"Those who fail to learn from history are doomed to repeat it." Winston Churchill

Something feels very odd about Dame Judith Hackitt's Interim Report. There are bits missing as if it's been edited by lawyers.

Despite being an interim report, much can be learned from the approach that has been taken and the direction in which the report is headed.

The importance of cladding combustibility is acknowledged by reference in the very first paragraph. Why then, is the issue essentially avoided in the subsequent 115 pages? At first glance, you might think that this is due to the broad scope of the enquiry, but the remit is much more specific to the Grenfell fire than the title of the report suggests.

In 1.39 (a section relating to the marketing of products) the report claims that there is no simple reason to explain why so many buildings are clad in hazardous ACM. But, of course there is a simple reason: it simply isn't (or certainly wasn't) a requirement of Approved Document B that it should be of limited combustibility, as is unjustifiably assumed from the outset.

As suggested by my opening quotation, if DJH believes that Guidance requires cladding to be limited combustibility, surely it would be remiss not to investigate the origins of that specific guidance and examine why it has spectacularly failed. When did it come into effect? Did the specification of buildings change at that point? Who drafted it? Who reviewed it? What steps were taken to update the industry and Building Control to the changes? And why did nobody notice it wasn't being adhered to?

But there are suspicious, associated omissions in the report. When over-briefly analysing how Regulations and Guidance are developed, the contextual importance of the BRE's role over the past 20 years in drafting Approved Document B is completely ignored. It gets worse..

Chapter 2 gives a chronological breakdown of the development of Building Regulations that refers to two key historic events in high rise external fire history. Why, in 2.16 does DJH bizarrely refer to the introduction of BS8414 testing following the Garnock Court Parliamentary Committee but NOT the associated recommendation that cladding should be non-combustible as an alternative to the test?

That was an opportunity tragically missed and hugely damning for the government, as famously Scotland adopted this route while England and Wales ignored it. This report is too detailed to miss that, and those who drafted it are too clever not to note the relevance. (If you read 7 (b) and (c), you also see that historically, it is generally accepted that 'external surfaces' as covered by AD B Diagram 40, is actual cladding itself, not just the external layer of the cladding material as some have wrongly claimed.)

In 2.17 Lakanal House is referred to in which six people died because of an illegally specified, combustible high-pressure-laminate panel - no 'filler' anywhere to be seen here. At that coroner's inquest, DCLG are on record confirming that high rise cladding was only required to be Class 0 as anything more stringent would limit the choice of materials. So at the very least, that explains why many early buildings are clad in cheaper combustible materials. The report refers to the coroner's recommendations, particularly in relation to clarifying AD B, but fails to say whether these were acted on and how. If they were, then the actions would be highly relevant and worth examining. If they weren't, then that's a fundamental failing of the Regulations process under review. Either way, it's a significant omission.

So, if this limited combustibility requirement did come into effect, when did it happen? Surely, that would be a milestone in fire regulatory history? What clause changed, and why was it so badly worded that nobody took any notice? Don't we need to understand that to make sure it doesn't happen again? No amount of reformed Building Control, Fire Risk Assessments or supply chain accountability would have prevented the polyethylene cored ACM being fitted to Grenfell because it conformed to the Guidance and as DJH points out, legally therefore, those involved will be deemed to have satisfied Regulations.

It's also remarkable given the evidence submissions I've seen, that DJH doesn't acknowledge the almost universal call for cladding to be limited combustibility. Didn't that seem odd to them if it already was the case? In fact, in RIBA's case, it's notable in itself that they even call for high rise cladding to be non-combustible. Isn't it significant that even RIBA don't seem to share her view that Guidance already requires cladding to be at least limited combustibility?

This is of course, an interim report. But a ship that sails from the wrong place, stubbornly heading in the wrong direction is unlikely to reach the correct destination.