills needed to aid that process. For example, it is seen as crucial for the CPM to understand what is reasonable and what is not in terms of the practical implementation of demonstrating compliance.

“They need to be independent and have a decent track record of displaying competence. They need to be able to stand their ground (i.e. have “teeth”) when dealing with contractors, and they need to have an overall general knowledge base of all associated fields. They should be interviewed prior to being hired to prove that they’re capable and this should include proving they can work around example scenarios with different challenges (falsified reports, design teams hiding mistakes, lawsuits, etc.).”

Industry professional

“They have to be very experienced and knowledgeable in fire engineering, building standards and also health and safety. They also need to understand how to apply these on site and be able to handle different opinions and objections from contractors and others on site.”

Local authority verifier

4. One participant stressed that in the context of HRBs, the CPM should have extensive construction and inspection knowledge in relation to complex buildings.

5. Interviewees have varied perceptions of the breadth and depth of technical knowledge that they believe a CPM should hold. This would appear to be linked to preconceptions about the intended duties/responsibilities/liabilities of the CPM, which (at the time of conducting interviews) was part of on-going discussions.

6. Several participants were keen to emphasise that the CPM could not realistically be expected to possess niche understanding of every field/subject required, and that the level of knowledge held by building surveyors might be a good benchmark. Others hold the view that the CPM should be represented by an entity made up of multiple people with relevant niche skills (structure, foundation, fire, waterproofing etc.) since it is felt that one individual CPM could not be considered competent enough to check all aspects of a building to the required level.

7. Other issues raised with respect to CPM competences:

  • There should be a clear categorisation of competences, starting with those deemed essential and those deemed desirable;
  • Competence requirements for specific types of buildings or projects may vary depending on the nature/type of the project or risks involved, especially in the context of expanding the CPM role to other types of the buildings in the future. It was mentioned for example that gas systems in the healthcare sector are different to those in schools.

“The skills and knowledge required would depend on the type of work being completed. A complex and high-risk building might need a fire engineer background, but a more straightforward build would need someone with an engineering background.”

Local authority verifier

3.2 Prior experience

1. All interviewees stressed the importance of the CPM holding prior experience in a relevant field, such as an architectural, engineering, surveying, fire engineering or local authority building standards profession. Other suggestions include robust construction and inspection knowledge, awareness of legal aspects/implications associated with the design and build process, (although the CPM is not expected to be a legal expert), awareness of the building standards system, and experience of managing HRB projects.

“They need to have solid experience working with people on construction sites, and have been involved with building design, including awareness of material requirements and fixing arrangements.”

Local authority verifier

“They should have some design experience, a practical understanding of the building warrant process, as well as site experience, including how things come together and the role of different stakeholders in the process. So, someone like me, who is nearing the end of their professional life.”

Professional body

2. Specifically in the context of HRBs, three interviewees (two professional bodies and one verifier) claim the CPM needs to be able to demonstrate experience of working on HRBs or demonstrate exposure of risk to the public beyond domestic projects.

3. Attempting to quantify or mandate an experience requirement in terms of a specific number of years would appear to be difficult and perhaps inappropriate, with individual stakeholder suggestions ranging from five to as many as 25 years – the latter of which would substantially reduce the available market. Several interviewees – backing up the views of the PBG – mentioned that the value of experience ought to be measured in terms of the types of projects worked on and the nature of the roles held.

“The CPM must have a working knowledge across the professional design disciplines and awareness of the specialisms, which takes a long time to obtain in practice post qualification – certainly more than five years, even with a structured CPD course.”

Professional body

“They should have at least five years’ demonstrable experience managing high-rise complex buildings. This could include site management, building surveyors, or building designers.”

Local authority verifier

“I’ve been working here for 26 years and I’m still learning so I definitely think you’ve got to have at least 10-15 years plus experience before you could do anything like that.”

Local authority verifier

3.3 Relative value placed on qualifications

1. Whilst all interviewees view proven competence, experience and attained qualifications as vital elements of the CPM role, competence and experience are generally valued more strongly relative to qualifications.

2. Membership of a relevant professional body with a design, surveying or construction focus is seen as especially important for demonstrating that the CPM has a suitable professional background, can work in line with a quality framework and ethical practices and has a proven commitment to continuous improvement. It is felt that this would help to deepen trust and confidence in the CPM role among industry and the public.

3. Several interviewees mentioned that a key focus for developing the CPM role should be on identifying the competence requirements and considering different ways these can be achieved depending on the individual and their professional background.

“Experience is most important, followed by qualifications and certifications. As long as people can evidence the knowledge they have, that should overtake the qualification level.”

Professional body

“Regulations are black and white and sometimes you have to use common sense to work through things – that is what experience is essential for.”

Local authority verifier

4. PBG members made the point that mandating minimum required qualifications and length of experience risk being somewhat arbitrary and expressed the following concerns:

  • The CPM role needs to be within reach of those suitably qualified and experienced to undertake it; and
  • Benchmarks of competence set by existing professional bodies may not go far enough to cover the complexities of high-risk buildings and what the CPM role needs to encompass.

5. These views were largely echoed among interviewed stakeholders, with some reticence about setting a minimum qualification threshold for several reasons:

  • Risk of limiting the market of potential applicants;
  • Experience and professional training are arguably of greater importance than a qualification; and
  • No single qualification on the market would likely fully cover what a CPM needs to know.

6. Added to that, views are mixed as to what a minimum qualification requirement should look like, for example higher national diploma (HND) or degree/equivalent in a relevant discipline, and what length of experience (in years) is enough.

“It needs to be a degree in a relevant discipline like design or construction and it needs to be assessed with refreshers every few years.”

Industry professional

7. Without prompting, several interviewees suggested creating some form of bolt-on qualification and/or test to upskill the CPM and ensure they have skills necessary to carry out their work. This is discussed further in sections 4.6 and 7.2

3.4 Pathways into the role

1. Interviewed stakeholders argue that progression into the role of CPM could follow various pathways, either from a building design or construction management background, but with an emphasis on the former.

2. Indeed, several stakeholders suggest that knowledge and practical experience of building design will be extremely important, with a small number of professional bodies commenting that only a fully qualified design professional would be able to ensure construction matches design intentions and is fully independent of the construction process.

3. Specific suggestions for job roles that might lend themselves to the CPM role include:

  • Architects;
  • Architectural technologists;
  • Building surveyors;
  • Building standards verifiers;
  • Civil engineers;
  • Clerks of works;
  • Construction site management professionals.
  • Fire engineers;
  • Health and safety advisors;
  • Local authority building standards professionals;
  • Quantity surveyors.

4. Whilst professional body membership was once again emphasised as an important pre-requisite, one body mentioned that not all routes would fit, for example someone specialising in rural land management.

5. Experience in terms of delivery of compliance in projects is also seen as important. A key ingredient is being knowledgeable enough to understand the issues and to have confidence to speak to verifiers accordingly to help overcome them.

“Progression into the role could come from architecture, engineering, building surveying – the scope is quite widespread.”

Wider built environment stakeholder

“Building surveying and building control are a natural education background for this role.”

Industry professional

“People who have previously worked in building standards will be best placed to progress into this role, as they will have knowledge of the cladding, fixings, materials and are familiar with completing paperwork and documentation in accordance with design plans.”

Local authority verifier

“Progression routes should start with a degree qualification (or level 6 equivalent), followed by professional qualifications including charterships. They need to have a broad range of experience alongside this, so they may be local authority verifiers, building standards or chartered surveyors. Onsite occupations, such as architects, may not be best suited where they do not have working experience and knowledge of building regulations.”

Industry representative body

3.5 Appetite for a bespoke scheme

1. The PBG expressed favourability to the idea of a dedicated scheme for the CPM role, with support from professional bodies and using a common framework of “bolt-on” standards/training set to the level of rigour required for work on HRBs. Stakeholders interviewed for the research were then asked whether they thought a bespoke bolt-on scheme should be developed by relevant professional bodies for those looking to take on the role.

2. The vast majority of interviewees are favourable – especially considering this will be a new role – to create consistency, give clients confidence, and ensure sufficient CPD arrangements are in place to cover key knowledge and understanding.

3. The minority unfavourable questioned whether there would be sufficient demand for a scheme and whether one or more professional bodies would have the resources to put in the significant investment needed.

4. This led to discussions on how such as scheme might be set up, governed and audited, including how individuals would attain and maintain accredited status. It is felt that the scheme would need to be perceived as credible and sufficiently rigorous to secure trust, but not overly burdensome to lead to low demand. Another caveat is that it would only be successful if developed by professionals who have the knowledge and understanding to know what the role would be required.

5. It should be noted at this point that stakeholder research previously carried out by Optimal Economics[11] also identified a preference for developing an scheme for the CPM role. It was felt that an scheme would ensure consistent standards. Key identified issues were how to deal with more than one professional body wanting to establish a scheme; ensuring a level playing field for all prospective CPMs; as well as cost and auditing considerations.

6. Outline proposals for what a scheme might look like, and how it could be operated, are set out in section 7.2 – National framework for the CPM role.

Contact

Email: buildingstandards@gov.scot

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