The Government is valiantly trying to turn over a new leaf in UK construction products’ safety and certification, and on 21st May the online consultation it launched to seek input on its Green Paper proposals officially closed.
So, will we now see meaningful action?
From our standpoint, as providers of sustainability-focused, energy-efficient building solutions, it’s debatable.
Here's our brief guide on what the Paper covers – and why, despite the name, its proposals are not as green as we would have hoped and even raise some red flags.
What issues does the Green Paper cover?
The Paper runs to some 158 pages, but the essence of the problems it addresses can be boiled down into five key points:
- A substantial number of construction products are still unregulated – around two-thirds of them, in fact.
- Many products lack robust safety evaluations. The focus of the current regulatory regime has primarily been to facilitate trade through appropriate technical specifications, rather than to ensure safety.
- Enforcement is weak, lacking sufficient authority and resources to hold manufacturers to account or take action against them.
- Availability and accessibility of product information is poor. Clear and comprehensive information about construction products is often simply not available.
- Fragmented regulatory landscape. This creates inconsistencies in oversight and enforcement, with multiple organisations involved, and communication, cooperation, and collaborative action often falling short.
But how credible is the rhetoric?
Sustainability: an afterthought that misses a trick
On the sustainability front, our first gripe is that the language is suspiciously vague. The proposals will “explore the concept that construction products should be required to undergo life cycle assessments” – but they make no commitment to do so.
More strategically, however, they are ignoring an open goal–namely, the often closely intertwined relationship between more sustainable products and higher levels of safety.
Many sustainable insulation materials are naturally fire-resistant. Flooring materials, for example, that are made out of natural and sustainable materials will burn cleanly in the case of a fire, releasing no toxic fumes.
LED lighting and other energy-efficient services don’t become dangerously hot (let’s not forget that the Windsor Castle fire was caused by a conventional lamp bulb being placed too close to a curtain!), and fire-resistant materials can also be made from recycled steel and engineered wood.
By glossing over this connection, the Paper completely bypasses a golden opportunity to make safety reform and sustainability reform meet in the middle and mutually support each other.
Regulatory improvement? Who’s assessing it?
One of the greatest shortcomings of the proposals, in our view, is that the responsibility for completing products’ risk assessment will rest with the manufacturers themselves.
Further, there is no current clarity about the circumstances under which official intervention or escalation may become necessary, or if indeed these options have been considered.
It all sounds a bit too much like the manufacturers marking their own homework for our liking – and it doesn’t bode well for the credibility of the reforms in general.
Reforms – country-wide but uncoordinated?
New powers are proposed for the established national regulators like the National Regulator for Construction Products (NRCP) and Building SafetyRegulator (BSR), for example.
However, exactly how these powers will be called on and applied at regional and local level isn’t explained.
There is mention of closer cooperation between agencies with related interests, including Local Authority Trading Standards (LATS), based largely on improved and shared technology platforms.
But we support the view, expressed in the recent Hackitt and Morrell-Day reports, that the absence of a single, authoritative building sciences institution at the top of the chain leaves the process rudderless from the start.
Documented and proven fit for purpose – a complex exercise
The paucity of available and easily accessible information about construction products, including relevant certifications, is a theme the Green Paper is keen to address.
And to its credit, it does this relatively thoroughly. The creation of product information libraries, shared with the national regulators but accessible to industry professionals and the general public alike, for example, makes good sense.
So, as well, does a product passport that details safety standards and supply chain minutiae, and the oversight and auditing of third-party certification companies by the regulators.
Yet the complexity of the challenge may be underestimated. With many products sold into the UK from abroad through online platforms where items can be badged as multiple brands or indeed sold as unbranded or generic merchandise, product information risks becoming more extensive and a great deal denser without an accompanying increase in transparency.
Conclusion: the thinking needs to change
It’s difficult for us not to applaud bold efforts to reform a construction products safety regime that has, along with building control processes, undergone a steep decline over the past three decades or so.
But this is a Green Paper that focuses too much on improving what we do, and not enough on changing what we do. This is why the massive opportunity to favour products that deliver safety, quality, efficiency, performance, and sustainability, all in one, has arguably been overlooked.
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