The proposed streamlining of Parts K and M, and the end of N, have been broadly welcomed by the industry. But would more simplification serve to clarify or confuse?
As soon as the coalition government came to power, it promised to do away with unnecessary red tape. 黑洞社区 regulations were immediately in the line of fire, with communities minister Andrew Stunell announcing plans to streamline the Approved Documents (ADs) and cut the industry鈥檚 costs of compliance.
In January this year, the government launched a consultation document that could prove to be the blueprint for the rationalisation of 黑洞社区 Regulations. The amendments to Parts K, M and N are an attempt to strip out conflicting and overlapping advice covering falls, access and the safe breaking of glazing in critical locations.
The proposal is that guidance supporting Parts K (Protection from Falling, Collision and Impact) and N (Glazing), and overlapping guidance that sits in Part M (Access) will be streamlined and simplified and form a new Part K, retitled Protection from Falling, Collision and Impact and Glazing Safety. If the proposals come into law, Part N will
cease to exist.
An impact assessment estimates that the move could save the industry between 拢63m and 拢138m over 10 years at a cost of only 拢3.14m in updating the documentation. The removal of contradictions between existing documentation means the new Part K would reduce disputes over the interpretation of guidance.
Peter Caplehorn, technical director at architect Scott Brownrigg, welcomes the proposal. 鈥淭hey鈥檝e done a really good job. At the moment, designers flick between the three ADs to make sure all bases are covered. Having one co-ordinated document lessens the risk of missing an important detail.鈥�
Caplehorn says the amalgamation would result in less time being wasted arguing with building control over interpretation. According to
EC Harris and PRP Architects, duplication affects 300,000 building control applications each year, which means designers waste time working out which bits are relevant, making the process more expensive.
Does it go far enough?
The new Part K would not introduce any new technical requirements, something that irks John Tebbit, industry affairs director at the Construction Products Association (CPA). He believes rationalisation needs to coincide with an update in technical guidance currently contained within Part N. 鈥淚t refers to obsolete standards. There鈥檚 no point buying a Trabant and sticking a BMW body on it.鈥�
These parts of the regs get less attention. They want to use them as a guinea pig
Paul Everall, chief executive at the LABC, says the government is testing the water with the rationalisation of K, N and M. 鈥淭hese parts of the regs get less attention. They want to use them as a guinea pig.鈥�
He adds that he can understand why some might want to group related guidance together, such as structural and site preparation, but he questions whether such a move would be worth it. 鈥淓verybody is familiar with the ADs as they are. Changing their structure would be a recipe for confusion,鈥� he says.
Tebbit agrees on this point.
鈥淚t鈥檚 not practical to move them together and it would cost a shed load of money. We should simplify current ADs but not worry about bringing them into single documents.鈥�
The complexity of other ADs makes rationalisation difficult, says Caplehorn. 鈥淚t鈥檚 a good move for these three,鈥� says Caplehorn, 鈥渂ut other ADs have other things attached such as construction product regulations and eurocodes.鈥�
Under one roof
Everall says the legislative picture could be clearer if all technical requirements were within 黑洞社区 Regulations. He cites water companies imposing their own requirements and planners insisting on renewable targets as causes of confusion.
In a submission to the Red Tape Challenge website, Diane Marshall, NHBC鈥檚 group head of building control, had other suggestions as to what could be moved into the regs. She said sustainable urban drainage systems, or SUDS, the Code for Sustainable Homes, energy performance certificates and Lifetimes Homes could sit under H, L, L and M respectively.
There is also widespread support for having additional documents for projects that could sit alongside existing 黑洞社区 Regulations. A regulations guide for loft extensions has been published by the CPA, and there will be one on domestic extensions in 2013.
Tebbit prefers additional project guides to an overhaul of regulations. 鈥淚f you鈥檙e not careful, you could end up with a monster document,鈥� he says. 鈥淵ou need to cut stuff out or you will end up with a telephone directory.鈥�
Part P: Don鈥檛 touch the electrics
In its drive to cut red tape the government is proposing to amend Part P (Electrical Safety in Dwellings). One of the options being proposed is to scrap Part P, but despite potential savings of almost 拢400m the government says this is not its 鈥減referred option鈥�. It says it couldn鈥檛 risk a reversal in the improvement of installations since its introduction in 2004.
The preferred option is to retain Part P with changes. The proposals aim to cut costs and bureaucracy without compromising safety, but the changes are causing concern.
There are two contentious amendments: making work deemed to be lower risk non-notifiable, which will reduce the number of jobs that come under the scope of Part P; and allowing third-party certification of electrical work that has been carried out by someone who is not a member of a competent person scheme.
The government sees the latter amendment working in one of two ways: members of competent person schemes could certify the work of non-registered electricians, thereby avoiding the need to notify building control; or any qualified electrician could inspect and test work by unregistered installers, such as DIYers. They would submit a condition report to building control who would use this to sign off the work without inspecting the installation.
The government estimates these proposals could save 拢144m over 10 years in reduced fees to building control, and only cost 拢8.1m.
Paul Everall, chief executive of the LABC, has a number of reservations over the changes. He believes that with a smaller role for competent persons, there would be less of an incentive for electricians to join schemes, leading to a decline in the quality of installations.
鈥淚f a non-competent person can do the testing, I fear the scheme will be undermined,鈥� says Everall. He also thinks government would have the burden of creating a non-competent person register of people testing installations.
The NICEIC, which runs a competent person scheme, is unhappy with the proposals and believes all works should be carried out by a competent person.
鈥淧ublished DCLG statistics show that nearly 6,000,000 domestic electrical jobs have been notified to building control since Part P was introduced. All of these jobs have been notified by contractors who have subjected themselves to an annual assessment, who inspect and test their own work and give the homeowner added peace of mind with an insurance backed warranty,鈥� says Emma Clancy, chief executive of NICEIC. 鈥淚f you cannot inspect and test your own work, you are not competent enough to be installing a potentially lethal piece of work.鈥�
NICEIC calls the reduction of notifiable work 鈥渄isappointing鈥�. The government鈥檚 document proposes that work in the kitchen, garden and part of the bathroom will no longer have to be notified. Everall believes that exempting kitchens would be unwise, as the close proximity of sinks to electricity would make electrocution a risk. However, he accepts the proposal to allow work in parts of the bathroom that are not close to water.
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