BIMinAM Advisory and Consultancy Working Group Meeting 01-10-2025
GEORGE STEVENSON …Expanded it to cover a whole range of different types of advisors, and what we're trying to do here is to bring together so there's a degree of consistency in terms of the advice that people are giving and also that people can learn from each other. So, this last week we’ve run four workshops on safety critical assets. And we've basically been updating the original information that we compiled back many years ago, but I think most people are aware of that. So what we've done with that is that we're updating the guidance.
We’ve also generated a very interesting little podcast from it as well that’s done from the information that’s come together, we’re going to be putting that on the BIM4Housing website. But as far as the guidance is concerned, the other thing that we’ve got is the Miro board that Das and Jarek are managing. So if there is information that you’ve got about the interpretation of the legislation then that’s a good place to go and suggest improvements. And finally we had the BIM4Housing development group meeting which was well attended and we had another one yesterday which was the design group meeting which again was very active.
Matt, Gareth, I think that you’ve been thinking about what we’re going to cover. Do you want to just introduce yourselves and obviously Debbie as well, who is one of the leads on this consulting group. First of all, Matt.
MATT TAYLOR I’m the director of Taylor Design Consultancy, we are an independent dry lining and internal fit out consultant. We deal with it tends to be larger scale projects that tend to warrant having a trade specific package consultant involved. We deal with contracts from architectural clients through to main contractors, trade contractors and building clients to ensure the primary aim of reducing the potential for defects to be built on site.
DEBBIE CARLTON I have a niche consultancy called Dynamic Knowledge that specialises in competency management and knowledge management. I do a lot of work in the built environment and I do a lot of work with AI. I sit on the Bridge Advisory AI group and involved in supporting a number of businesses doing AI platforms and stuff in the sector. And there’s a lot going on that all organisations can tap into at the moment in terms of AI resources if they want to be more aware of them. I also feed in to the industry Competence Committee, they keep on publishing new guidance, new expectations etc. and feedback on that. I don’t sit formally on the panel but they do ask me to review before they publish stuff.
GARETH GRIMES I’m the technical director at Clarke Banks. We are a three-pronged consultancy, we offer building control and also first principals fire design and facade and site services including Clerks of the Works. And our third silo is building safety advisory, so bridging the gap between building control and the built environment. And over 20 years in industry, chartered with countless agencies, my aim is to try and simplify what everybody is doing within the industry and remove all of the complications that are currently manmade and woman-made. Lots of over-complication out there, so my aim is to try and simplify things for everybody.
SYPRIAN A PITKIN I'm a building and design compliance consultant working at Frankhams. I actually carry out or perform the building regulation principal designer role and get involved with advising other principal designers or project teams on the building regulation when it comes down to submittal, both for non-NRBs and HRBs.
BEX GIBSON I work at Rider Levett Bucknall, I’m a building safety consultant specialising in the post-occupancy side of things, so everything post Building Safety Act really.
DAVID SIMPSON I’m from Associated Architects, we work across multi sectors including housing, a lot of higher education (schools in particular) and commercial. We also have recently set up a BRPD arm, both for our own projects and other projects as well and we’ve got two architects who are registered with the RIBA to undertake that. And I’m really here in my role as the practice BIM manager to understand how we can better deliver the data that’s needed throughout the life of the project in a streamlined way.
GEORGE STEVENSON You’ve been to several of the BIM In Asset Management meetings, what are you looking for from this community?
DAVID SIMPSON It’s really consensus and consistency in what we deliver. And also how we demonstrate and review competency, in particular for the BRPD role. So we’ve recently aligning all of our competency review standards for the RIBA documentation. So just to understand is that something that everyone else is doing, or are there other sets of standards that people use?
GEORGE STEVENSON It’s a very interesting point and it was raised last week by somebody that’s a profound expert in the building regs process. And what he’s explained is that what RIBA have done leaves out some very key sections of the Building Safety Act. In particular, they seem to have excluded the fire safety information. So you know on the spreadsheet you’ve got all of the different tabs? The ones that relate to Regulation 38 and I think it’s Regulation 7, he was saying that they’ve not been included. I was discussing this with another architect in the design group meeting.
He’s also going through the process, he’s using that RIBA template which a lot of people are going to use. The guy last week was explaining where the PDBR is working on behalf of the design & build contractor, if they simply follow that TIBA guidance the contractor is going to be exposed. so I think that’s something worth us maybe having a separate session on.
DAVID SIMPSON That’s useful, that tracker itself is something that we’ve developed our own version of that, so that’s the only one of those RIBA framework documents that we don’t use. But we do use the competency assessment, various spreadsheets.
GEORGE STEVENSON Nick, can you just explain what you do?
NICK I’ve been active in BIM for almost as long as George, or perhaps the same length of time. For the last 25 years I’ve been an independent consultant and one of the things I specialise is automated regulatory compliance. And maybe also supported compliant systems. And I think the whole Building Safety Act thing has actually thrown up some really novel problems like being asked to schedule every regulation and what building elements comply with it. Which has never been seen before in any regulatory system that I’ve seen. And I think there are a lot of challenges that we actually have to think differently. We’ve got a passive aggressive Regulator who just folds their arms and says impress us. And then throws out these really very demanding requirements.
GEORGE STEVENSON That actually those requirements are potentially killing projects.
NICK NISBET They’re killing projects because people don’t understand them and they don’t have the means to prepare the answers. Which is where my interest in automation comes in. I think a lot of the working groups that I’ve dipped in and out of, so I may be wrong, are heavily focused on gathering information and evidence. But there has been very little attention to proving safety or proving compliance.
GEORGE STEVENSON As far as our groups are concerned, I do think we are including that as well. But I definitely think that that sort of relationship is critical. And if we can improve it then we should do.
SYPRIAN A PITKIN I actually created, just going back to the RIBA template, a document for myself, but it’s only relevant to an HRB. the thing that we have to do, the reason why the Regulation 38 is not…it’s actually been forgotten. But I’m working on a project at the moment and I’m looking at going through the Part 2 Regulation 7 and 8 and the Regulation 4 Part 2. And some of these where I’m working at stage 1 to 3, I’m at stage 3, stage 4 i haven’t started. Regulation 38 is not relevant between stage 1, you don’t need that until you reach stage 5.
So this document from RIBA is actually a design management document. And I’ve had this conversation with architects and I personally feel that a lot of these are Part 2 Regulation 4 and Part 2 of 7, it’s not really relevant at this stage at the moment. Because obviously you have the different parts of the schedule…and that’s at the end of the project you reach stage 5 and that’s when you start to populate and the contractor as well. That’s the PCs’ remit to put the Regulation 38 documents together. So just saying this is just a design management to manage design during RIBA stage 1 and 4…the relevance of Regulation 38 is not really necessary at this stage. I don’t know if anybody has a view on that.
GEORGE STEVENSON That surprises me a little bit because I would have thought that the design strategy is something that should be reflected in the handover information.
SYPRIAN A PITKIN Well, technically it is because this is where you start getting all of the information that you need. For example, the design and access statement is one of the main things that’s evidence at this stage of the project with the planning documents. So in essence it is being developed, this is where the Golden Thread is being developed. So it’s there, the tabs are there for example, zoning in on the Regulation 38. This document often becomes part of the evidence, becomes part of the Golden Thread.
From the Golden Thread you will be taking on the document…that’s required for the Regulation 38. It's simply saying that the Regulation 38 have at this stage is just not really necessary or at stage 1, 2 and 3, what are you going to be commenting on Regulation 38 apart from that? Just that the contractor should ensure that the information is submitted to the AP or the responsible person at the end of the project.
GEORGE STEVENSON I have to say that I’m pretty sure that the role of the building regs PD extends beyond design.
SYPRIAN A PITKIN Yes it does…sorry, when you say it extends beyond the role of design, what’s the interpretation of that?
GEORGE STEVENSON Let’s open it up to the floor a little bit, David, would you have a view on that?
DAVID SIMPSON Certainly our view is that it certainly extends beyond the early RIBA stages right through to completion and beyond. We often have quite a debate with the BR principal contractor as to where the overlap is between our responsibility and their responsibility and where the handover is. And we see the design continuing, particularly on design & build projects, all the way through the stages.
And we see our role in making sure that designs that were submitted by the supply chain are still in compliance with the early stage of design intent and Regulation 38 is quite key in that in tracking any changes that come through that process and making sure that they have been agreed by everybody who is responsible for that. we very often get, even when we’re not BRPD and we’re just the architects on that, we will get trackers and forms from the contractor to sign against the fact that we’ve reached stage 5 or construction design stage that we still believe this is in accordance with the original various strategies for the design.
GEORGE STEVENSON Absolutely. Does anybody, rather than us dominating it on that particular point, is there anybody else that has some comments?
DEBBIE CARLTON I would concur with what David is saying and some clients that I’m working with and advising on the competency aspects of the Building Safety Act. Also the but that gets misunderstood is that until you understand where the responsibilities lie you can’t really be sure about getting what your competence requirements are right. So there is a relationship between responsibilities ad duties and competence here which unfortunately has been a bit misunderstood by the industry Competence Committee. So it’s better to be sure you’re getting the duties and responsibilities right and then aligning what your competence requirements are against that as an intent.
MATT TAYLOR I’d agree with that entirely. What is resulting from that and what we’re seeing is again as was happening around a decade ago and we’ve seen some sort of push in the other direction, but it now seems to be going back is the selling down stream of design responsibility. So what seems to be happening now is we’re tendering on three projects at the moment where the architect is stating that they consider themselves not to have responsibility for any of the fire performance whatsoever. So they are in effect in their own view only commenting on the aesthetic arrangements within the building and setting out bits and pieces like this which I would argue isn’t fulfilling their role of an architect.
If we’ve got package specific consultants there still needs to be somebody in there coordinating that process and I’ll give you an example. If we’re looking at party walls in a multi-storey building and we have to accept an arrangement that the architect has carried out their process correctly. And therefore if walls are stated as being a 60-minute requirement that that’s what is required. One of the reasons for that is that some of that fire strategy falls outside of our scope. So for example, if I was to state that typically that wall would be 120-minutes, if there is a different fire strategy in there relating to the M&E sprinkler system that might be a 60-minute requirement,
Now, for the architect to say I’m not taking responsibility for that we’re going to end up with mistakes. We’re going to end up with somebody saying well, ultimately I think that should be a 60-minute wall when it’s in fact a 120-minute wall because they’re not aware of all of the contributing factors. So, it’s quite a dangerous position to be in and it also raises the question, and I’m speaking specifically about a couple of projects here, I’ve seen this 4 or 5 times in the last couple of years now. If we’re having architects saying actually we don’t feel that we are capable of providing information to do with fire performance, does that raise a competency question?
As far as I’m concerned the architect should be competent to do that. So, are we saying that the architect isn’t a competent party in providing information on Part B on fire performance within the building? Because that’s quite a concerning suggestion in my opinion.
GARETH GRIMES Matt, what is the fire engineer saying on the projects?
MATT TAYLOR Not a lot at the moment.
GARETH GRIMES So if in principle the architect will layout the floor plate, this is where the rooms are, this is the space that we’ve got to work with, the architect will interpret Part B. So what’s required in regards to travel distances laid on that. The underpinning design comes then from the fire engineer to say yes, it complies with Part B or actually we need to work outside of Part B and use 9991 or 9999. That then prompts the architect to change the floor plate, add cross corridor doors, whatever the case may be. But ultimately the fire engineer has got to be the one who’s challenging the architect’s layout in regard to travel distances.
The compartmentation is set out in ADB, so if the architect is saying well I’m taking to responsibility of this, I would be challenging well do you understand Part B or not? Because you can’t just draw something and go that’s what we’re going to build, it needs in-feed from everyone. And then there’s duties under CDM that the architect has got to provide. So it sounds very complex, thankfully I’m not on the scheme, but ultimately the challenge has got to be to the fire engineer who’s on those two schemes and saying well what’s your thoughts on this, is it a 60-minute or is it 120? And then that’s justified by ADB or 9991 or 9999, that’s my advice on that one.
MATT TAYLOR I’d agree with that, I think that what seems to be happening is there’s a huge amount of ignorance of the CDM regulations. A lot of parties that we’re dealing with regularly and organisations that are frankly large enough to know better, are unaware of the requirements of the regulations, they are unaware of their duties as a designer. We’ve had efforts to try and hide who the principal designer is on projects which is concerning. The other thing with that, on these particular projects we do have a fire engineer who’s involved. Whoever the fire engineer who’s been advising the architect is seemingly long gone. We’ve had another fire engineer who’s been put in place by the main contractor.
They have provided a report which the main contractor has disagreed with and then they’ve been told that they’re no longer involved which again is slightly worrying. And so we’re left with a situation where it’s very much a scenario, and I’m seeing an increasing number of these, where we’re almost told this is the state that the project is in, it’s now down to the Stage 5 contractors and associated consultants to pick up the pieces. And my understanding of the Gateways and the Building Safety Act is that isn’t supposed to be happening, we’re supposed to be now getting projects that are pretty robust in terms of their design and capable, to get through those Gateways they’re supposed to be of a certain standard, that’s not what I’m seeing. Again, a lot of it is confusion.
It goes back to my opening statement that I’m trying to simplify stuff. We’ve got a lot of ostriches out there burying their head in the sand and rather than seek and talk through people who have been through a process. George, can I upload a document? What I’ve generated, and everybody can take it away and use it.
GEORGE STEVENSON Just picking up on what Matt said, I think that’s really critical because what that comes down to, a couple of things spring to mind. One is scopes of service: is anybody responsible, I think it’s the client, for making sure the scopes of service are aligned? Because the point about the fire engineer is a good one, but my understanding is that a lot of fire engineers are being appointed on a relatively simple scope and they only do a certain amount of work up until a period. And then the rest of it, somebody needs to be picking what materials are being used. And what happens if the fire strategy changes? So who owns that? I think it’s all very unclear.
GARETH GRIMES Under CDM the principal designer is the one who is capturing these things, the Golden Thread should be capturing any change management. So this segue ways straight into the document I want to share. So basically on the screen is I’m working with a client who is unsure of their competencies, unsure of their duties and unsure of who the design team needs to be. I’ll share this, people can take it away and do what you want with. But basically it provides a structure of scoring everybody who’s been appointed and do they understand what their legal duties are under the Building Safety Act, under CDM and it covers the whole team. There’s a competency matrix that’s in there.
So what this proves, or at least demonstrates, that the team appointed have gone through Gateways to prove that they are able to deliver their package, their design etc. so if something happens later down the line and the BSR or whomever challenges the client under the Building Safety Act or under CDM they can say we’ve done a robust check. And it ultimately ends with a face to face interview with all parties. And what is in the back of the document are CDM regulations and what the duties are of the client, designers, contractors etc. These are all of the baseline legislation that anyone engaging on a project should be aware that they are doing.
And then ultimately when you come out to CDM using this document it’s then the Building Safety Act and the other duties required. It gives a robust confidence to clients and designers that they are meeting what legislation is asking. Loads of confusion, people are writing scabs and going this is me, that’s what we can do. But as a point that Debbie raised, lots of people are confusing different asks. So I’ve put this together and we’re working with a number of clients. I’ll share it and if people want to use it and make it your own, crack on, there is enough work out there.
My aim on this is to simplify everything where we’re making things far to complicated. There’s simple questions that we should be asking: who, what, where, when, how and why? They should be the base conversations that we’re having with anybody.
GEORGE STEVENSON I think that’s excellent, Gareth. What I think would be really useful is for us to look at other people, because I imagine that other organisations are doing something similar. What we really want to do is have an industry best practice or example of that. So if it were possible for other people. Richard Nestor from Mott MacDonald, what Gareth has just shown there, I imagine that Motts and Frankhams from Cyprian and other people would have a similar type of set of information. Now if we could bring that together, given the fact that it’s driven presumably, Gareth, from your interpretation of the regulations.
GARETH GRIMES Exactly that and through experience of the old fashioned selling yourself to the client on this is the service deliverables. Certainly in my time in the industry, lots of contracts were won at that end stage of interview. Tell me how you manage health & safety? So you’re looking people in the whites of their eyes. Everybody wants to just go well, here is all of my paperwork that says that I can do it. Show me the people front and centre who are going to deliver, I want to talk to the architect, not to the draftsman. I want to talk to the fire engineer. These are the conversations that really need to happen. Who is the person who’s applying first principles to the structure etc., that’s where you get to the nuts and bolts. Unfortunately everybody does the reverse breaststroke to say that they can deliver services and they backfill resource with people who are brand new from different industries and they’re just being admin clerks and firing out stuff. Show me the people who are building.
DEBBIE CARLTON Gareth, you can’t do that any longer in terms of competency management, you can’t do that backfilling like that.
GARETH GRIMES I appreciate that Debbie, I’m not saying it’s acceptable. I’m just saying that’s how we’ve ended up in the problematic state that we are because that’s what’s been happening.
DEBBIE CARLTON Yeah. I think it’s brilliant what you’ve done and I’ll take a look at it. I think the Industry Competence Committee last week set out its new setting expectations document on competency management, so we can look and align with that. I think it’s not a bad document, I think there’s some improvements that can be made, but the thing is we also set it in that context of the stuff that’s coming out from ICC, that would be helpful as well as good practice.
GEORGE STEVENSON David, Richard, Syprian, Matt, who are carrying out similar types of things, would you be interested…just put in the chat it you’d like us to organise something to look at that. Would you be willing to contribute what you’ve got, Richard? Or get involved in reviewing it.
RICHARD NESTOR Possibly, depending on availability, yes.
GEORGE STEVENSON Of course, that’s a given really, we’re all volunteers and we recognise that. It’s just that I think there’s a consensus that by standardising some of this stuff it’s going to make it a lot easier for people to comply. Rather than Motts having a way of doing it and other consultancies doing the same. Do you think this is worth us looking at? What I was going to do was just go back to what was discussed at the last meeting because we’ve got…this is the advisory group workshop. Debbie, you wanted to update on the competency.
DEBBIE CARLTON No, I just put the link in there, there’s just been a new document published. I’m happy to share what my feedback is on it with the group if that’s helpful.
MAT TAYLOR We’re involved slightly later in the process that Gareth. Ideally the document that Gareth had on the screen and that level of knowledge and involvement prior to our involvement in the process would be most welcome. We have a document which is a standard letter of agreement that’s sent out which is on the back of the CDM regulations. It just states that we request confirmation that the client is aware of their duties under CDM and we try and put that on to our client to try and ensure that that chain of acknowledgement of the CDM duties is carried through right from the client to whoever is receiving the information. The amount of pushback that we get to that letter is above anything else, apart from perhaps payment. We get resistance to acknowledging, signing and returning that letter generally.
GEORGE STEVENSON So is there any sort of legal requirement to do it? That’s part of the problem, but that’s not going to change.
MATT TAYLOR It’s more just an acknowledgement, under Appendix 1 the client has to acknowledge that they’re aware of their CDM duties prior to commencing works on the project. Now, because we acknowledge that a lot of parties are unlikely to be aware of their duties under CDM that’s why we at the point that we’re involved where hopefully that’s all been agree prior, we say can we just have confirmation on our involvement that other parties are aware. Like I say that should have already happened, we don’t receive any acknowledgement of that, or very rarely do we.
GEORGE STEVENSON That’s concerning. I helped facilitate a workshop that Dame Judith presented at 3 weeks ago at UCL and there was a whole range of people on that. There was the people from the Regulator, there was Cross which is the industry reporting consultancy. And what was very consistent there was discussions around competency and the lack of means of actually getting people to do anything other than signing. I think that’s quite telling really. And if we can then have a mechanism, this comes to what Debbie has been bashing me over the head with for the last 4 years.
DEBBIE CARLTON They still don’t listen, George. I think there is another issue here which is AI has a big place in helping a lot of this. And if we’re going to make the effort easier then we need to use some of the tools as well. This shouldn’t be done just by humans.
GEORGE STEVENSON I absolutely agree.
GARETH GRIMES I’ll also send Jiss a white paper that underpins what you’ve said Debbie, which is how to unlock the Gateway process using a Large Language Model with an overlay. Not specifically for fire safety, but focusing on fire safety because that’s where all of the Gateway rejections are focused on, on that fire safety element. So I’ll also share a white paper that I wrote. By all means anybody criticise it, I’m just one person trying to walk a thousand miles. But if it opens up your synapses and you can improve on it that’s my aim.
DEBBIE CARLTON I was also in discussion yesterday at a Bridge AI construction event about lots of new AI companies in construction. There was another one that was doing some interesting stuff on the building safety regulations. So, there are others trying to crack this nut, we should be aware of and monitor because at some point something will come out that is a good enough quality to help us. In terms of competency, once they’ve done that we can put a lot of AI semantics on it which is a type of AI which is trained for the competency domain, so we can add value to it.
GEORGE STEVENSON I think what’s also useful to look at is the information that we’ve been compiling on safety critical assets. We ran 4 workshops last week and out of that we’ve got some really high quality valid data information about what’s required. For example, at that Dame Judith event she actually raised a particular example of a sprinkler system that was designed for student accommodation. And the pump that was actually used was only able to pump to the 13th floor and there’s 20 floors. And the installer of the pump was aware of the fact that it wasn’t adequate, but they went ahead and did it anyway because that was the specification they were working to.
And it begs the question as to what is the mechanism for a specialist subcontractor, for example, who’s been given a spec, to actually report that because who are they going to report it to? And since then we’ve been looking with Cross about having an anonymous reporting service whereby somebody being placed in that situation who by their professional responsibilities they should have raised it. But everybody is at risk there, aren’t they? Anybody that’s above the 13th floor would be at risk. So how do they actually report it?
So we’re coming up with something in BIM4Housing we’ve got something called the Black Box section. And we’ve been doing some work on it to make that better so that by the end of this week people that come across things that they have identified, if they want to report it anonymously to somewhere we’re going to provide the vehicle for that. The final bit on that, when we were talking with the sprinkler group on Thursday, one of the experts in sprinklers said well, it’s worse than that He said in London Thames Water have turned down the pressure in the pipes because they want to reduce leaks.
He said that effects the sprinkler systems. That was a bit of knowledge that I don’t think everybody in the meeting was aware of. And who would somebody like that who is an expert in it. Who would they actually report it to? Because they can’t report it to the Regulator. The regulators now, there’s only two people that the Regulator is set up to take information from. One is residents and the other is the principal accountable person. Now, if the principal accountable person doesn’t have the budget or is compromised in some way then people aren’t going to find out. So if anybody is interested in that Black Box thing put ‘Black Box’ into the chat.
GARETH GRIMES I’m just looking at the reporting. Surely in that incidence it’s up to the AP and the PAP to report the sprinkler issue. But if they’re not listening to the designer you can use the HSE portal to raise concerns in regards to safety. So, is it not worth exploring that HSE portal and that’s where people, because that in itself reports any issues in relation to health & safety concerns in the built environments during construction etc. Just what I’m trying to do is not get you go off and there’s already something there that could be used in that instance.
GEORGE STEVENSON How successfully is it being used? How many things have you reported to it?
GARETH GRIMES From my experience when I’ve logged an issue in regards to health & safety on a construction site, whatever, where people are not listening to advice you get an email back within 8 hours and then a case officer is assigned and they will then fill in the gaps. So it might be worth speaking to the HSE and say if we raise a building safety concern via the reporting tool on the HSE website is it just going to sit in a void or will it be looked into by a health & safety executive officer who is looking at the safety concern?
Rather than the BSR because the BSR are the repurposed environmental health officers from the local authority. That’s who the BSR people are and that’s why there’s issues in regards to their ability to look at design and stuff like that because they’re not used to that, they’re used to giving things like ratings on food outlets and things like that. So they’re on a bit of a journey to up-skill. So, it’s just food for thought, rather than create something that maybe already able to be in use.
GEORGE STEVENSON Yeah, what I’m saying is that every week, every day I see things being put up on the LinkedIn of the fact that this fire door has not been installed properly or these penetration seals haven’t been done properly. And I think that information isn’t being coordinated. So, we’ve had this Black Box thing in place for years and in the early days we were getting a lot of stuff on it, but we need to structure it a little bit better and that’s what we’ve done.
MATT TAYLOR Just in relation to your example there, George, of the contractor being aware that the pump wouldn’t cover more than the 13th floor. I would say that’s not a rare occurrence. Not specifically that, but there are numerous similar items that we see on most projects. One of the problems is that at Stage 5 the contractor has allowed for whatever is in the specification. They’ve allowed for whatever design they’ve perceived. Design is an incredibly difficult thing to try and price because you’re trying to work out what might become in a certain situation. But they’ve allowed for a certain amount.
If then something becomes apparent that is changed due to something being wrong, they are working effectively outside of their contractual agreement, they have contractual fees on that item. So to report that and to go through that potentially long winded process of back and forth of why it’s wrong, prove that it doesn’t work. The number of times I hear main contractors or the client team stating prove that that doesn’t work. We’ve got a situation at the moment with a ceiling where it’s open at both ends and we’ve been told to prove that it doesn’t provide fire performance. It’s daft stuff like that that, as a contractor, you haven’t got the time to be doing that, you need to be getting on with the rest of the project.
And you mention about the anonymous reporting process. It’s a step in the right direction because in a lot of cases the contractor sometimes won’t have the means to report. So they’ll have an FRI process potentially, but a lot of RFIs remain unanswered for quite a period of time. As well as that we’ve run a couple of projects recently where the RFI process has effectively been circumvented. We’ve had an intermediate contractor who has stated they’re going to be answering RFIs. And so certainly anybody further down the chain that them have been required to communicate via email which isn’t recorded, it isn’t how the process is supposed to work. And it doesn’t surprise me that that is a result.
And I think ideally what I would want to see from this situation is a mandatory process whereby the responsible parties and the client design team have a requirement to put a process in place that acknowledges any concerns that are raised. And resolves them, or intends to resolve them, within a certain timescale. Because I think that’s the only way to do it realistically without relying on the person who’s priced and is trying to deliver the job and highlight bits and pieces and raise those.
GEORGE STEVENSON Yes, absolutely, I think that’s really helpful.
NICK NISBET No one should be relying on the HSE or the Cross reporting mechanism for something that’s impacting human safety within phase. These other routes are important, but there has to be some empowering mechanism. The airlines went through this in the 70s where flight crew had to be empowered to challenge the judgement of the captain because there had been occurrences where the captain had used his dominance and his authority to crash the plane, or take the wrong solution. So they went through a whole cultural retraining thing to say actually the captain is the captain but it’s the team that’s responsible for the safety. And if it’s necessary to put it into contracts that any issues must be notified then that must be done.
GEORGE STEVENSON Yeah, an interesting example of that that we’ve been considering at the moment is that if you look at data, if you’ve got information that is in a common data environment. And the digital record is something now that is a requirement and it therefore is an important source of information going back from when the project started and maybe going back for 10, 15 years. There’s a temptation for somebody to just have all of that deleted if they want to remove the evidence.
So, what’s the duty of care on somebody like Asite or whatever to be that permanent record? Because a contractor or somebody that is paying for that at some stage…it’s an interesting one because the digital record now…I think we’re in a very different world in terms of that type of information. Does anybody have a view on that?
GARETH GRIMES I just wanted to add a bit to that and to Nick’s point. Under the Health & Safety at Work Act by your action admissions you can be prosecuted under that, if you knowingly mislead etc. So, the reason I’m saying the HSE portal is as a designer on the project I will tell a client look, this is what’s been specified, it doesn’t do the job. I’m not an enforcer, I’m not a regulator. I advise the clients if you install that it will only come to the 13th floor, you need a bigger pump set, you need a break tank, whatever the case may be. The client chooses to do none of that then ultimately you then track that in your Golden Thread, so you’re providing within all of your documentation this is what was said on the matter.
Personally I would then raise it with the HSE, you’re protected on whistle blower policies. Getting that written into a contract is going to be very hard, especially now when contracts are attempted to be rewritten to remove the Housing Grants Act in regards to going to adjudication. Because people want more control over who determines whether something needs to be rectified or not. It’s happening now in the commercial world, there’s lots of lawyers out there trying to rewrite and cancel out certain Acts. I haven’t got the answer, I’m just saying these are the problems that are day to day and getting anybody to write, like Nick suggested, in a contract that any issues must be raised and will be actioned, I think you’ll find a lot of people avoid that.
So whatever we come up with, and it’s the royal we, it’s got to be done ethically so we’re telling the right people and the reasons why. And it doesn’t absolve us because you’re part of the project, so you’ve got then a moral choice. Do you walk away from the project? And in this commercial world not a lot of people can do that. Or do you raise it and you advise I’ve raised it with the HSE, you’re going to have to explain it to them. I don’t know, is what I’m saying.
GEORGE STEVENSON Picking up on that, you said that that installation contractor should then report it to the client or you should report it to the client. Who’s the client? If they are a specialist subcontractor that’s maybe working for a Tier 1 M&E contractor, who in turn is working for a construction company, who in turn is working for a developer. And maybe some of that is social housing where the client of that is a social landlord, who is actually responsible? It’s complicated, isn’t it.
MATT TAYLOR Again, as Gareth said, I’m not providing any answers here, I think it’s a question that needs further discussion and considerable review to try and fully understand how we might go about addressing it. But just in relation to your previous comment, George, about Asite. The RFI process via Asite or any of the other project portals, I don’t think that is a sufficient means, it’s potentially an early identification means of raising something. But the number of RFIs that are raised about everything, some of them simple easy to resolve, some of them potentially serious concerns, isn’t really an ideal platform to identify what could be a serious cause of defect. Especially if it’s something that is clear.
Now, as Nick has mentioned, ideally you would want a contractually binding obligation, a legal requirement, but as Gareth has stated it’s perhaps unfeasible to expect that to be in a contract. However, we see changes to contracts where it suits those providing them. For example, following the Tall Building Working Group we started to see numerous contracts coming through that we were being asked to sign almost guaranteeing that people would not experience creaking of the partitions in tall buildings, something that couldn’t ever be provided and it was one of the outcomes of that Tall Buildings Working Group that that wouldn't be something that should be expected. Yet we still saw it in contracts because it was almost a passing on of that risk.
Now, if not contractual, and this is more a question to the wider group, how do we go about implementing a requirement which is in effect a sort of whistle blowing procedure of somebody within that process, at whatever level, saying I’ve noticed something I don’t think is correct or I don’t think is safe. There should be a process that it has an obligation to acknowledge that and to investigate it further with the interest of resolving it.
GEORGE STEVENSON Yes, just to emphasise that, we’re not saying at all that we shouldn’t use all of the HSE example. But in the aviation industry what they do now on near misses is if the pilot reports it promptly (it’s 3 days in the UK and it’s 10 days in America) they are resolved of responsibility. So what they’re doing there is encouraging people to report examples and by doing that what they’re able to do isn’t to after that particular person at all. It’s actually to be able to identify where there are things that are happening that could be down to other circumstances and therefore they see patterns.
And that’s where I was thinking a more anonymous way of doing it would be a useful thing to do. Because then it’s not something that people are threatened by, it’s just something that they’ve found something that isn’t right and therefore you could see if that’s happening a lot across lots of examples, like that sprinkler example of the pressure not being right because of what Thame Water have done, that’s something that could get picked up a more generic level.
GARETH GRIMES Just to say to Matt, on a project really the principal designer whether that be for Part B or whether it be for the general duties, that’s the gatekeeper on safety for the project, Obviously one fire safety, one for buildables and maintenance safety. That really needs to be the person who is actioning any change or any reporting, that’s the role under CDM and also the Building Safety Act. So whatever the answer is that person almost needs to be burdened with any issues on the project where a designer is being bullied to work unethically or provide a substandard design for something, you are the gatekeeper of that information and the escalation of that, whether it be to the client, the client’s agent or whatever.
And again that person can’t force the client to do something about it, but maybe they are the gatekeeper that then raises it to the external party like the HSE or whoever. I don’t know, I’ve not got the answers, but it’s unfortunate that these things we’re having to discuss now where people are going well, you’ve only asked for this pump so it’s only going to pump to the 13th floor. You’re dealing with an HRB, it’s got 7 more floors above it. The legislation asks for all areas to be covered by sprinklers and for it to be suitably designed. You’ve not done any of that so you as a designer have failed your job under CDM etc. So, I don’t know.
GEORGE STEVENSON As Matt’s saying, even though he’s raising something there with that ceiling that he’s saying was open at both ends, it’s pretty obvious that that isn’t suitable.
GARETH GRIMES With the ceiling being open at both ends, is you’re looking at ADB and what the requirements are for those ends to be closed off with suitable fire stops or cavity barriers. So the fire engineer is the one accountable for that. Every 20 metres a void should be provided by either fire stops or cavity barriers. So you’re challenging then somebody else’s design in regards to how you are functionally meeting requirements of ADB. And if you can’t, where is your justification to use BS 9991 99, etc.
GEORGE STEVENSON But what does he do as a contractor or as a designer, what does he do? Because the fire engineer almost certainly won’t be involved. Because the fire engineer, in my experience, they’re likes hen’s teeth, it’s actually quite difficult to find fire engineers at the moment.
GARETH GRIMES Fire engineers should be involved in all of the RIBA stages 2, 3, 4, 5 and handover, Certainly any design being handed over and all of your design being part of the Reg 38 pack etc. So the fire engineer should always be involved across the scheme.
GEORGE STEVENSON Yeah, but what I’m saying is on the ground that’s not happening, I believe. The feedback that I’m getting is that the fire engineer is brought in at the beginning of the project for a particular purpose. The scope that they’re given is to I think normally to advise the architect and then they don’t get a retained commission through the life of the job. Am I wrong?
GARETH GRIMES It all depends who is appointing the fire engineer, but through the different RIBA stages and RIBA 5 being handover, the fire engineer should be involved. Ultimately in this scenario I would be writing to the fire engineer via whatever portal that does projects right and I’d be saying please be aware there are no cavity barriers within this void. And I believe there to be a breach in design, circle in the architect, whatever sort of thing. It doesn’t absolve Matt because he’s raised it, but ultimately the principle contractor on the scheme is the one who should be addressing these items.
Because that is going to be a latent defect further down the line and it will come back and bite the principal contractor ultimately where it hurts with a Defective Premises Act claims. So yeah, I think what doesn’t happen enough on schemes are design team meetings where everybody comes together and talks about issues observed in the built and with design. People are just rushing through getting it built, whereas these should be captured in real time.
MATT TAYLOR One thing I think we’re overlooking here is that this is far more of an issue on projects that we are involved in where we are acting on behalf of the trade contractor. Now, the reason for that is the trade contractor, they guys are often identifying and acknowledging these issues won’t necessarily have contact with all of these other parties. They won’t have a line of communication with the fire engineer. They won’t have a direct line of communication necessarily with the architect. Their line of communication is with the main contractor. Now, on all of the projects that we’re involved in, and to second your comments to effectively paraphrase where is the fire engineer, the fire engineers involvement in a lot of projects that we’re working on, they are looking at individual case assessments. So a PFPF assessment of a certain scenario.
In some cases they are, and this is purely what I’ve heard through the grapevine, but they’re charging anything up to £10,000 per assessment. So, the main contractor is understandable reluctant to get them involved and provide an assessment. In addition to that the assessment can only be provided once there is a large amount of primary data and in many cases there may not be. So we’re seeing very few projects where a fire consultant will be involved on an ad hoc consultancy basis.
GEORGE STEVENSON Or even a retained basis.
MATT TAYLOR Exactly that. So this is where they’ll do something if there is a very clear scope and prior instruction to provide a set of information i.e. provide a report on this scenario. But we’re not seeing that ongoing involvement at all and that’s more or less every project, there are very few. Even the ones where we’ve got an active fire consultant involvement, and we have one that we’ve had ongoing for about 18 months where they have and the fire consultant is very good. But they are still being appointed when required to provide an assessment.
DAVID SIMPSON It seems we’re lucky enough to work with very good fire consultants and also quite switched on contractors. We’ve just had 2 projects that both completed last month where the fire engineers were retained all of the way through, both design & build projects. And we had similar issues to that ceiling issue on both projects. One it was a residential project, it wasn’t tall enough to trigger the HRB requirements. But it was picked up very late in the process that there were various electrical cables running through the fire protected lobby to the fire escape stair and the lift lobby, in contradiction to the wiring regulations.
And we worked through with the fire engineer and the M&E subcontractor to, at that stage we couldn’t move the cables, everything was cabled in. So we had to look to could we put in a fire rated ceiling? Could we change the fire strategy so that that particular rule didn’t apply? And we ended up doing a combination of the two, working very closely with the consultant there Hydroc, they are now Stamtec, but that was very good.
On another project, a 3-storeys school project with cross corridor doors creating that fire break and duct work passing over the top of them. Due to the amount of services that were going through they couldn’t form fire stopped fire breaks around all of the ductwork and all of the pipework that was going through what is quite a narrow and congested corridor.
So again we worked with the fire engineer to change the compartmentation strategy on each floor so that we didn’t have to do that. Because a lot of the partitions that were already under construction, although they weren’t designated as 30-minute or 60-minute they were meeting that requirement anyway because they had to meet very onerous acoustic requirements. So their construction meant that by their very nature that they were meeting the fire requirements. So we just had to make sure that everything was fire stopped for that rating going through it.
Both of those things were then picked up by the contractor in their principal contractor role with Regulation 38 trackers that were then disseminated to the whole design team where we all had to sign that yes, for our part in it we were satisfied that the works that happened on site changes to that fire strategy had occurred and we were happy with it in our role. So I think we’ve been quite lucky in that respect for both of those.
SYPRIAN A PITKIN I think every project is different. Most of my projects I’ve had discussions with the fire engineer in deciding what they are responsible for, who is responsible for what. And I have something here from a recent meeting from a fire engineer and this is what he said to me that the fire engineer’s role is to set the minimum performance criteria for the building in order to meet the functional requirement….another issue where I raised this at a design meeting and his remarks were we do not spec detail design of system and that’s for others. The functional requirement of what is. So what they do is just show how to meet the functional requirement. They do not design system, they're just spec.
And they're saying that stuff like example fire barrier should be picked up at stage five. We put it in our report, the architect then makes sure that their drawing is updated to match the report and what have you. But I want to share something based on these conversations I’ve been having with fire engineers. (shares screen). So based on these ongoing issues, I've been having different consultant whose responsible for what, I decided some time ago to develop this document and it's a design context declaration tracker. If the client should ask me to review all of the designers this is what I use. And every designer will have a design role.
This is a document at this stage I will issue to the design team and ask them to confirm that they’re satisfied with the narrative of their design role specifically. So it depends on the project, it depends on the scope of work that contract has been agreed with the fire engineer. But with a lot of fire engineers, they don’t go beyond just giving the minimum performance criteria and issuing that report. The only time they would go back to that report and update it is if someone like myself has reviewed something, a drawing, something does not comply, then they will go back. \
Or if something is missing or another designer is clashing in our view, that’s the only time they will go back to that report and update it. They tend not to go beyond Stage 4, I rarely see a fire engineer that goes beyond Stage 4. And retainer fee needs to be considered or even Stage 5 works need to be considered and not just wait until the end of Stage 5 where there they just need to update the as-built report and handover.
GEORGE STEVENSON I think that’s really helpful. What we’ve just been discussing here I think is a good example of what we can do collaboratively. Because if we’ve got maybe some agreed scope of service where you’ve got, for example David has just said that his experience of what the fire engineer’s scope was is very different to what Syrpian and Matt have just said. And Gareth has got an expectation of what the fire engineer should be doing, but unless that’s reflected in some sort of agreed scope then everybody is going to assume that the fire engineer is going to be doing something that they’ve not been scoped to do. So what I’m suggesting is that we maybe look at that as being let’s get together for an hour and share some examples. So if you’d like to do that then put ‘scope’ into the chat.
MATT TAYLOR I’m not disagreeing with anything that either David or Syprian have said there. I suspect this may be a combination of two concerns. Firstly I believe that the fire consultants’ appointment may not be continuing much after Stage 4. So it wouldn’t surprise me to see the fire engineers’ involvement being maintained up until the end of Stage 4 where it goes over to contractor design. And then they are no longer appointed or it’s considered that their services are no longer required because it’s then the contractors’ responsibility. In addition to that, just reflecting on a couple of points that Syprian made, I think that there is an interpretation that the fire engineer or specialist trade package consultant will provide information and therefore one or the other is required, when in fact that’s not the case.
There should be a trade specific specialist involved who is going to work on detailing making the arrangements feasible. But as well as that, if they are identifying issues they need to be fed back through the fire engineer. I’ll use a particular case example. We had an interface on a medical research project where there was a security wall and the line of the security mesh meant that it was running in the opposing direction to the fire compartment corner. Therefore you could either have a fire compartment corner or a security corner and it was simply a matter of one or the other. We raised this, but we said it’s ultimately going to require a revision of the fire strategy to resolve this.
But it was quite difficult to get any involvement from the fire consultant on the project to actually start to investigate that and it went on for at least a couple of months of to and fro of people trying to avoid the scenario what about if we do this, rather than actually focus on what needed to happen and put a plan in place to resolve it.
GEORGE STEVENSON How was it resolved?
MATT TAYLOR Ultimately the fire engineer got involved and there was an amendment to the fire strategy. And it that case there was actually resolution by…that’s what it needed, to be honest, it’s not something, I think we’re all too keen to say it’s a contractor problem now, it’s become their issue. But in a lot of cases if they are identifying the problem we should be grateful for that. Not saying OK well, it’s your issue because you’ve identified it because often they don’t have the means to do so.
Even if they’ve got a consultant involved. We can further explain the issue, we can say what we think needs to be done, but we may not have the multi-trade package involvement to resolve that. And in some cases if it’s an amendment to fire strategy that should be going back through the fire engineer. We can’t have contractors implementing fire strategy changes, there will be mayhem resulting from that.
GEORGE STEVENSON I hope everyone has found the meeting useful, I feel these sessions are helpful. Syprian, the scope thing, we’ve got a few people that said they’d be interested in getting together on that. Is that something that you’d be willing to share some of the things that your are doing there?
SYPRIAN A PITKIN Yeah, I would.
GEORGE STEVENSON We’ll try and set something up on that. And the other question that we opened up with was the question on the PDBR toolkit. I think David you were saying Associated Architects, you’ve done your own version of that. Is that something we could get one of your people that have been involved in that engaged in looking at that?
DAVID SIMPSON Yes, I’m sure it is.
GEORGE STEVENSON If anybody else is interested in the RIBA toolkit side of things, I think Gareth you do PDBR and Syprian does, so we’ll maybe pull something together on that.
CHAT
Debbie (Unverified)…. ICC latest if missed - https://consultations.hse.gov.uk/hse/icc-consultation/
Nick (Unverified)…. CROSS = legally required voluntary reporting
Gareth Grimes (External)… https://www.hse.gov.uk/contact/tell-us-about-a-health-and-safety-issue.htm
Academic Summary – Advisory Working Group Meeting BIM4Housing
Purpose & Context
The Advisory Working Group met to coordinate BIM4Housing activity, align outputs with regulation, and share lessons on improving building-safety information management. The group includes strategic leads, technical specialists and advisors, chaired by George Stevenson.
The session emphasised cross-group collaboration, clarification of roles, and practical implementation of regulatory principles across the BIM4Housing programme.
1. Governance and Scope of the Advisory Role
- George Stevenson explained that the Advisory Group’s purpose is to improve consistency in advice and facilitate learning between groups. He referenced recent workshops on safety-critical assets and a Miro board being used to collect examples and suggestions.
- Participants agreed that the advisory function should enable interpretation of regulation and promote shared understanding, avoiding duplication between groups.
2. Competency, Roles and Scope Confusion
- David Simpson, Syprian Pitkin, Matt Taylor, and Gareth Grimes discussed the confusion surrounding scopes of service — particularly for fire engineers, principal designers and contractors under CDM and the Building Safety Act.
- Syprian and others highlighted that some templates (such as the RIBA tracker) are being used inconsistently, and that Regulation 38 and handover information are often misunderstood in relation to RIBA stages.
- Others argued that design intent must be properly represented through to construction and handover, rather than being lost between project stages.
3. Data Assurance, Reporting and the “Black Box” Idea
- George Stevenson and several members raised concerns about the reliability and permanence of digital records in Common Data Environments (CDEs).
- The group discussed the idea of a “Black Box” — an anonymised reporting tool for safety issues or recurring system failures. Existing channels (such as the HSE portal and CROSS reporting) were considered useful but insufficient for capturing systemic problems.
4. Practical Implementation Problems: Examples and Causes
- Matt Taylor, Gareth Grimes, and others provided examples where project delivery diverges from specification — for instance, inadequate sprinkler pump capacity or delayed fire engineer input.
- Participants observed that commercial and contractual pressures often discourage proactive issue reporting or remedial action.
- Several agreed on the need for clear scopes of service and consistent competency checks so that responsibilities are correctly assigned and understood.
5. Use of AI and Automation
- Debbie Carlton and Gareth Grimes explored the potential of AI tools to support competency assessment and automate aspects of compliance checking.
- However, participants stressed that automation must always be paired with human oversight and verified datasets to maintain trust and accountability.
6. Coordination and Good Practice Sharing
- Gareth Grimes shared a competency-scoring framework and invited participants to contribute their own templates.
- David Simpson and others noted that retaining fire consultants through later stages significantly improves coordination and reduces design-construction gaps.
- Members agreed that pooling similar materials from multiple organisations would strengthen cross-industry consistency.
7. Emerging Consensus and Next Steps
- Participants committed to sharing examples of scopes of service, competency matrices and case studies.
- The Advisory Group will synthesise materials from other working groups, promote standardisation, and support the development of the proposed Black Box reporting mechanism.
Emerging Themes
- Advisory oversight must facilitate interpretation, not control.
- Role definitions and scopes of service require alignment to close gaps in responsibility.
- Reliable, permanent digital records are essential for traceability and assurance.
- Anonymous reporting mechanisms could improve transparency and accountability.
- AI and automation have promise but must remain human-verified.
- Cross-industry sharing of templates will enhance consistency and learning.
Key Insights & Lessons Learned – Advisory Working Group Meeting BIM4Housing (01-10-2025)
| Insight / Lesson | Explanation |
|---|---|
| Advisory Role as Enabler | Oversight should facilitate consistent interpretation of regulation and reduce duplication, not impose control. |
| Clarify Scopes of Service | Inconsistent scopes (fire engineer, architect, contractor) create gaps — industry examples and templates would reduce ambiguity. |
| Retain Technical Specialists | Projects where fire consultants are retained through multiple stages achieve smoother coordination and better safety outcomes. |
| Reporting and Escalation Gaps | Existing channels (HSE, CROSS) are limited; an anonymised “Black Box” could surface recurring safety issues and systemic weaknesses. |
| Contractual/Commercial Barriers | Adversarial contracts and fee structures can discourage reporting; procedural accountability is required. |
| Data Assurance and Permanence | Digital evidence must have clear ownership and permanence within CDEs to maintain traceability and reliability. |
| AI as a Supportive Tool | AI can automate repetitive compliance checks, but human verification remains essential. |
| Pooling Best Practice | Sharing competency matrices and scope templates across firms raises baseline capability and supports sector-wide alignment. |
