In this final article of three related to the importance of getting firestopping right, Simon Ince, Project Engineer with UL, discusses the value of independent Third Party Certification, illustrating how it can support improved fire safety standards.
The previous two articles in this series touched on some of the steps that can contribute to a voluntary culture shift; before any new regulations enforces that shift.
There isn’t a single solution or a magic wand that can be waved to improve the delivery of fire safety in the construction process. However, one area that has international recognition for helping improve quality and compliance is that of independent Third Party Certification (TPC) of products, services and management systems.
In the absence of regulation and stringent enforcement, Third Party Certification of firestopping on a voluntary basis is a useful differentiator for those who purchase and then depend on products or services to be fit for purpose. It also offers strong support to the due diligence process for those procuring firestopping products or services. TPC isn’t a guarantee, but rather a very good assurance of compliance or quality.
This article will reaffirm why TPC offers high levels of assurances, while exploring how TPC can support improvements to the building system as identified in the Hackitt Review.
As a global company, UL appreciates the subtilties of all the different markets we help clients sell into. The one common element across all those markets is the value TPC from an independent body offers. That value isn’t just for the manufacturer or service provider; the added value TPC offers is also for those purchasing from an often confusing marketplace.
When it comes to products or services that have a life safety function/performance requirement, having assurances from an independent expert body gives the buyer confidence in their purchases. Someone other than a user, manufacturer or service provider is giving this product or service certification. That independent certification denotes that the product or service conforms to a published set of requirements.
The purchaser can and should read those requirements and make a judgment on the level of assurance that adhering to those requirements offers. If they are happy that the product or service has been successfully and independently assessed against specified requirements and those match their own requirements; then they should be assured that what they are purchasing is fit for purpose. Steps 3 (a strong submission) and 6 (work control) as outlined in the previous article, stress the importance of having TPC to back up the design and build process.
In 2017 the Department for Business, Energy and Industrial Strategy (BEIS) reissued a document on behalf of Her Majesty’s Government, outlining their policy on Conformity Assessment and Accreditation for the UK. This document clearly spells out what conformity assessment is, what the benefits of conformity assessment are, and when and how it should be used. The document also states that it is important that those bodies who carry out conformity assessment activities are accredited to do so; thus increasing the assurance that their technical assessment is accurate and consistent. Accreditation of the conformity assessment body is judged against internationally recognised standards offering objective proof of a high standard of performance by the assessment body. Conformity assessment for firestopping products and installers should be provided by an accredited certification body.
The United Kingdom Accreditation Service (UKAS) operates under a memorandum of understanding with the UK Government and is the sole provider of accreditation in the UK. Accreditation by UKAS offers further assurance that the conformity assessment body is competent, independent and works with integrity in its conformity assessment certification services.
The value of accredited conformity assessment here in the U.K. is clear from this paragraph.
“Conformity assessment and accreditation are important parts of the nation’s quality infrastructure. By providing confidence in goods, services, management systems, and people they make a significant contribution to the economy, health and safety and environment”.
TPC is more than just testing; it examines the ability of the manufacturer or service provider to deliver a firestopping product or service consistently and to a defined standard. Consequently, the basis of many TPC schemes is an audit of the manufacturers’ or service provider’s Quality Management Systems (QMS).
The Certification Body (CB) will audit and seek evidence of good practice by the manufacturer or service company by asking questions of the company so they can validate claims of performance or competence; What does the company do to ensure that they have suitable checks and balances in place? How do they ensure personnel are competent to do their job? What internal quality checks do they have to ensure the product or service is fit for purpose? How do they internally review their processes and procedures to make sure the end result is always consistent?
In addition to any initial testing and QMS audit, there is normally a requirement for ongoing surveillance of the QMS and production/service, as well as random sample testing. However, it is important to stress again, that those who wish to gain assurances from TPC, should take time to check the scheme requirements, thus ensuring the scheme is robust and also to determine what process the manufacturer or service provider has been through to gain certification. TPC conformity assessment schemes are generally developed by CBs with wider stakeholder involvement and they generally fit into one of four categories;
Dame Judith Hackitt
Following the Grenfell fire in June 2017, Dame Judith Hackitt made over 50 recommendations on what needs to improve in relation to the construction industry and improving fire safety in the built environment. In her 2018 report she made it clear that if change was to occur, then an integrated approach had to be adopted.
In 2019 the Ministry of Housing, Communities and Local Government (MHCLG) agreed with her findings and in their response to a wider consultation on ‘Building a Safer Future’, they have since issued the draft ‘Fire Safety Bill’ and supporting legislation. It is expected that this Bill will be introduced sometime in 2021.
Dame Judith’s report however has triggered much more proactive responses from the fire sector. Many sector working groups have been developing industry backed recommendations; looking at competence, governance, new/improved guidance, standards and regulations. The Grenfell tragedy has quite rightly made the fire sector look at itself with critical but forward-looking eyes. The joint aim of all these groups and Government is for improvement across all areas; preventing another tragic fire and also to reassure all those who live in multi-occupied residential accommodation that their homes are safe and the risk from fire is as low as reasonably practicable.
So, where can third party certification help with the implementation of some of the many new recommendations? The concise answer is, everywhere it is already helping, and more if needed and asked of. Below are some examples of where third-party certification already supports quality assurance in the construction sector and how it might be called upon to support new areas.
The ‘golden thread of information’ has been a phrase well used since the Hackitt Report. Having accurate and evidenced information about the fire protection measures in a building is something that is essential. It confirms the suitability of the product and how that product matches the original design intent.
TPC of products already provides much of the rationale of the Golden Thread requirements. The certificate of conformity is normally available from a publicly available listing. The certification process confirms independently that the tests which support the performance claim are relevant/valid and contribute to the final certificate content. The certificate and listing will reference the product by name and describe its generic makeup. It will reference the producer and have a description of the overall system including the substrate used, the fixings used, the size, diameter, dimensions and even colour of the product tested, and most importantly it will describe the scope of its end use application.
The certificate and listing can be used to confirm the manufacturer’s claims of performance and more importantly the parameters that dictate that performance. The operation and maintenance manual will confirm the other parameters needed for maintenance and life expectancy of the product once installed.
Many reputable manufacturers and service providers see TPC as an essential requirement in the market. As outlined by UK Government policy, TPC can offer a competitive advantage – indeed many more tender specification documents are having TPC written in as a required criteria.
Despite much care being taken on testing and subsequent certification, the product is only as good as the installation of the product or system. Certification of installers of fire protection has been around for years, and again just like product certification, TPC is also being set more frequently as a requirement on tender documents.
TPC isn’t mandatory however and as per government policy it is unlikely to be made so. Therefore, other drivers need to be in place for TPC to assist more with quality assurance and conformity. The introduction of identified duty holders who are ultimately accountable may well change the way TPC is used; at least for buildings in scope of the new regulations. The client, principal designer and principal contractor will have a defence in court if something in their responsibility wasn’t done properly. Due diligence will need to be shown to have been done. i.e. What more could that duty holder have reasonably done to make sure the fire protection/firestopping was fit for purpose?
TPC is normally regarded as good evidence that due diligence has been seen to be done. It offers the duty holder a defence and also an assurance that a defence won’t ever be needed.
Competence of individuals has been a major focus area for the fire sector with much of the work done by the Competence Steering Group. It is anticipated that three duty holders will have their competences defined in a UK Publicly Available Standard (PAS) – the principal designer and principal contractor plus the building safety manager. Having a standard for those companies and individuals will allow for conformity assessment, either through a company certification scheme for the service providers, or through a competent person scheme which could be more suited to the role of building safety manager.
Another role which the Competence Steering Group identified as being much needed is that of Independent Construction Assessor (ICA); effectively a clerk of works appointed by the client in a construction project who is tasked with overseeing the project and ensuring quality is delivered. As this is an identified individual with a specific skill set, it could be appropriate to have them certificated as competent by an independent body.
TPC supports many other areas of fire safety – design of active fire protection systems, certification of fire risk assessors, fire risk management certification and certification of companies who maintain and service fire safety systems and appliances.
Having voluntary certification across the fire safety sector is proving to be increasingly valuable; it is becoming essential for manufacturers and service providers in the passive sector to have TPC, as their clients see the benefits and are becoming aware of the downside of not insisting upon it. Commercial drivers will always provide an incentive for those who are missing out on tenders or whose products are not being specified. Consumer pressure is increasing the demand for TPC and ultimately certification schemes are for the protection of the consumer. In the area of firestopping TPC undoubtedly is supporting change.
Within the draft Building Safety Regulations there is a requirement for existing occupied buildings which fall within scope to have a robust and structured management system in place. Requirements such as having a resident engagement strategy and providing a safety case will add to the workload for those accountable for buildings.
TPC could be used to help building operators to demonstrate to all stakeholders that they have a robust and audited management system which is applied to the building to keep it as safe as reasonably practicable. BS 9997 prescribes how a management system can by applied to an organisation’s fire safety management at a strategic level.
There may be a case, however, for a more focused management scheme which is applied to a specific named building, which addresses the specifics of the Building Safety Regulation requirements. A TPC scheme which assists the regulators and enforcers to identify those following best practice will enable them to focus on those with less assurance and potentially more risk. This risk-based approach has been discussed in the past and there can be little doubt that a scheme designed to demonstrate compliance with a regulation would have many benefits for stakeholders; especially the residents of the building it applies to.
Residents will know that continued certification is based on the management system meeting a set of published requirements. Thus, offering them independent assurance that their building is as safe as reasonably practicable.
We are at a point where very soon fire safety is going to change. All the work going on behind the scenes since Grenfell is going to start to materialise into standards, guidance and regulations. Once published it is going to be expected that people, products, services and management systems conform to those published expectations. Third Party Certification is a tool to be used to help with conformity assessment and quality assurance. However, those with an interest in offering TPC shouldn’t necessarily be the sole designers and administrators of schemes.
New TPC schemes should be driven by consumer demand, or where there is a specific need identified by government. It should be clear to all that the need for fire safety assurance has never been more prevalent. MHCLG and stakeholder sector bodies need to approach Certification Bodies who have the technical expertise, capacity and systems to support conformity assessment and quality assurance in the UK.
In summary, Third Party Certification, or TPC, is an internationally recognised system that can help change the fire safety sector. Dame Judith Hackitt identified the construction process as “being broken”. TPC could help prevent similar breaks in the future and as part of a complete overhaul of fire safety, it could provide some/many of the much needed quality assurance and conformity assessment indicators required.
As touched on at the beginning of this article, this is the final article in the series on firestopping from Simon. The previous two touched on some of the steps that can contribute to a voluntary culture shift; before any new regulations enforces that shift.
Access new fire safety expertise by downloading the free Barbour Director's Briefing, and learn how to create a 'carefully devised plan of action' to make your fire strategy more comprehensive than ever. In this free Director’s Briefing, Barbour EHS provides key information relating to the Regulatory Reform (Fire Safety) Order 2005 in England and Wales, including what is required from the responsible person of a property.
Disappointing that you don’t see much chance of TP becoming mandatory. Effectively, gas safety is delivered this way, so it wouldn’t be such a huge leap. I believe that gas changed after a series of explosions, so Grenfell should be the fire to trigger this change in construction.
Unfortunately market forces is the only way I can see TPC becoming the must have. i.e. if every customer is asking for it and you don’t have it then you are going to get it or go bust.