Colin Timmins, H&V Portfolio Manager at BEAMA, warns of the dangers of scrapping the Domestic Building Services Compliance Guide.
Published in 2018, the Hackitt Report into Building Regulations and fire safety made some significant recommendations for building compliance. In particular, there is the recommendation that the Building Regulations generally need to be improved because, it said, “the package of regulations and guidance (in the form of Approved Documents) can be ambiguous and inconsistent”.
While this review was stimulated by the tragic events surrounding the Grenfell Tower fire, there is a recognition that all aspects of compliance and enforcement could be improved upon, not just fire safety.
This will include energy conservation, covered under Part L of the Building Regulations and, with the government’s focus on achieving net-zero, it will be increasingly important that opportunities to improve the energy efficiency of homes are not being missed.
As a reaction to the drive for greater clarity, the government proposed in the recent Future Homes Standard consultation that they would aim to improve clarity by putting all of the minimum standards for building services into the ‘Approved Document’, meaning that there would be no need for the accompanying Domestic Building Services Compliance Guide.
This sounds sensible but there are two important things to consider. The first is the sheer level of detail that is provided in the Compliance Guide. There are sections on all types of heating system and controls and I would argue that it is more comprehensive than confusing.
In most cases it is used as a reference rather than a step by step guide, so the level of detail makes sense. Moving this information into the Approved Document means that the level of detail will be reduced and undoubtedly things will be lost.
The second aspect to consider is that industry is familiar with referring to the Compliance Guide. While it is guidance only, it does provide the commonly accepted standards for compliant installations, so anything that disappears from the guidance could well end up not being installed as common practice.
While installers will want to install a compliant system, there will always a danger of being undercut by competitors who will focus on the minimum standards and nothing more. There is a whole grey area between minimum standards and accepted minimum practice, and the fact that the Compliance Guide traditionally sets out the latter is a good compromise towards ensuring systems are installed to run as efficiently as possible.
In setting out their intention that the Domestic Building Services Compliance Guide will not continue, the government state that industry could provide their own guides to supplement the Building Regulations minimum guidance. While there is sense in this, there is also a very real danger that we could end up with conflicting industry guidance, leading to less clarity rather than more.
The Compliance Guide was always seen as a government document and therefore the ultimate statement on what should be done, something that other guidance will always lack. Whereas industry guidance has always served a key role is in helping to interpret what the government guidance means in practice. This cannot help where there is ambiguity from the government, as demonstrated by the lengthy confusion over what was meant by the Boiler Plus definitions for smart controls.
An interesting point made in the Building Regulations consultation is that the Compliance Guides were introduced “at a time when the industry was undergoing rapid change to implement new energy efficiency standards, and the documents have served an important purpose in providing additional guidance to the Approved Documents”.
Considering that the next few years are going to see even more significant changes for the heating industry as we move away from fossil-fuelled heating to low carbon options, it seems strange that the Compliance Guides are now seen as surplus to requirements.
The final decision on this will only be made once the responses to the Building Regulations consultation have been carefully considered by the government. As we’ve said before, clarity on minimum standards is always desirable, and there needs to be flexibility in compliance as long as a suitable efficient and effective system is delivered to the customer.
The complexity in building services systems, both for the installer and the building control bodies that enforce the regulations, means that any changes to the level of guidance provided could lead to unforeseen consequences. It is to be hoped that the government takes every care to ensure that any changes implemented will help industry consistently deliver the low energy heating systems that are a fundamental element on the path to decarbonisation.
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