Hackitt Review on Fire Safety: an isolated approach to building regulation?

In her review, Building a Safer Future: Independent Review of Building Regulations and Fire Safety: final report, Dame Judith Hackitt confirms what many people already knew: there is widespread ignorance, indifference and inadequate regulatory oversight and enforcement. This criticism is largely aimed at the construction industry.  She calls for a new regulatory framework that will "drive real culture change and the right behaviours" (p. 6). A key recommendation is her call for a stronger enforcement agency that covers the entire life cycle of a building - but only in respect to fire safety. The report also exports more responsibility onto the construction industry for fire safety. 

Hackitt is to be commended for focusing on the actual performance of buildings over their life, not merely a hypothecated version when they are built. This is a significant move. It will help to accelerate the change in how society and the construction / property industries think about buildings and our practices in producing and operating them

The report implicitly acknowledges a need for system-based approach to fire safety. However, it is an ad hoc approach and fails to take its own logic to a reasonable conclusion as Hawken, Lovins & Lovins (1999, p. 117) stated:

"the optimisation of components [of a system] in isolation tends to pessimize the whole system."

The provision of public safety is a key aspect of building regulation and there is a long history of the state ensuring this. However, the brief for the Hackitt Review is partial and only addresses one strand: ensuring fire safety. This is understandable given the tragedy of the Grenfell Tower fire. However, it cannot be considered in isolation. The opportunity has been side-stepped to undertake an overarching review of the scope and goals of regulations in order to go back to first principles and address them in a systemic way. 

David Eisenberg (2016, p 469) identified that most regulatory reforms are based on sub-systems that address specific hazards. This is the problem with this Hackitt Review - its focus is only on one aspect and lacks integration. As Eisenberg reminds us: the formulation of building regulations lacks a process for considering risks from changing circumstances, notably mitigation and adaptation to climate change, but also the changing availability of resources (water, energy, materials and waste) as well as other factors of how the uses of buildings change over time. It's not unusual for a building to be designed for one use (offices) and then change to a different use (residential). Or for a residential building to actually have many different uses under the same roof (retail, commercial, office, residential).

Although the Hackitt Review advocates a joined-up approach to fire safety, it is reactive and misses an opportunity to more broadly rethink how buildings are regulated. This cannot be done in isolation for each aspect (e.g. fire safety). It is essential to also include the broader aspects of building operation, such as energy efficiency and demand. At first glance, one might consider safety hazards and the environmental hazards (e.g. energy consumption) to be radically different but there is a compelling argument for including not only immediate risks (fire safety, structural integrity, etc) but longer-term risks.

For example, one recommendation (8.1) in the Hackitt Review that mandates a digital standard of record-keeping for the design, construction, maintenance,  occupation and refurbishment of high-rise residential buildings (HRRBs) might be extended to include records about other aspects germane to the scope of building regulation (e.g. indoor temperatures, air quality and energy consumption). The creation of "passports" (or digital records) for buildings would address the asymmetry in information that exists for buildings (when buying, selling or renting property) and also provide a clear picture on other aspects of building performance in relation to existing regulatory requirements (Lützkendorf & Lorenz, 2011).

Recommendation 10.19 for the UK to rejoin and learn from the international community is welcome. In addition to rejoining the IRCC (Inter-jurisdictional Regulatory Collaboration Committee) the UK would benefit from involvement in other organisations that develop principles and approaches to building regulations such as the International Living Future Institute which has created the Living Building Challenge which has a measurable and outcomes-based approach.

There are many lessons to learn from the present poor governance of buildings. There is a pressing need to address the prevention of fire and the creation of a resilient approach to protect the lives of occupants. But there are equally important other issues that must also be addressed.  This is an an opportunity to look afresh at the entire regulatory process for the design, construction and operation of buildings. The Hackitt Report forms a basis for this discussion, but we need to go much further and develop a holistic approach to change both the culture of practice within the construction industry as well as how it is regulated.

References

Eisenberg, D. (2016) Transforming building regulatory systems. Building Research & Information, 44(5-6), 468-473. https://dx.doi.org/10.1080/09613218.2016.1126943

Hackitt, J. (2018) "Building a Safer Future: Independent Review of Building Regulations and Fire Safety: Final Report. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/707785/Building_a_Safer_Future_-_web.pdf

Hawken, P, Lovins, A and Lovins H. (1999) Natural Capitalism: Creating the Next Industrial Revolution. Boston: Little Brown. https://www.natcap.org

Lützkendorf, T., & Lorenz, D. (2011) Capturing sustainability-related information for property valuation. Building Research & Information, 39(3), 256–273. https://dx.doi.org/10.1080/09613218.2011.563929