Six Honest Serving Men and Women

I KEEP six honest serving-men (They taught me all I knew); Their names are What and Why and When and How and Where and Who.

Rudyard Kipling Just So Stories for Little Children, 1902

https://www.kiplingsociety.co.uk/poems_serving.htm

Every Journalist knows Kipling's approach to enquiry. Hopefully the questions raised by Jim Glocking of RISCAuthority and the Special Projects Group of the Fire Protection Association will get the serious attention they deserve. The Fire Protection Association has published a Report of their research dated 22 February 2018 sent to Judith Hackitt's Review of the Building Regulations and the Grenfell Tower Inquiry:

CLADDING APPROVALS A review and investigation of potential shortcomings of the BS8414 standard for the approval of cladding systems such as those commonly used on tall buildings

https://www.abi.org.uk/globalassets/files/publications/public/property/2018/04/abi-cladding-systems-research-report-2018-04-19.pdf

The Report speaks directly to the SYSTEM test allowed as an alternative to PRODUCT testing in Paragraph 12.5 of Approved Document Part B Volume 2:

Commissioners of the research, the Association of British Insurers, declared in a Press Release on 25 April 2018 '... the utter inadequacy" of BS 8414 external wall system tests. In the Press Release titled "Scale of fire safety testing failures laid bare", Huw Evans, the Director General of the ABI, said:

'Dame Judith Hackitt’s important work post-Grenfell has already recognised the building control system is broken. This latest research is yet more evidence that fundamental reform is needed to keep our homes and commercial premises safe from fire. It is a matter of urgency that we create the right testing regime that properly replicates real world conditions and keeps pace with building innovation and modern design.'

Perhaps a way to understand this is that "building innovation and modern design", or the Government's policy push to "Modern Methods of Construction", has been pursued by gaming the BS 8414 test in both its Parts. The SYSTEM test was developed after the Garnock Court Fire in 1999, when it was recognised that PRODUCT tests were inadequate. The mood reflected by the Select Committee hearing and Report in 1999/2000 was to expect that the external wall shall only be built of non-combustible MATERIAL.

www.publications.parliament.uk/pa/cm199899/cmselect/cmenvtra/741/9072001.htm

www.publications.parliament.uk/pa/cm199900/cmselect/cmenvtra/109/10901.htm

Nick Raynsford, as the Minister responsible at the time, and notably advised by Paul Everall, went on to allow combustible materials to be SYSTEM rather than only PRODUCT tested, and assessed. The Second Special Report – Government Response to the First Report is here:

www.publications.parliament.uk/pa/cm199900/cmselect/cmenvtra/389/38902.htm

Everall has been Chief Executive of LABC, the representative and promotional body for Building Control teams working in local authorities, since its formation in 2005. Raynsford is Chairman of the Construction Industry Council Approved Inspectors Register (CICAIR), and Chairman of both the NHBC Foundation and the NHBC Foundation’s Expert Panel. Both the LABC and NHBC have endorsed BS 8414. The assessment of the BS 8414 test continues in accordance with the BRE's BR 135 Fire performance of external thermal insulation for walls of multistorey buildings, published in 2013 to a Third Edition.

The FPA-RISCAuthority Report just published does not address the BR 135 assessment. It looks at the test.

BR 135 was first published in 1988 in response to what was then recognised as the increasing use of thermal insulation as part of refurbishment programmes on existing residential tower blocks. That is over a decade before the 1999 Select Committee asked for a British Standard to "full scale" test the fire performance of external cladding systems. After BS 8414 had been issued by the BSI, the Second Edition of BR 135 published in 2003 provided a method of assessing the fire performance from test data. It offered design principles that reflected changes in commercial products and systems. It was not what the Select Committee had foreseen, but BR 135 became the document that gives the criteria for BS 8414 testing in two Parts, not the British Standards themselves. A critique of BR 135 is logically due.

Jonathan O’Neill, Managing Director of the Fire Protection Association said:

'The results of this important research confirm long-held concerns by many in the fire sector that the current cladding test standard requires urgent review to ensure that systems that pass are reflective of the systems that are installed and of the risks to which they are exposed. We urge BSI (British Standards Institution) to urgently reconvene the group responsible for this standard to consider the results of this research and to make changes to the standard as required.'

With apologies to Glocking, O'Neill and Evans, the Kipling style questions they have raised are:

1) What would an adequate SYSTEM test be?

2) Why are ALL ELEMENTS not considered, such as membranes?

3) When might PRODUCT testing be adequate?

4) How can consultants and contractors proceed to design and build without FULL DISCLOSURE of tested details and specifications in both PRODUCT and SYSTEM tests?

5) Where is additional testing of the CAVITY BARRIER required?

6) Who will ensure that as tested MATERIALS and WORKMANSHIP are replicated consistently on site so that Regulation 7 might be complied with?

https://www.legislation.gov.uk/uksi/2010/2214/regulation/7/made

Other questions are available...

More honest serving men and women like Jim Glocking are urgently needed to ensure compliance with Regulation 7, which of course has its own Approved Document.

Regulation 7 is the Elephant.