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Combustible materials in construction

Euan Durston

Euan is an all-rounder with excellent communication skills and experience of working on complicated projects involving multiple stakeholders – from the briefing and planning approvals processes to the site delivery stages.

Our response to the Ministry of Housing, Communities and Local Government’s review of the ban on combustible materials in buildings.

The current consultation reviewing the impacts of the ban on the use of combustible materials in and on the external walls of buildings has provoked a wider debate within our studio about the impact of this ban on the development of timber construction and the implications for the role of innovation in tackling the climate crisis.

At the moment we believe there has been a breakdown of trust in the system of building regulation and its implementation, and that this is a wider issue than the detail of the regulations themselves. The construction industry needs to find a means to restore trust in the industry collectively beyond just regulation.

To be effective, the Building Regulations require a robust system for their enforcement that commands trust and respect. The regulations that were in place before the Grenfell fire should have prevented it. In the post-Grenfell climate our experience has been that clients are making their own knee-jerk reactions independent of regulations and partly due to the lack of any swift or definitive updates. Employer’s Requirements are taking precedence over Building Regulations which in theory should be applicable to all projects.

Decisions about forms of construction to adopt or exclude are being driven by all of the following:

  • Pressure from residents and tenants who do not feel safe.
  • Client perception of risk (real, reputational, future).
  • Reaction of insurers (both Building insurers and professional indemnity insurers).
  • Reaction of mortgage lenders for market sale properties.
  • Personal opinions and prejudices of building control officers or authorities.
  • Personal opinions and prejudices of architects and contractors who are fearful of finding themselves asked to testify at future enquiries.

Our residential clients and contractors are taking a 100% risk averse approach. They are ruling out the use of timber in Employer’s Requirements and eliminating any combustible materials from construction. This affects specification right down to cavity trays, DPC’s and the adhesives used to bond brick slips to lintels. Contractors are reverting to what they know best – ‘old school’ brick and block construction. The effect of this is to counter any ongoing efforts to upskilling and modernise the process of building construction in the UK.

At the same time we are experiencing a definite shift among clients away from reliance on passive fire safety – structural performance and compartmentation – towards active fire safety – providing sprinklers to apartments and communal areas. Although housing design has historically relied on passive fire safety and ‘stay in place’ strategies we feel that the legitimacy of this approach has been undermined in the perception of our clients by the number of buildings found not to perform as they were designed. We think the residents in high-rise residential schemes for example, would be unlikely to be willing to obey Fire Brigade advice to ‘stay in place’ now. Clients are anticipating future changes in regulation and trying to future proof schemes currently at the design stages. Sprinklers offer more design flexibility in internal flat layouts but their take-up varies from project to project.

This gap between what the regulations should in theory safely allow and what building commissioners are actually willing to do in practice has arisen because of a breakdown of trust. This has been driven in part by the number of buildings that have been signed-off and then found to have basic construction defects such as missing cavity wall ties. Local Authority Building Control certification has been exposed as being no guarantee that building regulations have actually been complied with. In the residential sector in particular, the ‘guarantees’ of some Independent Approved Inspectors are in reality insurance policies against defective workmanship rather than confirmation that construction has been independently inspected and approved.

The Performance Gap between as-designed and as-built conditions is a pressing concern and is in part related to the system of Building Control and the procedures for the quality assurance of this system through site inspection and certification.

Overcoming the challenges facing our society in relation to climate change will require more collaboration and innovation in the construction industry. If the ban on combustible materials is to be permanently enshrined within Building Regulations it must be done in a way that does not stifle future innovation in new forms of construction technology. At the same time, our profession has a duty first and foremost to ensure the safety of all those who use the buildings that we design.

We therefore need to create a safe space for the exploration of new materials and approaches while rebuilding trust. We think that this may require a more transparently evidence-based approach to writing new regulations that is backed up by demonstration and testing rather than desktop analysis. If the effect of this would be to require new materials or combinations to be mocked-up and tested on a project-specific rather than generic basis, providing video evidence of the fire-test results for the reassurance of future occupants, that would be a positive first step.

The more difficult second step will be to rebuild a site inspection and certification regime that will guarantee that the ‘as built’ product matches the tested sample and to define which parties within the industry should be responsible for which roles within the system. We believe that reforms are needed to address the efficacy of the Building Control system in its entirety and not just the specific wording of individual regulations.

Euan Durston

Euan is an all-rounder with excellent communication skills and experience of working on complicated projects involving multiple stakeholders – from the briefing and planning approvals processes to the site delivery stages.

How can we help?

Please get in touch if you’d like to know more about us and how we work with our clients, consultants and colleagues.