Avoiding Failure: Product Data Post Grenfell

What follows is an extract of our 2021 publication: Digitisation for construction product manufacturers: a plain language guide.

We republish this following the launch on Friday of the Netflix Documentary Grenfell Uncovered.

Whilst the guide was written almost exactly four years ago it makes an important point about how information was the missing element in the conversation at the time and why it is still so important.

You can download a copy of the plain language guide from which this extract is taken by visiting our publications page.

Avoiding Failure: Product Data Post Grenfell

The Grenfell tragedy shocked everyone and challenged us to think again about how our industry works.

Let’s begin with a story, told two ways.

A data journey, version one

1. A building control officer signed off a building based on reference to approved drawings. They didn’t know a product had changed and had no way of telling there had been an incorrect specification or substitution.
2. The installer worked according to approved drawings but installed a different product. They’d relied on the distributor to supply what was suitable.
3. The distributor supplied an alternative product. They checked for suitability against the contractor’s order and believed it a suitable substitution based on the product’s declared conformance.
4. The contractor tendered for the project and chose materials based on previous experience, conversations with the product’s sales team and distributor prices.
5. The salesperson offered their product alternatives based on design and performance requirements. As far as they were aware, all the products they offered were suitable.
6. The architect used the manufacturer’s website to choose a suitable product and obtained approval for the design based on test certificates and building regulations.
7. The manufacturer’s marketer obtained the test certificate and placed it on the manufacturer’s website. They weren’t to know that the test certificate was out of date, fraudulent or obtained by deception.

Everyone in this story acted with integrity to the best of their ability, but there was still a fire and people still died. So, what was missing?

A data journey, version two

1. The manufacturer’s marketer places secure links to the test records and declarations of performance (DoP) for their products on their website, held on a secure independent third‑party site. All product marketing material links to this source for evidence, while the website also supplies information on compatibility, obsolescence, suitable alternatives and other performance‑related data.
2. The architect chooses a suitable product and obtains approval, checking—and referencing—the independent source in their details.
3. The salesperson wants to change the specification because they have a cheaper alternative. The architect, manufacturer and building‑control officer approve and amend the design, which is recorded.
4. The contractor tenders for the project knowing competitors cannot substitute products without an approved design change, ensuring compatibility and preventing unsafe or inappropriate substitution.
5. The distributor checks the product meets the specification and can offer alternatives with transparent approval back through the chain.
6. The installer is confident the correct product has been supplied, verifies it against the secure record, installs it using the manufacturer’s up‑to‑date instructions and records the installation in the project log before cover‑up.
7. The building control officer signs off the building as before, but this time the product is correct and this can be verified.

All the actors in this second version behave competently and with integrity; the procedure is essentially the same, but the outcome is completely different. Why is that?

Since Grenfell, new legislation and government‑supported initiatives are emerging that seek to prevent similar failures in future. To avoid tragedies like Grenfell, manufacturers—like all other actors in the supply chain—need the following four characteristics: Integrity, Competence, Compliance, Information.

Integrity

The Construction Products Association (CPA) has drafted a Code for Construction Product Information (CCPI), which aims to ensure the integrity of marketing information. A consultation on the code was carried out in Spring 2021 and the CPA intends to launch the CCPI in Q3 of 2021^[i].

Manufacturers will be invited to sign up to the code and declare that all information they provide about a product will be accurate, accessible, up-to-date, clear and unambiguous. The CPA argues this will ensure that users can rely upon this information when making key decisions.

Story one shows that an unsafe building can still be produced even when all actors in the supply chain, including manufacturers, act with integrity.

While a code of conduct is to be welcomed as a declaration of integrity, it cannot of itself ensure safe buildings, and fraudulent misrepresentation cannot be prevented by adherence to such a code.

We published a response to the CCPI consultation, which is available on our website^[ii]. It shares our concerns that the code in its current draft form has confused the market and has the potential to cause harm.^[iii]

When you think about ensuring integrity in your business dealings, you also have to think about data integrity. Data integrity is the maintenance of, and the assurance of, data accuracy and consistency over its entire life-cyle. It is a critical aspect to the design, implementation, and usage of any system that stores, processes, or retrieves data^[iv].

Individual people can act with personal integrity in their work, but they won’t be able to be effective if they are not working with data that also has integrity.

The ideal place to encourage integrity and transparency is your trade association. We talk more about this in the section on how trade associations can help on page 35 of this guide.

Competence

Ensuring competence in construction professionals is a key initiative of the post-Hackitt reforms. A UK cross-industry competence steering group was established in 2018 by the Construction Industry Council (CIC) and has produced two reports: Raising the Bar in August 2019^[v], and Setting the Bar in October 2020^[vi].

The new Building Safety Regulator will include a national suite of competence standards, which are being developed by the British Standards Institution (BSI)^[vii] and arrangements for assessment and governance.

Story one shows that competence isn’t a silver bullet. Competence is irrelevant where there is a lack of integrity. Where there is no clear, guaranteed and unadulterated information to work with, it doesn’t matter how competent you are.

Nevertheless, manufacturers should monitor this emerging requirement for competency. How will it be met? How will it be enforced? Will it be effective? What competency is required to install your products?

Compliance

At the core of the Building Safety Bill is the Building Safety Regulator, who will oversee a rigorous new regulatory regime for the design, construction and occupation of higher-risk buildings^[viii].

The regulator will have three main functions:^[ix]

• To oversee the safety and standard of all buildings.
• To directly assure the safety of higher-risk buildings.
• To improve the competence of people responsible for managing and overseeing building work.

The regulator will have teeth, too. The Bill will create new civil penalties and criminal offenses for breaches, and the regime will have enforcement powers.

In January 2021 the UK Government announced^[x] that alongside the Building Safety Regulator, there will be a Regulator for Construction Products, housed within the Office for Product Safety and Standards. The Government also commissioned an independent review into the current testing regime in April 2021^[xi].

A robust regulatory system is a crucial part of the effective control of safety in buildings. However, it will only be effective if it also relies upon clear, accurate and unambiguous information and professionals’ abilities to implement its requirements.

Information

The importance of information is at the core of the post-Grenfell reforms. One example of this is the concept of the golden thread.

The Explanatory Notes to the Draft Building Safety Bill^[xii], published by the Ministry of Housing Communities and Local Government (MHCLG) on 20 July 2020, defined the golden thread of information as:

“Fire and structural safety building information held digitally to specific standards. These standards will include requirements around robust information management and keeping the information up to date. The golden thread will ensure that those responsible for the building have the required information to manage building safety during and throughout the lifecycle of the building.”

An updated version of the Building Safety Bill was published on 5^th July 2021^[xiii] and on 21 July 2021 the MHCLG Building Regulations Advisory Committee published a Golden Thread Report^[xiv] setting out the definition and principles of the Golden Thread and how digital standards will underpin it. Part 4 of the Golden Thread Definition states:

“4. The golden thread information should be stored as structured digital information. It will be stored, managed, maintained and retained in line with the golden thread principles…The government will specify digital standards which will provide guidance on how the principles can be met.”

The new golden thread – an accurate and up-to-date record of the building data – will be required to be digitally traceable. This means that information about products will have to be digitised and manufacturers will have a legal requirement to comply.

If manufacturers don’t digitise their product information, they won’t be regulatorily compliant. As digitised information becomes a requirement for the golden thread it will also become the standard in construction, including from the early stages of any development.

The key to an effective golden thread is data that’s structured, secure, verifiable and interoperable so that it can survive the process and be accessed with confidence.

How should product data be organised?

• Structured. Organised according to a predefined schema, data becomes machine readable and easy to analyse.
• Secure. Only available to those who are authorised to view it yet available in an emergency.
• Verified. Guaranteed to be accurate by being traced back to the source.
• Interoperable. Able to be transferred accurately between software platforms, such as those used by different actors in the supply chain.
• Dynamic. To be effective some data needs to be dynamic not static, that is regularly updated so that it remains live, accurate and relevant to its users.^[xv]

Structure your data

As the regulatory environment evolves over the coming years, manufacturers can prepare for compliance in a way that not only makes buildings safer, but that’s also more efficient for them to execute.

The integrity of their information is secured to the benefit of not only themselves, but also the whole supply chain. Structured data is at the core of this process. ^[xvi]

Published October 2021.

Footnotes:

[i] Homepage – Building Safely https://web.archive.org/web/20210730225843/https://buildingsafely.co.uk/

[ii] https://communities.theiet.org/blogs/948/7213

[iii] The Code for Construction Product Information (theiet.org) https://www.theiet.org/impact-society/government-policy-and-submissions/submissions-archive/the-code-for-construction-product-information-2021/

[iv] Data Integrity Definition (en.wikipedia.org) https://en.wikipedia.org/wiki/Data_integrity

[v] Raising the Bar – Construction Industry Council – Construction and fire industries set out sweeping proposals (cic.org.uk) https://cic.org.uk/news/article.php?s=2019-08-16-construction-and-fire-industries-set-out-sweeping-proposals

[vi] Setting the Bar – Construction Industry Council – Built environment and fire industries set out blueprint (cic.org.uk) https://cic.org.uk/news/article.php?s=2020-10-05-built-environment-and-fire-industries-set-out-blueprint

[vii] Built Environment Competence Standards | BSI (bsigroup.com) https://www.bsigroup.com/en-GB/industries-and-sectors/construction-and-the-built-environment/built-environment-competence-standards/

[viii] It is worth noting that the scope of ‘higher-risk buildings’ may change. The current definition is set out in the factsheet “Buildings included in the new more stringent regulatory regime” published on 5^th July which confirms that the scope of the new regime could change in the future.
“Guidance: Buildings included in the new more stringent regulatory regime: factsheet” – GOV.UK (www.gov.uk) https://www.gov.uk/government/publications/building-safety-bill-factsheets/buildings-included-in-the-new-more-stringent-regulatory-regime-factsheet#will-the-scope-of-the-regime-change-in-the-future

[ix] Explained: The Draft Building Safety Bill – GOV.UK (www.gov.uk) https://www.gov.uk/government/news/explained-the-draft-building-safety-bill

[x] New regulator established to ensure construction materials are safe – GOV.UK (www.gov.uk) https://www.gov.uk/government/news/new-regulator-established-to-ensure-construction-materials-are-safe

[xi] Independent Review of the Construction Products Testing Regime – GOV.UK (www.gov.uk) https://www.gov.uk/government/groups/independent-review-of-the-construction-products-testing-regime

[xii] Draft Building Safety Bill PART 2.pdf (publishing.service.gov.uk) https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/901869/Draft_Building_Safety_Bill_PART_2.pdf

[xiii] Building Safety Bill, 5 July 2021 – GOV.UK (www.gov.uk) https://www.gov.uk/government/collections/building-safety-bill

[xiv] Building Regulations Advisory Committee: golden thread report – GOV.UK (www.gov.uk) https://www.gov.uk/government/publications/building-regulations-advisory-committee-golden-thread-report

[xv]  Dynamic Data – Wikipedia https://en.wikipedia.org/wiki/Dynamic_data

[xvi] An earlier, more detailed version of this article can be found on the blog: Avoiding Failure: Product Data Post Grenfell – IET Engineering Communities (theiet.org) https://communities.theiet.org/blogs/948/7099