Richard Catt elaborates on something that could really be a huge change to the way our industry is structured and the administrative cost and burden on contractors and fitters.
Depending on the subject, the individual’s ability, and the complexity of the task, it takes a greater or lesser amount of time to reach a high level of competence. Driving is perhaps a good example where through training you achieve a level of competence to pass a driving test and safely control a vehicle. Beyond which, for most, further experience leads to higher degrees of competence. Be that reacting to different road conditions (snow, ice, poor visibility), heavy traffic and driving in cities, driving different types of vehicles, towing, or driving abroad.
One of the roles of the CFA is to scan the horizon and look for emerging trends including technical, legislative, and regulatory evolution and decide through consultation what input CFA members and the sector needs to have.
As far back as September 2019 and most recently October 2023, in CFJ articles I have spoken about the changes that were happening due to the terrible tragedy at Grenfell. The momentum has continued to grow, and competence is now very much part of the common dialogue and language around change in construction.
In the build-up to consensus, CITB are speaking about it in terms of what they are planning to deliver in the training arena. Within recent work, CFA and a subcommittee of members undertook to update the training standards for flooring. Competence featured for the first time with new content and wording being added.
Driving this chain of thought is a key finding by Dame Judith Hackett that competence in construction (or a lack of it) was a main factor in the many failures identified within her May 2018 report ‘Building a Safer Future’. It was also reflected in the updated Building Safety Act that gained Royal Assent in April 2022. www.gov.uk/guidance/the-building-safety-act
One thing has been clear, government requires the construction industry to respond and modernise. Post Grenfell, twelve working groups were formed through a Competence Steering Group (CSG) and these were tasked with reviewing and driving improvements in competence across the supply chain. Working groups for engineers, fire engineers, assessors, enforcing officers, site supervisors and project managers were formed to name a few. As I write, the Building Safety Regulator (BSR) is expected to announce an extension to the period for experienced Building Inspectors in England to complete their competence assessment, as required under the new building safety regime.
Two working groups that potentially impacted flooring are working group twelve (WG12) for products and working group two (WG2) for installers. For our sector, the output from WG12 landed first in the form of the Code for Construction Products Information (CCPI – www.cpicode.org.uk) which encourages manufacturers to sign up for a voluntary code that defines how they should market their products, where product information is clear, accurate, accessible, up-to-date and unambiguous.
The next to begin to unfold (for flooring) has been the output from WG2 for installers. The direction of travel here is informed by all the inputs mentioned above but also The Building Regulations etc. (Amendment) (England) Regulations 2023 (www.legislation.gov.uk/uksi/2023/911/made).
Here is an extract.
‘PART 2A Dutyholders and competence’ Chapter 3 is the key bit.
Competence: general requirement 11F.
– (1) Any person carrying out any building work or any design work must have— (a) where the person is an individual, the skills, knowledge, experience and behaviours necessary, (b) where the person is not an individual, the organisational capability, to carry out— (i) the building work in accordance with all relevant requirements; (ii) the design work so that the building work to which the design relates, if built, would be in accordance with all relevant requirements.
(2) Any person carrying out any building work as a contractor or any design work as a designer must have— (a) where the person is an individual, the skills, knowledge, experience and behaviours necessary, (b) where the person is not an individual, the organisational capability, to fulfil the duties of a contractor or designer, as the case may be, under these Regulations in relation to the work.
Note the inclusion of competence and references to organisational competence and installer competence.
Driven by CLC, CFA have been invited to contribute to the next phase of work, where the national occupation and training standards I mentioned earlier will again be reviewed. This time the objective will be to create a Competence Framework against which any company involved in floor laying and the fitters themselves can be compared and assessed. We have fed back plans to engage in 2025 as there is work to do in advance including, we feel, some industry consultation.
What does this mean in practice? To be honest it is difficult to say from what we know, and we have asked CLC and the project leaders involved to update us as things develop, acknowledging at the same time that they want us to be part of the journey. One question I am minded to ask; is our sector, in these terms as a finishing trade, part of building work? I pose that question in light of the driver for this is Grenfell where failure and subsequent work have been focussed on high rise, high risk, (HRHR) buildings, products, and installers that ultimately have an impact of fire safety. Cladding being the most highly publicised sector, but this easily extends to things such as fire doors, dry lining, raised access floors, staircases, and balconies. These all have significant impact in a fire scenario and have an obvious connection to fire safety.
This all comes in to focus for decorative flooring when you consider that one possible scenario is that ALL subcontracting trades may in the future have to be able to provide formal accreditations in terms of competence ie:
1. Subcontracting companies (working on HRHR and perhaps others) could have to go through an accreditation process (regularly and independently reviewed) that demonstrates they understand competence and can manage a competent work force.
2. The fitters they employ could also need to have a competency-based accreditation that show they have built on their basic qualifications to add appropriate experience and competence. This could be part of a card scheme like CSCS and could be subject to onsite checks like a CSCS card and regular CPD.
Both requirements could form part of the tender process and be included within PQ requirements for main contractor work. Extensions of this could then move into new build homes, refurbishment, and direct client work in the same way as qualifications and accreditations like CSCS cards inform best practice for qualifications in our sector.
The CFA is only just beginning its work and I would welcome feedback from any quarter as part of our consultation process. This really could be a huge change to the way our industry is structured and the administrative cost and burden on contractors and fitters. So, we need to get it right.
The CFA is a leading trade association representing the Flooring Industry. If you would like an application pack or further information on the benefits of membership, please contact the CFA.
0115 9411126
info@cfa.org.uk
www.cfa.org.uk
