BRE A study into the level of checking of structural design Date: April 2014 A8331628 Report prepared by: Dr Stephen L Garvin, John Reid and Chris Landsburgh BRE Scotland, Orion House, East Kilbride, G75 0RD The opinions expressed in this report are those of the authors. Report commissioned by: Building Standards Division Local Government and Communities Directorate Denholm House Almondvale Business Park Livingston EH54 6GA Tel: Fax: e-mail: web: standards 01506 600 400 01506 600 401 buildingstandards@scotland.gsi.gov.uk www.scotland.gov.uk/Topics/Built-Environment/Building/Building- © Crown Copyright 2014 Applications for reproduction of any part of this publication should be addressed to: BSD, Directorate for the Built Environment, Denholm House, Almondvale Business Park, Livingston, EH54 6GA This report is published electronically to limit the use of paper, but photocopies will be provided on request to Building Standards Division. 2 Contents 1 Executive Summary 4 2 Introduction 6 3 Review of guidance documents 8 4 Survey of verifiers 22 5 Interviews and reviews 34 6 Discussion 67 7 Conclusions 79 Appendix 4.1: Survey response information 81 3 1 Executive Summary The Building Research Establishment (BRE) has been commissioned by the Building Standards Division (BSD) of the Scottish Government to undertake a research project to investigate the level of checking of structural design. The background to the research is that the Building (Scotland) Act 2003 permits the design of building work to be certified by qualified, experienced and reputable building professionals and tradespeople as complying with the building regulations. The objectives of the research are as set out in the introduction to this report. The research has involved the following tasks: A literature review of relevant documents involved in certified and non-certified compliance checking of structural design. A survey of local authorities on their procedures and practices for checking noncertified designs. Interviews and projects reviews with Approved Bodies and verifiers. The following conclusions are made from the research: The SER Scheme for the certification of structural design has been shown to be robust and to set high standards for Approved Bodies and Approved Certifiers of Design. It covers the competence of those within the scheme and sets standards for certification activities. There is flexibility in the scheme operation, which is based upon risk assessment of the complexity of the project and the impact of any failure, with different options for the certification process. The higher risk projects are typically only undertaken by Approved Certifiers of Design, and involve separate designers, checkers and certifiers in accordance with the advice in European Standards. In non-certified work the process is typically controlled by experienced Building Standards Surveyors. Each verifier has their own approach, with only a few having experienced Building Standards Engineers (civil or structural) in the verifier team. All verifiers indicated that they took measures to ensure that competent individuals undertook the structural checking. However, the assessment of competence was by the individual verifier with no evidenced of consistency being presented. There was lack of consistency and indeed transparency in the approach amongst the verifiers to structural checking. The approach typically reflected the resources available to the verifier, with the smaller authorities in particular having 4 less resource of qualified civil or structural engineers to call upon. However, all verifiers interviewed had procedures in place to manage structural checking. The scheme sets a template for consistency in the approach amongst different Approved Bodies and Approved Certifiers of Design. It is clear that over the years a robust approach to auditing the membership has improved standards and consistency between certifiers. Although the Approved Bodies and certifiers found the audit process difficult it had benefits for the membership that were ultimately invaluable. There was no evidence that the end products of certified and non-certified approaches were different. However, there were clear differences in the approaches. The certified approach is more highly regulated by the scheme and there is scope to improve the consistency of the non-certified approach. A number of recommendations have been presented by the research, which are aimed at closing the gap between the approaches. The recommendations are achievable and proportional to the levels of risk involved in structural checking. There is scope to make the non-certified approach more consistent and transparent. At the same time the SER scheme may be able to consider reducing its requirements for lower risk work to encourage certification of this lower value work. 5 2 Introduction The Building Research Establishment (BRE) has been commissioned by the Building Standards Division (BSD) of the Scottish Government to undertake a research project to investigate the level of checking of structural design. The background to the research is that the Building (Scotland) Act 2003 permits the design of building work to be certified by qualified, experienced and reputable building professionals and tradespeople as complying with the building regulations. Certification of Construction is also possible. Certification is an optional procedure for the implementation of building regulations in Scotland and is only relevant to work that requires a building warrant. Certification can only be undertaken by an Approved Certifier of Design or an approved certifier of construction who is registered with an appropriate approved certification scheme. They must also be employed by an Approved Body that has been approved as adopting suitably professional practice to provide a certification service, including quality assurance procedures to check compliance with building regulations. The certification system is operated by the Scottish Government Building Standards Division (BSD). Approved Certifiers are directly responsible for their own certification work but they can also certify work by others, as long as they take appropriate steps to ensure that the work conforms to the building regulations. The use of an approved certifier removes the need for the detailed scrutiny by local authorities. Approved Certifiers of Design are responsible for specified aspects of the design of buildings such as structure or energy standards. If they are satisfied that the proposed design meets the requirements of the building regulations, they may issue a certificate which will be submitted with the building warrant application. The certificate of design is taken as proof of compliance and the verifier does not check the specified areas. Certification schemes are approved by Scottish Ministers. There are currently five certification schemes and seven scheme providers. When a building warrant application is received the verifier carries out a detailed technical check of those aspects of work that are not certified, assessing the application against the relevant standards in the building regulations. The Technical Handbooks and other guidance documents issued by Scottish Ministers assist verifiers to fulfil their duty. If a certificate for the certifiable aspects is not provided, the verifier will need to undertake checks on those. The Scheme for Certification of Design (Building Structures) was established as a result of a joint initiative by the Institution of Structural Engineers (IStructE) and the Institution of Civil Engineers (ICE). The Guide describes the Scheme and its operation and is 6 issued by Structural Engineers Registration Limited (SER), the scheme provider. Information about SER may be found at www.ser-ltd.com. The objectives of the research were as follows: Objective a: Identify the key attributes that support the robustness of the scheme. This should look at the level of competency of the certifier and the level of checking undertaken. Objective b: Identify the key attributes of the verification role undertaken by local authorities when work (that could be certified) is not certified. This should look at the level of competency of the verifier and the level of checking undertaken by them, or by others contracted by the verifier. Objective c: Consider and report on the consistency of the certified approach taken by Approved Certifiers. Objective d: Consider and report on the consistency of the non-certified approach taken by verifiers. Objective e: Consider in terms of the “public interest” whether there is a gap between the robustness of certified (non-verified) structural designs and equivalent non-certified (verified) designs. Objective f: Where gaps are shown to exist, identify ways for certification and verification to be further aligned to improve compliance with the Building Regulations. Objective g: Identify whether any additional levels of certification or verification checking are needed for work covered by the scheme. This report provides the findings of the research and reports progress with regards to the literature review of guidance documents available to those undertaking checking of structural design. It also addresses discussions held with local authorities and the SER Certification scheme. The report provides a number of conclusions and recommendations. 7 3 Review of guidance documents The initial phase in the research has included desk based review of the available guidance documents on the competence and level of checking required to assess compliance. The desk based review has included the following documents: SER Ltd web site, particularly the scheme guide and relevant technical bulletins. Guidance from Scottish Government, Certification Handbook, Procedural Handbook and Technical Handbooks. Guidance from LABBS and SER on compliance checking. Audit reports on the SER scheme and recent audit reports on the local authority verifiers. The desk-based research is relevant to objectives (a) and (b) of the project as set out in the project specification. 3.1 SER Scheme Document The SER Scheme Document details all aspects of the certification of design scheme for structures. It sets out the governance and operation of the scheme as well as the competence and level of checking needed on structural design. In clause 4.2.6 it states that a Certifier must not certify any work that does not comply with the Building Regulations and must not certify any work that has not been checked for compliance with the building regulations. A Certifier issues a certificate, using the prescribed form, to the applicant for building warrant or amendment to warrant who submits the application to the Verifier noting the number of the certificate in an annex to the application. Clause 4.4 covers criteria for membership and therefore the competence of certifiers. Membership is restricted to chartered engineers who are Members or Fellows of IStructE or ICE (i.e. MIStructE, FIStructE, CEng MICE, or CEng FICE). In addition, certifiers must satisfy the following: generally, to have a minimum of five years relevant experience of the design of building structures, gained after award of chartered membership of ICE or IStructE; 8 to agree to adopt appropriate procedures to satisfy themselves of the compliance or non-compliance of design work described in an application for building warrant or amendment to warrant; to declare that they will only certify if they have sufficient knowledge and understanding of the Building (Scotland) Regulations 2004, the Technical Handbooks; relevant codes of practice and design guides; to agree to undertake appropriate CPD and to declare at annual intervals their CPD record; to declare their experience and expertise in specified aspects of structural design of buildings and to take account of this declaration in their certification practice; to undertake to understand the Scheme’s requirements as described in this Scheme Guide; to undertake to abide by the Code of Conduct; to keep a logbook that details all certificates issued together with a record of the basis of decisions on compliance and details of any 3rd party relied on in making decisions on compliance; and to agree to submit evidence of their certification practice to audit by SER on request, including the logbook of certificates issued. Clause 4.6 has a number of items that refer to the level of checking of structural design needed, as well as further competence based issues. Clause 4.6.1 states that the Certifier should be satisfied that their knowledge and experience enables them to discharge the responsibility of certifying a particular design, bearing in mind the type of structure, materials used, complexity or unusual nature of the project. If appropriate, the Certifier should call on other suitably qualified and experienced engineers for advice or to undertake specific checks in order to be satisfied with the design. Clause 4.6.2 requires the certifier to keep a checklist or certification plan for each project certified and to ensure that there is a logbook of all jobs certified. Clause 4.6.3 ensures that the certifier can only rely on certain types of information (e.g. BBA Certificates), not certificates produced by other engineers to relieve them of their certification duties. Clause 4.6.4 refers to the need to take account of other standards during the compliance checking process. However, any structural calculations related to other standards need to be checked by the verifier. 9 Clause 4.6.8 covers the checking process for certifiers, as follows: “The adoption of appropriate levels of checking of designs before they are certified is a fundamental part of the Scheme. It is the Certifier’s responsibility to determine the appropriate checking regime for any particular project. Reference should be made to Technical Bulletin No 2 for the limited range of projects where a Certifier may also be the designer and the checker. Technical Bulletin 2 also provides general guidance on checking.” It is the certifier’s duty to inform the designer of any non-compliance issues (Clause 4.6.9). The certifier should not approve the design until changes are made and compliance is proven. Clause 4.6.19 refers to the completion and that it is the applicants duty overall to ensure that the completed building complies in all respects with building regulations. However, the certifier should ensure that the relevant person has been supplied with any information regarding the design which the certifier regards as necessary to enable a completion certificate to be signed. Clause 4.7 covers the duties of the Approved Body. The Body must allow an environment in which the certifier can carry out the work required to address compliance. The Approved Body should inform the client of the time and cost required to properly address the compliance. The liability of the certifier should be limited by appointing different designers from certifiers. A code of conduct is set out within the scheme guide, which sets requirements for the certifier. It includes the following: 3.2 exercise appropriate skill, care, diligence and judgment in undertaking the certification of Design (Building Structures) with respect to the Building (Scotland) Regulations 2004; undertake only those tasks for which they have appropriate expertise and experience; acknowledge that for some projects they may lack appropriate experience to enable them to act as the Certifier. Technical Bulletins Six technical bulletins have been prepared by SER, all of which provide guidance to certifiers on the level of checking required. Technical Bulletin 2 has been prepared with the following purposes in mind: 10 1. To describe the range of minor projects that an Approved Certifier may certify when he/she has also carried out both the design and the check. 2. To provide guidance on how checking of work that is not covered by 1 above should be undertaken. In situations where the SER design certificate is signed by an Approved Certifier who is also the designer. It is recognised that there will be no independent check of the design and this carries a risk that an error in the design will go undetected. It is therefore restricted to situations where this risk is regarded as being low due to the low occupancy and conventional design of the structures involved. It is the responsibility of the Certifier to determine the appropriate level of checking that should be applied to a particular design with the guidance intended to aid that decision. Guidance on achieving acceptable levels of design reliability is provided within BS EN 1990:2002 Eurocode- Basis of structural design. The SER approach to checking has been guided by the recommendations of this code. Four Design Check Levels have been defined, as follows: DCL1 – Self check: the certifier is also the designer. DCL2 – Simple check: the certifier is not the designer. DCL3 – Intermediate check: more involved check on calculations and designs, certifier is not the designer. DCL4 – Extended check: separate detailed check by someone not involved in the design. It is the responsibility of the Certifier to identify the appropriate level of check to be undertaken for a particular project, or part of a project, and to establish that this check has been undertaken by persons with the appropriate knowledge and experience. In deciding the appropriate level of reliability check for a particular structure the Certifier should take account of the following factors: The complexity of the design The experience of the design team The possible consequences of failure in terms of risk to life, injury, economic loss or environmental impact Public aversion to failure 11 The expense necessary to undertake the check. A key factor in deciding an appropriate Design Check Level is the consequence of failure of the structure. Three risk classes, based on the consequence classification proposed within EN 1990, have been adopted by the SER checking procedure as follows: RC1: Low consequence for loss of human life and economic, social or environmental consequences small or negligible. RC2: Medium consequence for loss of human life, economic, social or environmental consequences considerable RC3: High consequence for loss of human life or economic, social or environmental consequences very great. Technical Bulletins 3, 4, 5 and 6 provide guidance on the certification of individual types of construction. 3.3 SER Guidance Documents There are a range of guidance documents that are provided by SER. In the first guidance document the background to the scheme is explained. The certification system is grounded on the principle that suitably qualified and experienced building professionals can accept responsibility for ensuring compliance with the building regulations, without the need for detailed scrutiny of designs or inspections by local authorities, provided they are employed by reputable firms that operate a system of careful checking. Individual membership of the Scheme is open to a Chartered Civil or Structural Engineer who is a member or fellow of ICE and/or IStructE, who generally has at least five years’ post-chartered experience of the design and construction of building structures, and who can demonstrate knowledge and experience of the Scottish Building Standards system introduced by the Building (Scotland) Regulations 2004. In Guidance Note 2 it is stated that it is imperative that when certifying the compliance of a building, stage or component, the process by which compliance was assessed is recorded in writing and placed on file. The record of the Certifier’s assessment process is subject to audit at any stage after submission of the warrant application. It is, therefore, essential that all such records are placed on file without delay. Assessing compliance is not a retrospective activity and must precede the signing of the certificate. In this context, the design of building structures is assumed to comprise survey and investigation reports, structural calculations (including statements of assumptions), drawings and details (including reinforcement drawings), and the relevant parts of the 12 specification for the works. In the case of alterations to an existing building, survey of the condition of the existing structure and assessment of the effect of the alteration on the stability of the completed building are included. In the case of conversions Approved Certifiers have the responsibility for assessing whether design proposals satisfy the structural requirements. Certification should include scrutiny of design assumptions, calculation methods, drawings, relevant parts of the specification, and other documents as appropriate. Checking must be undertaken of the adequacy and mutual compatibility of all loadbearing elements. Certifiers must also bear in mind of the requirements of the regulations with regard to the durability of materials and their accessibility for maintenance and replacement. The Certifier must take account of procurement practice specific to the project in deciding how to satisfy themselves of compliance with the Building Regulations. For instance, a building structure may include a number of design packages undertaken by different designers. Some of the components may be designed by contractors or subcontractors while others may be undertaken by designers who work for the Approved Body and yet others by specialists in a particular structural form. Irrespective of the source of the design, it is essential that it is independently checked for adequacy and for compliance with the Building Regulations. The Certifier should decide the appropriate level of checking. For the largest buildings and buildings that are structurally more complex or unusual, checking should be more comprehensive and more independent of the designer. The more complex, unusual, or large the structure, the greater is the check level and independence required. Guidance Note 3 deals with options for certification. It builds on the advice given in Technical Bulletin 2. The certifier can choose between a number of options, which may be used in conjunction, for undertaking the certification for a project. Whichever option is chosen, for each aspect of the design, it must be recorded along with the reasons for that choice for future audit. The Guidance Note is intended to explain the intention behind the options offered by the system. The guidance note refers to both certification and checking, which are described as separate activities. Certification cannot be delegated to a third party while design checks can only be undertaken by an individual with the necessary experience in the particular aspect of the check. Appendix A of the note helps the certifier to identify structural elements that may be encountered on a project and the information that will be necessary for the certifier to undertake the task. Five options are given for certification, as follows: 13 Option 1 – certifier is also the designer, but an independent design check is also needed. Option 2 – the certifier is also the checker, but the certifier cannot be the designer. The certifier should be competent in all aspects of the design. Option 3 – the certifier makes an independent assessment, to be used for elements of the building where the certifier has not acted as designer or checker but is sufficiently experienced in the design of such elements to be able to carry out a review of the design and certify on the basis of their own knowledge and experience. This option should also be used where senior members of staff are reviewing work carried out by staff under their control but where detailed design checks have been carried out by others. Option 4 – the certifier relied on competence of an identified third party, is intended to be used where the design of the element in consideration is outwith the competence and experience of the certifier requiring them to rely on the advice of an “external” specialist or expert, or for components covered by independent test certification. Option 5 – the certifier is the designer and has also carried out a self-check of the design. This is only appropriate for minor works. Guidance Note 4 describes three types of certificates of design under the SER Scheme, as follows: New Building Certificate; Alteration, Alteration and Extension or Extension of an Existing Building Certificate; Conversion Certificate. In addition to the certificate(s) the Certifier needs also to consider whether or not Schedule 1 (in relation to contractor designed elements) should be completed and attached to the original certificate which is issued with the Warrant application to the Verifier (currently the local authority). A Schedule 2 (a record of the manner in which the project has been certified) should be completed for both a New Building Certificate and an Alteration and Extension Certificate and kept with the record copy of the certificate. In the case of staged certificates, when schedules 1 or 2 are being completed, the information that the Certifier inputs onto the schedule should only be relevant to that particular stage. Form Q must be submitted to the verifier on completion of the project. 14 Where a Building Warrant application includes work that is outwith the scope of a single certificate (New Building, Alteration and Extension, Conversion), each relevant certificate must be submitted. For example, where alteration and/or extension work is being undertaken in a building which is also subject to conversion, as defined in the Building Regulations at Schedule 2 to Regulation 4, then both an “Alteration and Extension Certificate” and a “Conversion Certificate” must be submitted (Currently under review). Failure to submit the correct certificate(s) and schedule(s) may result in a delay in the Building Warrant application. It is important to check that the description and location of the project are compatible with the Warrant application, certificates can, however, be amended by the SER Administrator. Details of all certificates issued should be entered into the Certifiers logbook and copies of certificates and any associated schedules should be kept by the Approved Certifier for record and future SER audit purposes. Guidance Note 5 concerns a process for reporting failures in certified buildings, this is for use by certifiers and should be sent to SER. Guidance Note 7 covers the requirements for continuing professional development. Guidance Note 8 covers design changes during the design and construction process that could impact on structural safety. The purpose of this Guidance Note is to provide certifiers and their clients with guidance on the risks associated with post certification design changes and to suggest some strategies for managing these risks. The note covers good practice with regards to document control, keeping records, strategies for risk management and amendment to warrant. Guidance Note 9 describes the changes made in 2010 to the building regulations (Section 1), in particular the introduction of the structural Eurocodes. Guidance Note 10 covers the use of the certification mark issued by Scottish Government for Approved Certifiers of Design. 3.4 Audit guidance and reports Guidance has been provided on audit processes and practices. These are audits by SER of scheme members, both Approved Bodies and Certifiers. Guidance on what is expected in terms of certification practices is given, with what constitutes minor (improvement issue) and major non-conformances. An audit feedback report has been prepared for the period of November 2011 to April 2013. The report sets out 12 categories of the audit that need to be addressed for Approved Bodies. It also sets out the 30 items that can be included for certifiers audits. The report sets out the percentage of minor and major non-conformances that were found in all SER audits. Bodies and certifiers are graded in their audits from A (very good) to E (poor). 15 The SER report concludes that it is satisfied that the majority of Approved Certifiers and Approved Bodies are undertaking their roles generally in accordance with the Scheme requirements and that the public can have confidence that the Scheme is delivering appropriate levels of safety. As well as SER carrying out audits of scheme member, the Building Standards Division undertakes audits of SER as a scheme provider. Five audits have been carried out since the scheme started, the latest being in 2013. BSD had recently introduced procedures for conducting targeted audits on the Structural Engineers Registration Limited’s continuous improvement action plan. This was the first audit to be conducted using this method. SER Ltd had published revised audit procedures in November 2011. The main drivers for the revision were to provide additional guidance to Scheme members as to the evidence that is required at audit and to provide greater clarity of timescales for both auditors and auditees. One of the main changes introduced was to allow greater flexibility when a certifier was suspended having received a grade D marking at audit. The grade D marking has now been split into D1 (mentoring) and D2 (suspension). This has been beneficial as those awarded a grade D1 at audit were offered assistance through training and mentoring to improve performance without being suspended from the scheme. Up to the date of the BSD audit, twenty-eight D1 grades had been awarded, of these 17 had submitted updated procedures and have had these accepted and the threat of suspension from the scheme has been lifted. A further four were waiting to get their proposals endorsed. The revised procedures also included the following: Management of certifier activity Management of post certification design changes Maintenance of records Use of Approved Certifier Registration Mark. BSD concluded that SER Ltd has proved to be delivering the scheme to a high standard and continue to endeavour to improve performance. The results of the audit also showed that SER Ltd see education and promotion as important aspects of their work by providing a number of training events for both staff and members of the scheme, and producing more up-to-date guidance material. 16 3.5 Certification Handbook The Certification Handbook covers the requirements of certification schemes, including design and construction, it is not specific to the SER scheme. The purpose of the Certification Handbook is as follows: how the certification system operates how certification schemes are approved and controlled how Approved Certifiers can be directly appointed the role and responsibilities of those involved in the certification process, and the application process for: o a certification scheme o scheme provider status and o direct appointment as an Approved Certifier. In clause 3.2.4 the scheme provider is described as being responsible for the appointment of Approved Certifiers and Approved Bodies for the scheme. Approved Certifiers must have the appropriate qualifications and experience relating to the scope of the scheme and must be employed by an Approved Body. Scheme providers must control the membership application process. The scrutiny of individuals and bodies may be delegated to agents. However, the decision-making control over approvals, audits, and disciplinary procedures must be retained by the scheme provider. Approved Bodies may, when appropriate, subcontract certification work to other Approved Certifier(s) from the same scheme, provided that this is covered by appropriate insurance. Scheme providers must put in place procedures to review membership, at a period specified by the scheme provider and agreed by BSD. The scheme provider must assess the competency of self-employed/sole practitioners who wish membership as an Approved Certifier and Approved Body. Selfemployed/sole practitioners must demonstrate that they have adequate personal liability insurance for both Approved Body and Approved Certifier status. An appropriate code of conduct, complaint, disciplinary and appeal procedures must be devised and adopted as set out in Appendix A ‘Complaints Procedures for Schemes’. Clause 3.3.2 states that in order to gain membership of a certification scheme applicants must demonstrate that they have the appropriate level of competency which is measured by assessing: qualifications 17 experience, and understanding of the role of Approved Certifier of Design to certify that specified aspects of design or construction comply with the Building (Scotland) Regulations 2004. An Approved Certifier of Design is defined in the glossary as follows: “An individual with appropriate qualifications, experience and understanding of the role of Approved Certifier to certify that specified aspects of design comply with the Building (Scotland) Regulations 2004. Approved Certifiers of Design may be approved by a scheme provider under Section 7(2) of the Act or by the Scottish Ministers under Section 7(1) of the Act. They may only issue certificates that are countersigned by the certification co-ordinator of an Approved Body. They must keep a record of all the certificates of design that they issue.” 3.6 Procedural Handbook This handbook explains the procedures set up by the Building (Scotland) Act 2003 and the Building (Procedure) (Scotland) Regulations 2004. The procedures are for building work to which the Scottish building regulations apply and for other matters covered by the Act, in particular those dealing with dangerous and defective buildings. The purpose of the handbook is to clarify the intent of the procedure regulations and expand on the procedures set up by the Act. Unlike the Technical Handbooks and most other guidance documents issued by Scottish Ministers to support the building regulations, this procedural handbook has no specific legal status, but is designed to aid the practical operation of the procedures. The purpose of the building standards system is to protect the public interest. The system is pre-emptive, designed to check that the proposed building work meets the standards. Clause 1.9.1 of the handbook explains that the Act establishes a role for suitably qualified people, businesses or other bodies, when appointed by Scottish Ministers, to certify that certain design or construction work complies with the building regulations. Two roles are designated, Approved Certifiers of Design and Approved Certifiers of Construction, both of which certify compliance with the building regulations, as laid down in the scope of the certification scheme run by the scheme provider. Clause 1.9.2 covers the Approved Certifiers of Design. It states that Approved Certifiers of Design are responsible for specified aspects of the design of buildings such as the structure. If satisfied that the proposed design meets the requirements of the building regulations, an Approved Certifier of Design may issue a certificate for submission with the application for building warrant. Certifiers must have due regard for 18 compliance with the full range of relevant building standards requirements, not just those of immediate relevance to the particular aspect. For instance, design of a central heating and hot water system should take into account requirements for accessibility and for fire separation and acoustic insulation of separating walls and floors as well as those for energy efficiency and hot water storage. As the certificate of design is taken as proof of what it purports to cover, the verifier does not check those matters. A verifier must, however, check that the person signing (the approved certifier) is suitably qualified to issue the certificate of design in relation to the matters certified and that the counter-signing firm (the Approved Body) is approved to co-ordinate the certification of those aspects. These checks are made using the on-line certification register. A table of warrant fees is given in clause 3.14.1 for new build work. The fees range from a minimum of £100 for work with a value up to £5000. The maximum fee example is £4,630 for £1,000,000 of work value. For every additional £100,000 an additional £250 is added. The discount on the warrant fee if a certificate of design is included in the application is 10%. In clause 7.2.9 it is stated that verifiers must accept a certificate of design as conclusive of the facts to which it relates when determining the application for warrant, this does not prevent verifiers, when checking work on site, from reporting failures to build in accordance with the warrant. A verifier could then serve a building warrant enforcement notice. Clause 7.6.2 covers certificates of design, a verifier must accept certificates forming part of an application for warrant as conclusive of the facts to which they relate. If all other matters comply, a warrant must be granted. However, if a verifier considers that a certifier may have committed an offence under section 11(4) of the Act by issuing a false or misleading certificate, the verifier should report the matter to the procurator fiscal service. Scottish Ministers can approve schemes whereby admission of individuals or bodies to the scheme confers approval as an Approved Certifier of Design, subject to limitations imposed by Scottish Ministers. Each scheme is specific to an aspect of design or construction, and may be further limited by designations based on risk assessments or specialisations. Such designations limit the scope of work an approved certifier can cover, for instance with regard to the type of work, the use of the building, the intended occupancy, the area or volume of the building, or the adoption of particular construction techniques or materials. Where the scheme provider is a professional body or trade association, or a subsidiary of such a body, it is not a requirement to take membership of such a body or association, although it is expected that the advantages in the support available to members will encourage membership. 19 3.7 Technical Handbooks There are two Technical Handbooks, one covering domestic buildings and the other non-domestic buildings. The Technical Handbooks have been issued by Scottish Ministers for the purpose of providing practical guidance with respect to the requirements of the provisions of the building regulations under a notice given in accordance with Section 4(2) of the Building (Scotland) Act 2003. Each Handbook has eight sections. Section 0 covers general issues and sets out how and when the regulations apply to buildings and works. The other seven sections are as follows: Section 1 Structure Section 2 Fire Section 3 Environment Section 4 Safety Section 5 Noise Section 6 Energy Section 7 Sustainability. Section 1 of the technical handbooks covers the standards for structural performance of buildings. The intention of the section is to ensure that the structure of a building shall be designed and executed in such a way that, during its intended life, it will not pose a threat to the safety of people in and around the building with an appropriate degree of reliability. To achieve a structure with adequate structural resistance, serviceability and durability the following should be taken into account: the loadings (actions) on the building nature of the ground collapse or deformations stability of the building and other buildings climatic conditions materials structural analysis and 20 details of construction. There are two structural standards within this section, as set out below: Standard 1.1 (Structure): Every building must be designed and constructed in such a way that the loadings that are liable to act on it, taking into account the nature of the ground, will not lead to: the collapse of the whole or part of the building deformations which would make the building unfit for its intended use, unsafe, or cause damage to other parts of the building or to fittings or to installed equipment or impairment of the stability of any part of another building. Standard 1.2 (Disproportionate Collapse): Every building must be designed and constructed in such a way that in the event of damage occurring to any part of the structure of the building the extent of any resultant collapse will not be disproportionate to the original cause. A range of additional guidance documents are referenced as regards disproportionate collapse. These documents are used within the building regulations in England as guidance. Annex 1A covers the structural design standards, so called Eurocodes, referenced within the Section 1. There are also a range of guidance documents such as the small buildings guide that are referenced in the technical handbooks and can be used (but with caution as the document is becoming out of date)to assist in designs that meet the requirements of the regulations. 21 4 Survey of verifiers A survey of verifiers was undertaken in order to gather information on the approach to structural checking across all 32 local authorities. The survey was undertaken on-line using a series of questions. The questions were intended to determine the approach to structural checking across the local authorities as well as related requirements. There were eight questions within the survey, with additional space for verifiers to supply any other information that they considered relevant. A total of 32 respondents completed the survey, however, these were not necessarily all from different local authorities as more than one response may have been sent by a single verifier. Also to ensure non bias opinion of the answers received the survey remained anonymous. 4.1 The survey This section of the report gives a breakdown and summarizes each of the questions and responses contributed from the local authorities. The items included for each question are as follows: The question The responses Discussion of the responses. Please refer to the Appendix 4.1 for details of the survey, the survey participants and the responses for any questions that enabled the participants to expand on questions. Question 1 The question asked was as follows: “Please indicate the guidance that is relevant to you when undertaking compliance checking of structural design to Standards 1.1 and 1.2.” This question required the participant to consider a list of compliance checking guides/documents, and asked them whether they had: a general awareness; they use the guidance sometimes; 22 they use regularly they do not use at all. The guidance documents that were included are as follows: Structural Eurocodes British Standards Small buildings guide Technical Handbooks Industry guidance Other guidance. Responses Of the 32 respondents 31 responded to this question. Table 4.1 summarises the findings. Note that the data entered refers to the number of respondents that completed each box; the rows add up to 100% (but not the columns). Awareness Use Use regularly Do not use Structural Eurocodes 33.3% 33.3% 30.0% 3.3% British Standards 20.0% 13.3% 66.7% 0.0% Small Guide 3.3% 36.7% 60. % 0.0% Technical Handbooks 3.4% 20.7% 75.9% 0.0% Industry guidance 3.3% 30.0% 66.7% 0.0% Other guidance 0.0% 14.3% 57.1% 28.6% Guidance Buildings Table 4.1: Summary of responses to Question 1 23 Discussion Verifiers only check non-certified work for compliance with Standards 1.1 and 1.2, that is typically focussed upon work at the low complexity design end. The use of British Standards and technical handbooks is clear by the verifiers, but equally they are happy to use industry guidance and the small buildings guide. There was less active use of the Eurocodes, indicating their relatively recent introduction and that designers are still working to the older British Standards. BRE asked the participants to detail any “other” methods of checking that they used, nine responses were received. One example given is as follows: “Our response is a collective response from Building Standards and our Property and Technical Service who check structural calculations when they are submitted. Building Standards Officers for example use Structural Eurocodes less than the Structural Engineers in Property and Technical. Likewise the Structural Engineers will generally use the small buildings guide less frequently than a Building Standards Officer” Further information on the types of industry guidance used was not provided in any detail. However, reference to BBA Certificates or BRE Reports was confirmed in the interviews carried out and reported below. Please see Appendix 4.1 for further responses to Question 1. Question 2 The question was as follows: “Please indicate the means of assessing compliance within your authority.” This question required the participant to state their means of assessing compliance within their authority. A list of choices included the following: Structural checking is undertaken in-house by a Building Standards Surveyor. Structural checking is undertaken in-house by a Building Standards Engineer. Structural checking is undertaken by an engineer from another department within your local authority. Structural checking is undertaken by a neighbouring authority under contract or clustering agreement. Structural checking is undertaken by external consultants – who are SER certifiers. 24 Structural checking is undertaken by external consultants – who are not SER certifiers. This question was split into the following areas: Allowing verifiers to choose between: Yes and No, meant that BRE could consider if there were any other means of checking the specialist design methods. The participant was able to split each section down into percentages to share the ‘approximate percentage undertaken by each route’. Responses Of the 32 respondents 26 responded to this question. Table 4.2 summarises the findings. No. of responses Yes No Complexity of projects (in general terms) In house Building Standards Surveyor 28 73.1% 26.9% Low In house Building Standards Engineer 26 25% 75% Medium and High Engineer from other authority department 24 54.5% 45.5% Medium and High Engineer from another authority 24 18.2% 81.8% Medium and High External consultants – SER certifiers 24 5.0% 95.0% Low External consultants – non SER certifiers 22 54.5% 45.5% Medium and High Undertaken in another manner 23 26% 74% Medium and High Table 4.2: Summary of responses to Question 2 25 Discussion Table 4.2 indicates that the majority of the participants do not use ‘external SER certifiers’ and chose to use their own ‘In house Building Standards Surveyor for low complexity works. A minority of the local authorities have Building Standards Engineers. However, the responses demonstrate that are a range of approaches in the local authorities by staff undertaking compliance checks on non-certified work. For the verifiers who undertook structural checking in house using a building standards surveyor these were nearly all in the low complexity category, only one verifier stated that medium complexity was carried out by surveyors. Where building standards engineers were employed by verifiers then they typically undertook low and medium complexity work, although two indicated that they undertook only low and medium work. Where checking was carried out by engineers from another part of the local authority then this was for medium and high complexity work. The same applied when work was carried out by other local authorities or external consultants. Question 3 This question was as follows: “When there is a specialist design element e.g. roof trusses, do you typically take the same approaches.” This question allowed the participants to indicate their approaches for specialist design elements. The responses were similar to those for question 2. Responses Of the 32 respondents 31 responded to this question. The responses were as summarised in table 4.3 Number Yes NO 74.2% 25.8% Table 4.3: Responses to Question 3 Discussion One survey participant stated an extract from their internal procedures manual, which is as follows: “The following is an extract from our internal procedures which covers this point: - 3.1.2. There are two qualifications that apply here: • You should not attempt to make a decision if you are in any doubt, seek advice from other more 26 experienced staff or if the design is complex seek the submission of calculations. In all cases full structural details must be submitted. • Where the design deemed satisfactory but prefabricated roof trusses are proposed, the following is to be sought - A design statement that specifies the loadings used, the standard on which the design is based, and design details together with a structural truss layout. Calculations are generally computer generated and cannot be readily checked without access to the same software package so should not be requested.” Another contributor stated that they would accept the manufacturers certificate for the specialist design element, as follows: “A roof truss certificate can be asked for” or “for a small building I will accept a truss manufactures design certificate” This question proved to have a range of responses from the local authorities. Please see Appendix 4.1 for further response to Question 3. Question 4 The question was as follows: “What level of competence (e.g. qualification and experience) do you require by those undertaking structural checking of design for non-certified work.” Responses Of the 32 respondents 31 responded to this question. Table 4.4 summarises the findings. Building Standards Surveyor Local authority Engineer External Engineer Yes No Yes No Yes No Degree level engineering qualification in relevant discipline 45.5% 54.5% 95.2% 4.8% 88.9% 11.1% Member of an appropriate professional body 62.5% 37.5% 91.3% 8.7% 100.0% 0.0% Technician level engineer 12.5% 87.5% 66.7% 33.3% 16.7% 83.3% 27 Other construction professional 45.5% 54.5% 0.0% 100.0% 16.7% 83.3% Experience of undertaking structural design 45.5% 54.5% 93.8% 6.3% 87.5% 12.5% Other qualifications 60.0% 40.0% 0.0% 100.0% 57.1% 42.9% Table 4.4: Summary of responses to Question 4 Discussion A Building Standards Surveyor should hold a relevant degree in order to undertake structural checking. However it is unclear from the responses whether the degree level engineering qualification (45.5%) was indeed in a structural related field or not. For example, , it is known that building standards degrees do not currently educate students on the structural analysis of buildings. The responses demonstrate that the verifiers expect those undertaking structural design typically to have an appropriate qualification in structures, to be a member of a professional body and to have relevant experience. Question 5 The question was as follows: “When processing a building warrant application with a certified structural design has there ever been any need to raise any comment on the design back to the applicant or certifier.” Responses The responses are summarised in figure 4.1. The question received 25 responses and as a result had a 60/40 (Yes/No) split. 28 Figure 4.1: Response to question 5 Discussion The feedback, for those who selected ‘Yes’, indicated a number of reasons for contact being made with certifiers. “Lack of information in drawings for inspection purposes, Lack of performance specifications and occasional informal clarification of loadings in design. This rarely happens, but on a couple of occasions they were concerned with obvious errors in the structural design specifications. When an engineer has certified a design and issued design drawings for an extension to a property which is known by building standards to conflict with local knowledge of the house construction i.e. specifying concrete lintels in a timber framed building. We are not permitted to question design covered by SER certificate. We do however on occasion have to ask for the submission of additional supporting information to accompany the design certificates.” See Appendix 4.1 for further responses to Question 5. 29 Question 6 The question was as follows: “Can you provide an estimate number of building warrants your authority has processed in the past three years (With SER Certificates).” Responses Of the 32 respondents 22 responded to this question. Table 4.5 shows the yearly difference between the amounts of warrants processed with SER certificates. Respondent number 2010-2011 SER Building Warrants 2011-2012 SER Building Warrants 2012-2013 SER Building Warrants 1 N/A N/A 200 2 825 800 796 3 300 260 300 4 450 376 404 5 460 525 451 6 341 302 273 7 341 302 273 8 31 29 27 9 611 532 516 10 266 392 377 11 N/A 97 161 12 358 299 320 13 31 37 45 14 300 250 200 15 344 308 288 30 16 283 227 234 17 143 120 119 18 508 440 361 19 800 800 800 20 256 196 182 21 4781 4527 4561 22 278 227 248 Totals 11707 11046 11136 Table 4.5: Response to Question 6 Discussion The data received from the verifiers indicates that the number of building warrants that are accompanied by Certificates of Design for structure have remained substantially unchanged over a three year period. Question 7 The question was as follows: “Can you provide an estimate number of building warrants applications with structural design requirements, i.e. where a structural check was necessary, in the past three years – not certified.” Responses Of the 32 respondents 22 responded to this question. Table 4.6 shows the numbers of building warrants processed. 31 Respondent number 2010-2011 Non SER Building Warrants 2011-2012 Non SER Building Warrants 2012-2013 Non SER Building Warrants 1 N/A N/A 140 2 600 600 600 3 250 230 200 4 14 29 23 5 460 525 451 6 Not available Not available Not available 7 1264 1128 1048 8 3238 203 153 9 1400 1250 1150 10 1401 1132 1007 11 15 (estimate) 15 (estimate) 20 (estimate) 12 58 43 37 13 90 110 140 14 15 10 10 15 3 2 5 16 69 70 75 17 No response No response No response 18 No response No response No response 19 800 800 800 20 13 30 28 32 21 1667 1573 1596 22 No response No response No response Totals 11357 7750 7483 Table 4.6: Response to Question 7 Question 8 The question was as follows: “Please add further information below that you think is relevant to structural design checking of non-certified work” Responses This question allowed the participant the option to share their views on the structural design checking process. There were twelve responses from the survey participants. The following list gives some of the responses: “Sometimes gaps in the design calculations in the interaction between new work and existing elements. Marrying of architectural and engineer’s drawings can cause issues on site if contractor is not fully informed. If the main, calculations are found to be correct but we still have a duty to verify. A large percentage of calculations are submitted by private individuals who may not afford the applicant the same protection as the certified route - however, it is likely to be a lower cost for the design.” “There are several customers who will not provide certificates of design but instead provide structural calculations for verification. The authority will have these calculations verified by an external certifier which very often results with the cost for consultation being greater than the (whole) warrant fee received” “Recording systems do not allow for an accurate estimate of questions 6 and 7, but more SER certificates are received than calculations.” Please see Appendix 4.1 for further responses to Question 8. 33 5 Interviews and reviews The research involved carrying out a number of interviews and reviews with verifiers, Approved Bodies and Certifiers of Design. The latter includes Approved Body Coordinators as well as the certifier. The contract requires BRE to interview six verifiers and six certifiers / Approved Bodies. 5.1 Verifiers – interviews and reviews The selection of verifiers was made on the basis of data supplied on building warrants, therefore allowing large, medium and small building standards departments to be involved (two from each category). The selection also sought to include verifiers from cities, mixed towns and rural and more rural locations. A total of six verifiers were interviewed and projects reviewed. The interviews with the verifiers included 12 questions. The questions examined the approach to compliance checking of non-certified work by the verifier and the requirements made with regards to competence and qualifications of individuals undertaking structural checking. The interaction between verifiers and certified work was also examined. The review of projects was undertaken. BRE requested that nine projects be supplied, including three larger, three medium and three smaller. However, it was clear that noncertified work lies mainly in the smaller category (alterations and extensions) with a lesser number of medium projects. Larger projects tend to use SER certificates with only one verifier having three relevant examples. The reviews looked at how noncertified work was assessed and evidence that decisions were recorded and competent professionals were used. 5.2 Certifiers – interviews and reviews A similar approach was taken to the selection of certifiers. SER Ltd assisted BRE by directly contacting their scheme members and requesting that assistance was supplied to BRE. In total five Approved Bodies and Approved Certifiers of Design were interviewed. Each of the interviews included a review of various types of certified projects. The approach to the interviews addressed the issues of competence and procedures undertaken in certification. The project review looked at the process and procedures. It is not a technical review of the work that was carried out, but instead considered the thoroughness of processes. 34 5.3 Findings - verifiers Verifier 1 Interview The verifier had a mix of towns and rural locations within their territory. The approach to structural assessment is to undertake all checking in house by members of the building standards team, i.e. by verifiers. There are two Building Standards Engineers (civil) in the verifier team that are qualified to undertake structural checking, this aspect of the work involves about 50% of their time. The other 50% involves safety of sports grounds, structural surveys of buildings and dangerous buildings. The verifier also carries out some structural checking work for two other local authorities. The verifier has an end-to-end process from building warrant application through to completion certificate. This process is captured within a large flowchart, which includes a specific sub-flow for structural checking, accounting for both certified and non-certified work. There is a master spread-sheet kept by the engineers for all structural checking, this helps to track items such as Form Qs, as well as non-certified works. The verifier also uses the Building Standards ‘Uniform IT System’, which is used commonly by local authorities and will record any certificates of design issued to the verifier. For a specific project there is a checklist that is kept and it is signed off by the person undertaking the structural check. In this authorities area the applicant rarely declares who has provided the structural design and calculations. If a warrant application is submitted without a SER certificate or design and calculations then the verifier will write to the applicant and request that they submit one or other. Once structural design information and calculations are submitted they will be checked. This can take from one hour to several for more complex projects. However, the verifier typically receives non-certified work that is more straightforward alterations and extensions and rarely medium sized projects. Some projects will require a second opinion, but generally the design is checked only by one Building Standards Engineer. All large projects tend to arrive with a certificate of design. For non-certified work there are queries on around 50% of projects by those checking the structural design, however, these vary substantially from minor comments to serious miscalculations. Calculations may be checked ‘by hand’ or using software programmes. If a wrong calculation is found then it is normally included in the ‘points letter’ to the applicant. Corrections to calculations will be required before a building warrant is provided. Other problems that occur when the BS engineers are carrying out checks are that architects drawings often do not match the structural engineer’s drawing. As a result 35 these issues are always queried by the verifier for both certified and non-certified designs. The approach has not changed substantially over the years. Only in the use of computer packages for structural checking, plus better control over project files with improved IT systems. All verifier staff are now in the same office so checking issues has become easier. The verifier does not out-source the structural checking, either within the local authority or to outside consultants. If a project was outside of their expertise then they would do so, but it is not typically necessary. The verifier has not typically found any issues with specialist design elements. To date there has been no requirement to bring in further engineering expertise to check specialist design elements. The engineers undertaking the structural checks are civil engineers, one being chartered and the other a graduate. Both members of staff have been employed by the verifier for many years. The verifier requires a certain level of qualification and experience from anyone undertaking structural checking, but there are no written requirements for this purpose. The verifier requires technical staff to undertake a certain amount of CPD each year, needs are identified in the annual staff performance and development review. Therefore, relevant training is encouraged and both staff have been trained in the Eurocodes. The verifier has not needed to carry out checks on certified designs, but they do need details to carry out reasonable enquiry. If a ‘member of the public’ raised a concern about certified work then they would go back to the SER member first, but under their duty to protect the public might have to take matters further. As yet this has not been required. The verifier did not think that there was any difference between certified and noncertified work within their area. This was a result of the in-house Building Standards Engineers. It is preferable if the verifier has this capability in house in order to maintain standards of checking. The verifier uses a risk based approach for projects based on the current performance framework and associated compliance during construction guidance to support reasonable enquiry. The complexity of the design is taken into account in carrying out the checking. However, in practice both BS engineers can check any level of complexity of design. 36 Projects review A total of nine projects were supplied by the verifier for review. These were predominantly small types of projects involving alterations and extensions. Table 5.1 provides a summary of the findings of the project review. The findings of the review typically were in line with the interviews. All work was undertaken by the in-house Building Standards Engineers, with no requirement for external checking. It was noted that in most cases the applicant did not supply structural design information at the warrant application stage. The verifier therefore requested either the relevant drawings and calculations, or a certificate of design. In most cases the engineer that carried out the design was not identified on drawings or calculations, this was typical for the small works. Unless the designer is also a member of the SER scheme then they will not be able to provide the SER at this stage, as the Certification Handbook states the following: “Clause 3.2.11: The scheme provider must put in place procedures to ensure that Approved Certifiers and Approved Bodies do not certify work which is outside the defined scope of the scheme. In addition, the Scheme Provider must ensure that an Approved Certifier does not certify work what they have not done themselves or supervised on an ongoing basis.” A certificate would only therefore be possible if the original designer was a scheme member. Verifier 2 Interview This is a small local authority, with one large town and otherwise predominantly rural areas. There are no in-house Building Standards Engineers or indeed other engineers in the local authority (including the verifier team) to undertake structural checking. The approach to assessment depends on the experience of the Building Standards Surveyor, with the procedure for checking depending on the complexity of the project. They have a contract with a local firm of structural engineers. Where calculations are supplied by applicants then they will be sent to the firm to be checked. The firm used is a member of the SER scheme. In the past the Building Surveying courses included simple structural design but this has more recently been removed and therefore those who are newly qualified need to pass more of the checking to engineers. The verifier has a new team leader who has reviewed the approach to structural checking by other members of staff and found that these approaches vary. They are 37 currently undertaking a review to standardise this to ensure consistency and encourage learning from one another. The verifier has a flow chart guide for the general verification process and is working towards including the structural verification process within that system guide. They are in the process of employing graduates as new members of staff who will be required to follow the updated process guide. The building standards system is audited to ISO 9001. Where good details are supplied for low complexity structural designs the design can be assessed by experience and the small buildings guide or similar technical guides. If more complex structural designs or specialist design elements are involved (i.e. portal frames etc.) then the calculations will be sent to external engineers for checking. However, structural checking is not routinely outsourced. Senior staff are chartered surveyors with honours degrees in Building Standards surveying. They would undertake or supervise each assessment. All staff are subject to annual reviews of training needs, where needs are identified and courses or CPD are then undertaken. Those undertaking the training are required to cascade the learning back to the team. All surveyors have access to British Standards and other technical documents. Certified designs are not checked further, but site checking that the construction meets the design is required. If a member of the public raised a concern about certified work then it would be investigated. However, this would generally only be where the site work has deviated from the plans. The approach between certified and non-certified work may vary, but the verifier considered that there was not a gap that would affect the safety of buildings. One of the objects of the verifier’s training regime is to clearly identify the in-house capabilities and therefore to find the correct balance between retained assessments and external assessments. Further guidance on the types of projects or levels of risk that do require an external qualified structural engineer was identified as a need. Projects review A total of eight projects were supplied by the verifier for review. These were predominantly small types of projects involving alterations and extensions to domestic properties, although two non-domestic properties were also included. Table 5.2 provides a summary of the findings of the project review. The findings of the review typically are in line with the interviews. Any work with structural calculations was checked by an external consultant, otherwise simple designs were done by experienced Building Standards Surveyors. 38 It was noted that in most cases the applicant did not supply structural design information at the warrant application stage. The verifier therefore requested either the relevant drawings and calculations, or a certificate of design. As noted for Verifier 1 a certificate would only therefore be possible if the original designer was a scheme member. Verifier 3 Interview This was a large city local authority with a substantial number of building warrant applications each year. The verifier referred to previous in-house structures schemes and the self-certification scheme that preceded Certification of Design to demonstrate their experience of structural certification. Previous schemes still required some degree of checking of the design, but since the introduction of Certification of Design no checks are carried out on certified work. Where an application for building warrant is made without certification of the structure then it will be checked by in-house Building Standards Engineers (civil or structural). At present there are two part time engineers employed by the verifier, but a full-time post is being advertised. The engineers must be qualified and have the experience to undertake structural checking. The approach to checking work varies on the complexity of the project. For smaller jobs, e.g. lintels, the checks are straightforward and do not necessarily need calculations. For medium projects more detailed checks on drawings and calculations are needed. For larger projects there are few that do not have a Certificate of Design for structures. In the few instances of larger projects it can lead to issues as the noncertified route requires all design information to be supplied on application. There is no equivalent of the certification Schedule 1/Form Q process. So far the verifier has not had reason to send checks outside of the verifier team. At present there are no framework contracts with SER members or other consultants. If necessary the verifier would use external consultants to check high complexity designs, if this was considered necessary. However, fees can be an issue as the amount may not be enough to cover an external consultant. The building standards system is controlled overall by the use of the ‘Uniform IT system’. There is a system in place in order to control each application, including the role of structural checking of design. The checking of the structural performance is the responsibility of the engineer and there is no further check by other staff. If the engineer is unfamiliar with a design or component then they will seek support from colleagues or undertake research to determine compliance. 39 The engineers use relevant software packages in order to check calculations. The current versions are intuitive and can be readily used. The engineers keep up to date with developments through training and CPD (35 hours per annum). They have access to standards and technical information on line in order to allow them to check compliance against the latest information. The software packages now take account of European Standards as well as British Standards. No checks are done on certified designs, but they need to have all relevant drawings and calculations before the warrant can be signed-off. If a member of the public raised an issue about certified work then the verifier is duty bound to investigate. The verifier recognises that there are differences between the processes involved in certified and non-certified work. The certified route begins during the design stage, allowing the certifier to undertake or monitor changes. The verifier receives noncertified work after the completion of the design process. Issues arise if the design calculations are incorrect, or not enough information is supplied. The verifier considers that there is a need for consistency between all verifiers in their approach to structural checking. However, this should be the same for all standards, not just singling out structural design. Projects review A total of nine projects were supplied by the verifier for review. These were split across the complexity and risk spectrum, with three being high risk projects. Table 5.3 provides a summary of the findings of the project review. The findings of the review typically are in line with the interviews. Any work with structural calculations was checked by in-house engineers in the verifier team. It was noted that in most cases the applicant did not supply structural design information at the warrant application stage. The verifier therefore requested either the relevant drawings and calculations, or a certificate of design. As noted for Verifier 1 a certificate would only therefore be possible if the original designer was a scheme member. There was a substantial difference in the amount of information (drawings, calculations, etc) in larger projects than small projects. The complexity of the project requires much more time to check and will inevitably lead to more issues being raised and resulting correspondence. The higher fee will cover these issues to a certain extent, but errors in calculations or drawings can result in more work for the verifier. 40 The same approach is taken to structural checking for small, medium and large projects. The larger projects may need further levels of checking in a recognised procedure as the level of risk is higher. Verifier 4 Interview This Local authority covers a large geographic area and includes a number of towns and a substantial rural area. There are no in-house Building Standards Engineers (civil or structural) in the authority. The approach taken to structural checking is as follows: No external SER member consultants or engineering firms are used for any structural checking work. Very low risk work goes to the Building Standards Surveyor, but this is minimal due to the type of projects submitted. Low risk projects go to roads engineers in the local authority, which tends to be smaller simple works. Medium and high risk projects, including anything with calculations goes to the roads and bridges (civil and structural) engineers who provide an opinion on compliance. The roads engineers are qualified and members of professional bodies. If the project is beyond their expertise then they will declare this matter and the project will be referred to Building Standards (civil) Engineers in another local authority. There is no direct contact between the engineers and the applicant in most cases. Therefore dealing with queries or requests for more information can be time consuming, possibly coming up against timescales for responses. The use of roads or external engineers (civil or structural) for structural checking is controlled by the Building Standards Surveyor for the project. The engineer will supply a formal memo back to the verifier to record the results of the assessment. In around 60% of cases there are queries raised by the engineers. There was no specific checklist, risk assessment or sign-off sheet used to control the process. The verifier team do risk assess all projects and know many of the applicants and as such can use experience to estimate any likely deficiencies in the design. At the same time the engineers will always check all drawings and calculations. The roads engineers in the authority tend to receive the design to consider first and it will only be sent out to the other authority if it is outside their capability. This was a selfassessment of competence and there was no distinction between civil or structural engineers in this respect. There is a team of four roads (civil and structural) engineers 41 who carry out this work, but the work is arranged through a team leader. The drawings and calculations that are assessed are signed off by the individual engineer. The approach to assess structural design has not changed much since the introduction of the new legislation in 2005. Two years ago they started to use Building Standards Engineers in the other authority as there was a ‘spike’ in more complex non-certified works that could not be addressed by the roads engineers. The verifier uses only suitably qualified and experienced personnel to undertake the structural checking. There is no written description of qualification or experience of those undertaking the checking, but this is not a new area and the needs are well known. The verifier team expects the roads engineers to be carrying out any necessary training or CPD to keep up with developments. The engineers are members of professional organisations who expect a certain level of CPD each year. The verifier has noted that as the SER scheme has developed that certifiers are now more willing to include their drawings to allow site checking. This is in contrast to the early days when it was only the Certificate of Design that was sent with an application. Enough detail is required to undertake reasonable enquiry. There are issues that arise with Form Q, as the authority regularly has to chase for them to be supplied. There is no further checking of structural design by the verifier if it has a Certificate of Design. However, the verifier would investigate any issues raised by a member of the public in relation to certified design. Such issues have been raised in relation to shop fronts and glazed canopies, but it often is a matter of difference of opinion between professionals. The verifier did not consider that there was a gap between certified and non-certified work. However, they are different processes and this has to be recognised by those involved in the building standards system. As certification is not mandatory there is a need to ensure that there are good procedures in place to assess structural designs. On the whole the verifier would prefer to see everything being certified, as this relies on qualified professionals and would reduce costs and time in the system. It was thought that producing guidance on structural checking by verifiers of noncertified work could help to align the two approaches. There is also the need to better connect structural design and the actual construction work, so that reasonable enquiry is straightforward and thorough. Projects review A total of nine projects were supplied by the verifier for review. They were predominantly in the low to medium complexity description, with none of high complexity. Table 5.4 provides a summary of the findings of the project review. 42 The findings of the review typically are in line with the interviews. Any work with structural calculations was checked by roads engineers or the BS engineer in the other authority. It was noted that in most cases the applicant did not supply structural design information at the warrant application stage. Verifier 5 Interview This is a small authority in terms of population and number of building warrants, but a large geographic area. The approach taken to checking structural design depends on the complexity of the project. If the project is of high complexity and the submission is not complete it may be sent back with a suggestion that full calculations or an SER certificate be supplied. Historically the Building Standards Surveyors used to check minor calculations but procedures in place before SER minimised this practice. When SER was introduced some of this ability was lost. The verifier has no in-house Building Standards Engineers. As such the Building Standards Surveyor may request a Certificate of Design with the submission. Where calculations and structural drawings are submitted and they cannot be checked in-house, these will be sent to an external consulting engineer to be checked. The applicant will be informed. The external engineer must be a current member of SER. Therefore, only minor structural works are checked by a suitably experienced Building Standards Surveyor. The surveyor works with a protocol sheet for each project, which outlines the approach to dealing with non-certified applications. This explains the procedure for checking calculations and where deemed appropriate assessing low complexity projects against the latest edition of the small buildings guide. The protocol also permits at the lowest level of risk assessment by the Building Standards Surveyor and if the works are assessed to be of a minor nature, they may take a view on whether the structural works are acceptable or not. There is no significant amount of checking that is carried out in-house by the verifier, as the majority of applications include certification. The few more complex cases that are non-certified go out to SER registered engineers. In general the office would have three different levels of surveyors and different levels of training. At present all are at the highest level for all areas. Therefore all are competent to visually check structural details. New entrants would progress through a training process and be given responsibility to match their experience. 43 The verifier did not consider that there was a significant gap between the two approaches as the majority of projects had structural certification, with mainly low complex building works being submitted directly to the verifier. The move towards high use of structural certification has resulted in de-skilling of the verifier staff, but the system works at present. Projects review Two projects were supplied by the verifier for review, both were domestic projects involving alterations and extensions. Table 5.5 provides a summary of the findings of the project review. In the first project the check was carried out by a subcontracted SER engineer and in the second it was undertaken by an experienced Building Standards Surveyor. Verifier 6 Interview The verifier is part of a city authority, but not with a high number of warrants. The city is divided into areas and each of the senior staff in the building standards section look after specific areas. In some of the areas the majority of buildings are of similar design (i.e. an estate of houses from the same manufacturer). The surveyors therefore become familiar with the characteristics of these specific house types and therefore are aware of the possibilities for alterations. This permits plan checks to be undertaken on some of the properties. Where complications or innovative designs need to be considered, senior staff will be available to assist with the assessment. Engineers from another department are available if required, initially for advice and then where necessary with a formal request and brief for checking the design. The city centre contains a higher proportion of non-domestic and more complex buildings. This area is serviced by the most senior staff, who have the necessary additional experience. Where these surveyors reach the limits of their knowledge the project can be passed to the engineers for checking as required. The other departments used by the verifier (structures and bridges section) had certified quality management systems. The verifier was considering the possibility of obtaining this certification. There are nine engineers (civil and structural) in other departments that support structural design checking. At present four are fully chartered, with the others are working towards this status. Structural checking is not sent outside the local authority. The engineer’s in-house sit adjacent to the building standards group in a large open plan office and would deal with all calculations that require to be checked. The team leader within the structures section is a member of SER and therefore demonstrates competence to undertake structural checking. 44 The verifier stated that they would outsource checking if necessary, this might be where independence of the checking is necessary. The competence required of those undertaking the checking depends on the complexity of the work. There is an initial check to determine the level of experience or qualifications appropriate to the project and then the checking would be handled in accordance with that assessment. The resources available to this verifier show that they are capable of providing a wide range of responses from plan assessments to a full structural calculation checking service. Training is carried out in-house every month. This is undertaken from a variety of sources. Where appropriate, the Building Standards Surveyors will join the engineers to receive joint training in subjects appropriate to both. On other occasions the engineers will give presentations to the Building Standards Surveyors. In addition, some training will be delivered by manufacturers with regard to their own products. There is a training budget but this is supplemented by free training where necessary. Staff are asked to provide feedback on what training is required. If any of the staff attend an external course, then they will provide a summary of the course to the other members of staff. A recent project was reported by the owner of a certified building to have differed from the design. The Building Standards Manager asked all the parties to attend the site to discuss the problem. The issues were identified, the change was shown to be justified and the situation was being resolved. In cases where a member of the public raises concerns over certified work then all relevant parties are asked to meet on site to discuss the issue and plan for resolution. The verifier does not believe that a performance gap exists between certified and noncertified work. The problem exists between the design, which may be approved by some system, and what is finally built. They believe that there is a need for a course leading to an approved certifier of construction for site built buildings. Projects review A total of eight projects were supplied by the verifier for review. The projects were all domestic extensions and alterations, most were considered low complexity with only one larger extension considered medium complexity. Table 5.6 provides a summary of the findings of the project review. Although the verifier has stated that they use a SER member who works for another team they were used in only one of the eight projects. The rationale behind the use of the engineer rather than experienced surveyors was not explained or written down. The majority of the projects were low complexity, but some clearly had structural 45 calculations to consider. It is unclear if these were ‘visually’ checked or software was used to re-check applicant’s calculations. 5.4 Findings – certifiers of design Certifier 1 – Large sized firm Interview This is a large sized multi-disciplinary firm, employing around 10,000 people in the UK and other countries. This firm used to have two SER qualified staff, one in their Edinburgh office and one in their Glasgow office. The Edinburgh office is now closed and therefore they have only one practitioner in Scotland. There is another qualified member of staff in one of the English Offices but they would only be used occasionally. They are currently interviewing for an additional engineer who they wish to be SER members. The firm joined the SER scheme as the process of passing calculations through building standards was slow. The discount on the warrant fee is a small incentive, but the improved warrant approval process is the main driver. Designers within this company are not normally certifiers and therefore the designs are checked by the SER certifier. They have an in-house management system which is used to provide the structure to each project. The system sets up gateways within the project whereby the progress and risks would be assessed and used to direct the following stages. This is designed to ensure a robust and consistent approach to the design of the project, including the certification of design. The approach and gateways are related to the complexity of the project and therefore would first be established at the start of the project and then followed thereafter. The system adopts KPI’s for the reviews and therefore there is on-going assessment of the staff following the system. The risks involved in any project are established at the start of the project. The risks are formally assessed and the gateways established to reflect the agreed risk management actions required. The firm operates an ISO 9001 system and have been audited twice, leading to modifications of the system as potential weaknesses were noted. Certifiers and other staff have full access to on-line technical document resources where the majority of technical guidance is available. The firm has an excellent training policy and system to ensure staff are well trained and up to date. Some of the training is carried out in-house in Scotland, but staff are also sent to courses all over the UK. The currently employed certifier is a degree level qualified civil engineer with chartered status. They were employed by the firm for a number of years before becoming a 46 certifier. The firm would expect any certifier to have at least five years design experience. The firm has no problems with specialist design elements of buildings. This is a large organisation with a significant number of engineers and the spread of experience means that the majority of designs can be handled internally. Any new certifier would follow a personnel system geared to review performance and experience linked with the gateway reviews of projects. If there was a complaint or query raised on certified design the firm would look for an independent check to be carried out. Independent would mean someone in the firm, but not connected with the project. The current checker is in the Chester office for any issue arising in the Glasgow office, and vice versa. If a new SER qualified engineer can be appointed in the Glasgow office then this would be the first port of call. If supplementary checking is required other structurally qualified and experienced inhouse engineers would be involved. The firm had no comment to make on the comparison between certified and noncertified work. However, it was noted that the certified route is a package and provides robust checking. Non-certified work tends to be a ‘looser’ system and therefore quality is not as assured. Projects review A total of nine projects were supplied by the firm for review. The projects were predominantly non-domestic (seven) with two being domestic. They ranged in complexity, with one school being highly complex to a low complexity domestic alteration involving internal walls and ‘slappings’. The approach to certification was within SER guidance and described as Option 3, i.e. the certifier makes an independent assessment, to be used for elements of the building where the certifier has not acted as designer or checker but is sufficiently experienced in the design of such elements to be able to carry out a review of the design and certify on the basis of the certifiers own knowledge and experience. SER describe this option as being used where senior members of staff are reviewing work carried out by staff under their control but where detailed design checks have been carried out by others. The same approach is used no matter the risk class of the project or its complexity. Certifier 2 – Medium sized firm Interview This firm is a medium sized engineering consultancy. They currently have one SER Approved Certifier of Design, the other certifier left in January 2014. They are currently advertising for a new member of staff qualified for SER certification. 47 They have full professional indemnity cover for the certification projects. They operate a quality control system modelled on ISO 9001 but it has not taken through to full certification and auditing. The firm uses the SER audit procedures as a means to control certification of design procedures. They regard SER as more appropriate to the work they are carrying out than not going through certification. They joined the SER system due to senior partner belief in quality, checking of processes and the guidance of the Institution of Structural Engineers. The approach to certification for the firm is that there are several qualified engineers capable of structural designs and independent checking of calculations. Generally projects are designed, checked and certified by experienced chartered engineers One of the chartered engineers carries the responsibility to review changes to building standards and technical standards and inform the rest of the staff of these changes. They are affiliated to BSI and the BSI update magazine provides notification of changes. The certifier is a degree level qualified structural engineer with chartered status. Any new certifier would be expected to achieve such a standard. The standard approach to projects is designed to cope with complex designs and therefore this is the starting point for all projects and simplifications will occur as the project requires. The firm does not subcontract either design or certification works. The in-house expertise exists to certify all building types no matter the complexity. The firm indicated that they have had difficulty in obtaining design information on large glazing projects from suppliers. However, they would always check the design information provided for specialist elements, including the designer, checker and certifier. The firm provides certifiers with the opportunity to do appropriate CPD and training. Courses are held locally, organised by the IStructE. The firm did not give an opinion on whether or not there were differences between certified and non-certified structural design. However, they did think that compulsory certification of design where it exists would be beneficial. Projects review A total of nine projects were supplied by the firm for review. The projects were predominantly domestic (six) with three being non-domestic. They ranged in complexity, with a change of use conversion and a new build care home being highly complex projects. 48 The approach to certification was within SER guidance and described as Option 3, i.e. the certifier makes an independent assessment, to be used for elements of the building where the certifier has not acted as designer or checker but is sufficiently experienced in the design of such elements to be able to carry out a review of the design and certify on the basis of the certifiers own knowledge and experience. The same approach is used no matter the risk class of the project or its complexity. The firm has only one certifier at present, gives a degree of vulnerability should they leave the firm. As yet there was no experience of being without a certifier, but procedures should be put into place to manage such an event. Certifier 3 – Medium sized firm Interview This medium sized practice has 15 chartered engineers, only one without chartered status. This engineer is close to applying to be chartered and therefore is reasonably experienced. All other engineers have been chartered for a minimum of five years. The engineers have access to the Technical Index’s website which provides a wide resource of technical support documents able to supplement the Technical Handbooks on the Scottish Government website. There is a robust training system with opportunities for the engineers to follow webinar training, presentations from manufacturers and attend lectures at Stirling University geared to CPD for engineers. Consideration is given to suggestions from the engineers of where the current training could be supplemented. This practice operates from two offices in the central belt and both offices are set up for SER certification independently with an engineer in both offices named as the approved person/body. There are two certifiers in one office and five in the other office. The designer and checker are generally two separate engineers and for projects from medium complexity and above the certifier would provide a second check on the project. The company is capable of bidding for and designing for a wide range of projects and is well resourced to permit this to occur efficiently. Each project is assessed at the briefing stage and the approach is then determined to match the level of complexity and this then becomes part of the quality system checks to be applied throughout the design and construction. Since the QA system is based on the SER guidance, each step mirrors the general approach to certification. The match between the two systems makes it easy to ensure the SER recommendations are followed accurately. Any indications of problems with a particular project would be re-checked initially on the drawings once reasonable information had been obtained. The review would escalate 49 as required to ensure either that the problem was not significant or that it required attention and would be followed through to a safe and competent conclusion. SER would also be informed if the notified problem required attention. Projects review Three projects were presented for assessment covering low, medium and high complexity. The low complexity project was a domestic extension where the design was checked and certified by the same engineer but not by the original designer. The medium complexity projects was designed by one engineer, checked by another and certified by a third. The high complexity project was designed by two engineers, these calculations were checked and certified by a third engineer and signed off also by the Certifier who is named as the Approved Body. Certifier 4 – Sole Practitioner Interview This sole practitioner is a self-employed certifier, but also acts as an associate certifier on behalf of a medium sized firm. The certifier joined the scheme as a sole practitioner from its early days. On the SER scheme the certifier is registered as an Approved Certifier of Design and as a firm (Approved Body), allowing him to sign Parts A and B of the certificate. The certifier previously worked with the self-certification scheme for structural checking under the previous legislation. The certifier is typically the designer and certifier for the range of projects undertake. This is the Design Check Level 1 in accordance with SER guidance. The majority of certified work is in Risk Class 1, but the certifier has assessed others designers structural design. If it is a larger project then the certifier would most likely refer it to another Approved Body. A risk assessment is made for each project, which is based on the SER guidance. However, most of the sole practitioner work is RC1. The risk assessment is recorded if it is a SER job. If it is non-certified then there is no identification of the risk. The main types of work are domestic alterations and extensions as well as agricultural buildings. The work in this area is increasing mostly agricultural sheds and slurry pits. The certifier would only certify work that is within the scope of the Technical Standards (1.1 and 1.2). There are now more requirements to check on fire protection, which has been introduced into standard 1.2. 50 In terms of the use of the guidance the technical standards only have a few pages, but they refer to British and European standards. The standards are the guiding documents that are used in determining compliance. The certifier previously used the small buildings guide. There are details on the Scottish Government website for thermal insulation and these can be used to check the interaction of insulation and structure. As yet the certifier was not using the Eurocodes on a regular basis, although relevant training has been completed. The certifier would still use BS6399 for wind and snow load; normally this is done through software calculations. In the case of agricultural buildings which do not have Eurocodes as yet, the certifier would then use British Standards for such work. In terms of qualifications, the certifier is a degree qualified engineer and charted member of the IStructE. There is a certain amount of training mandatory under the scheme and through IStructE. The certifier would only subcontract out the certification if it was a larger and more complex project. Examples would be due to a more complicated timber frame structure. The certifier has also been subcontracted by other Sole Practitioners as well. For specialist design elements a performance specification is needed. For example for specialist piling the engineer or the certifier prepares the performance specification and then the contractor would undertake the design. This is normally under the Form Q system, which can be difficult to close off. The certifier stated that the process of obtaining information on specialist design elements can be tortuous. The certifier uses staged warrants, especially for timber frame projects. The certifier uses the IHS system to access the most up to date standards and guidance. The certifier also receives updates from IStructE, and undertakes their CPD courses. There are not courses typically locally, so would need to travel to the central belt from the south of Scotland. The certifier has to meet the SER requirements for CPD each year, 20 hours. There is a log on the SER website to keep track of CPD carried out. It is possible to include self-learning and use of webinars. As a sole practitioner it is difficult to do a full QA system. The certifier considers that the SER audit process can be difficult as it is time consuming and costly, whilst diverting effort from fee paying work. However, it has value and ensures that good practice is followed in the certification activity. If there was an issue raised by a member of the public or verifier then the certifier would obtain some peer review, for example involving another engineer to recheck a design. Certified designs are accepted by the verifier in all cases. Verifiers are reluctant to get involved as it has been covered by the certifier. 51 For non-certified work there can be queries, mostly on drawing and calculation differences. The certifier noted that certified and non-certified work can be at the opposite end of the complexity spectrum. In particular non-certified work may not identify the designer, but in the SER scheme it has to do so. The value of aligning the approaches needs to be assessed. The certifier noted that 80% of work is non-certified with only 20% certified, this is mainly cost driven. The certifier was of the opinion that SER should streamline their paperwork for smaller projects. At present all complexities of projects need the same approach to recording information, which the certifier considered was not a proportionate approach. The certifier is of the opinion that there is a gap between certified and non-certified work, SER is a difficult but transparent system. However, the certifier did not consider the verifier processes to be as transparent for non-certified work. The certifier considers that all verifiers should promote certification of design, some do, but it is not consistent. The SER scheme offers better procedures for high risk works. Efforts should be made to align the approaches, movement of the non-certified approach upwards, whilst making SER more flexible to better undertake lower risk work. Projects review Three projects were supplied by the sole practitioner for review. The projects were all domestic projects, two involved new build (one and two houses respectively) and an attic conversion. The certifier was the designer in all cases. The engineer receives the design drawings from the architect and then provides additions to the design and undertakes calculations. Information on timber frame design is typically given by the supplier, it is then checked by the certifier for compliance. Timber frame design is often dealt with through a Schedule 1/Form Q approach, but if the information is available in time then it will be assessed before the warrant application. Certifier 5 – Sole Practitioner Interview This sole practitioner has been a member of the SER scheme since it began in 2005. The certifier is also a certifier within the similar SER scheme for Jersey. The certifier had previously been involved in the self-certification of structural design in the building standards system prior to 2005. As a sole practitioner the certifier does not certify other designers structural design work. On the SER scheme the certifier is registered as an 52 Approved Certifier of Design and as a firm (Approved Body), allowing him to sign Parts A and B of the certificate. As a sole practitioner the certifier acts as both the designer and certifier. This is in accordance with Option 5 of the SER guidance, or Design Check Level 1. In some instances it can be considered as Option 4, if there is a specialist design element. The certifier normally works with only three architects, who are aware of the requirements for structural design and will understand the certification process. As part of the structural design the certifier will check what the architect has drawn and specified, and then add notes and information in accordance with the guidance. This might be sufficient for a simple low complexity project, but design calculations or further drawings might be required for more complex works. The certifier will use Schedule 1/Form Q when required. However, the clients are often unaware of the certification procedures and are unwilling to pay for post-application design work. He uses both British Standards and European for design and certification purposes. At present most designers still use British Standards as these are still fit for purpose. For example, the use of BS6399-2 for wind loads is typically slightly less onerous than EN1991 but the BS is still fit for purpose. However, in the future these standards will become less applicable and all designers will need to move to the Eurocodes. The certifier uses software for design purposes. The certifier will then use hand calculations and comparison against standards as a means to check during the certification process. SER requires at least 20 hours of CPD per annum. This is undertaken by attending events or carrying out self-learning. The certifier is located in a remote rural area and the opportunity to attend events is few, with visits to the central belt expensive. The certifier attends SER conferences to keep up to date. Any changes to Technical Standards are monitored through regular reference to the Scottish Government website. By assessing compliance using British and then European Standards it can keep the certifier vigilant to any errors. The certifier will assess the risk in each project using the SER guidance. The certifier typically covers only Risk Class 1 projects, but has occasionally undertaken Risk Class 2A work. Projects where there is a risk of disproportionate collapse is one of the highest risks, guidance is given in standards and from the IStructE on this matter. In order to manage risk the certifier will typically keep with RC1 projects. The certifier has three parts to each file, as follows: Part 1 – certification scope and checklist related, ticks and sign off of the various items that are needed – checklist is as per the Scottish Government, procedural guidance for certification (see website – also applies to Energy schemes – need 53 to include in literature review). This checklist approach takes account of SER requirements, covers all issues by those considered as major or minor nonconformities, or items for improvement. Part 2 – approval stamped (by certifier) drawings. Part 3 – calculations, checks and other information. This is used as a control system and to assist risk management. The certifier has had 40 years design experience in structures, the certifier is a chartered member of the ICE and has higher degree level qualifications (PhD). The certifier provides builders or ground contractor with a template report to provide ground investigation reports. This normally includes trial pits for the site. The certifier does not routinely supervise this work, but will use the report provided as part of the compliance check. The certifier requires the person carrying out the supervision to be appropriately qualified. For specialist design elements, e.g. a pre-manufactured roof, then it needs a performance specification to the plans. This is put on a Schedule 1, which then needs a Form Q on completion. Form Q needs calculations from manufacturer to allow its completion, the certifier then needs to assess the calculations and drawings. Checks on calculations are normally carried out using software to determine if it is adequate or not, however it is often possible to determine from experience. The performance specification needs to be on the building plans at the warrant application. Any manufactured product would need to be supported by BBA Certification, TRADA or similar. The certifier will check if there are conflicts with fire protection, steel beams need to be protected in an appropriate way, this needs to be stated on plans. If the architects’ drawing has inadequate fire protection, then they will not certify, even if this means a loss of business. Most of the certification is completed before warrant submission, but the certifier needs to ensure that the scheme is met as far as the SER audit is needed and there can be conflicts in this approach. The certifier stated that work can be lost as it costs to do it properly. Clients don’t want to pay for site investigations to determine ground conditions and other necessary checks, but the SER scheme requires such things. This is not helped by the lack of education about certification amongst clients, architects and others. For some projects the SER scheme is simply too costly for clients. 54 As yet no complaints have been raised about certified designs. There can be queries from the verifier where the construction does not seem to match the design, but this is normally resolved quite readily. If a change is made the client should inform the certifier and it can be dealt with readily, but it does not always happen. The certifier considers that there is a substantial gap between certified and non-certified compliance checking. The certifier does not see evidence for good control over structural checking in local authorities or that drawings and calculations are properly checked. In some cases verifiers do not understand Form Q and the certifier has known some to accept calculations later in the process rather than insist on the Form Q from the certifier. However, the certifier considers that it is more important to ensure that the compliant design is actually built as this is the biggest area of risk. SER, verifiers and the Scottish Government have a responsibility to raise awareness of certification of design and to promote it above all other forms of compliance certificates that can be produced in design and construction. Local authorities should be required to educate the public in accordance with the Building (Scotland) Act 2003. Projects review A total of ten projects were supplied by the sole practitioner for review. The projects were mainly domestic projects, involving alterations and extensions, and new build. Two non-domestic projects were also included. The certifier was the designer in all cases. The engineer received the design drawings from the architect and then provided calculations. The design was then checked through software and by hand calculations as well as reference to appropriate standards. 55 Table 5.1: Summary of verifier 1 projects review Category Description and comments Types of projects Of the nine projects there were six that were alterations and extensions to existing house. One was an alteration to a local authority office. Two new builds were included, a domestic bungalow and a cattle shed (note that this check was carried out for another authority). Approach taken to checking In all cases the structural checking was undertaken by in-house Building Standards Engineers (civil). There was evidence that the processes required by the verifier were followed in each case. Evidence competence of The work was undertaken and signed off by the BS engineers. The interview provided information that both staff were qualified engineers with substantial years of experience of structural checking. Completion project files of The project files, checklists, correspondence and forms were completed as required. A number had reached completion certificate stage, but others were still to be completed. All checked drawings are stamped and initialled by the BS engineer. Issues verifier by The issues raised in the majority of projects were that structural information was not supplied on application. The verifier sought either the drawings and calculations, or a certificate of design. The initial noting of missing information is done by a BS surveyor, only when the information is supplied does it get transferred to the engineer. raised Any involvement from other parties Only the BS engineer has been involved in the structural checking. Other comments There was no documentary evidence that any sample second checks were carried out on these projects. However, in the interview this was noted as a possibility. If a second check is carried out then it would be useful to record this in the project file. 56 Table 5.2: Summary of verifier 2 projects review Category Description and comments Types of projects There were eight projects supplied by the verifier, six of these were domestic alterations and extensions and two were non-domestic properties. One large steel frame shed was included as a new build. Approach taken to checking There was a mix of projects involved, the simple alterations were assessed by BS surveyors, any with structural calculations were sent to external consultants. The approach was in line with the interview. Evidence competence of The external consultants are SER scheme members and have the capability to undertake the structural checking of design. The smaller works are checked visually by more experienced surveyors. Completion project files of The files were complete as expected, although some of the projects were still in progress and they were not yet finalised. Issues verifier by The issues raised in the majority of projects were that structural information was not supplied on application. The verifier sought either the drawings and calculations, or a certificate of design. The initial noting of missing information is done by a BS surveyor, only when the information is supplied does it get transferred to the engineer. Any involvement from other parties The use of external consultants appears to be common in the projects reviewed. These are SER scheme members and only one firm appears to be used routinely. No other parties were involved in the structural checking. Other comments NA raised 57 Table 5.3: Summary of verifier 3 projects review Category Description and comments Types of projects A total of nine projects were provided by the authority, these included three small, three medium and three large. The projects were all controlled by the verifier’s systems. The different types of projects demonstrated the varying levels of information required in the design, for the larger projects folders full of files were required, whilst for small jobs a single drawing and calculations might be all that is included. One of the more complex projects was a staged warrant, which allows the design to be staged. Approach taken to checking For this verifier all checking was undertaken by in-house BS engineers. There was no involvement from other parties within or outside the verifier. Evidence competence of The members of staff undertaken each of the project checks were qualified engineers with substantial experience. Completion project files of In all cases there were full files of information that was commensurate with the type and size of the project. The drawings were all stamped and initialled when approved. There was a building warrant control sheet that was used to control the project compliance checking. Issues verifier by In most of the projects further information was requested by the verifier, including structural design information. The more complex the project then the longer the list of outstanding items that needed to be addressed. The amount of correspondence with the applicant was also greater for the larger projects, which tended to have more contention between the parties. Any involvement from other parties There was no direct involvement from other parties, other than the verifier and the applicant. Where there was disagreement between the applicant and the verifier this was resolved between the parties rather than using external consultants. Other comments The higher complexity and larger projects had the same process and procedures as the small projects. There were no additional checks made by other engineers or indeed any further risk management actions in terms of compliance. For the staged warrant this is a means by which not all information needs to be supplied in advance to the verifier as the design can be staged. However, the verifier has few staged warrants that are not certified. raised 58 Table 5.4: Summary of verifier 4 projects review Category Description and comments Types of projects The projects were predominantly low complexity and domestic works, these included alterations and extensions. There were two non-domestic buildings of medium complexity. Approach taken to checking The majority of the assessments were undertaken by the roads engineers. In only one case (non-domestic alteration) were the designs sent to another authority. In one (non-domestic) case the project files were incomplete and there was no indication of who has assessed the structure. Evidence competence of The interview has indicated that the roads engineers were all competent engineers, the project files show that the assessment has remained within that team. Completion project files of In most cases the (paper) files were completed. As well as the paper files there were on-line systems that tracked projects (Uniform IT system). This included electronic documents including those submitted or otherwise scanned by the verifier. In one case there was an incomplete file, however, it appeared to be a work in progress. Issues verifier by In a number of applications structural details were not initially supplied. These have been requested. There are minor issues that needed to be addressed such inconsistencies in the drawings and sizes quoted in calculations. Any involvement from other parties The only other party involved was the second local authority who are subcontracted to check a specific structural design. Other comments NA raised 59 Table 5.5: Summary of verifier 5 projects review Category Description and comments Types of projects Two projects were supplied by this verifier. Approach taken to checking In the first project there was a new garage being constructed as well as alterations, which was sent out to an engineer. In the other project a BS surveyor undertook the checks on a project involving alteration and extension. Evidence competence of In the first case the competence was achieved through the use of an external SER member. It was less clear in the second case where the BS surveyor undertook the check. The surveyor was experienced, but would not have had specific structures qualification. Completion project files of The two files were completed as expected. However, the second was still in progress. Issues verifier by In both cases the verifier required further design information, with lists of information being supplied to the applicant. Any involvement from other parties The verifier has used an external structural engineer to undertake the checking of one project. Other comments NA raised 60 Table 5.6: Summary of verifier 6 projects review Category Description and comments Types of projects There were eight projects supplied by the verifier, all were domestic alterations and extensions. They had no non-certified projects that were outside of this type. Approach taken to checking In most cases the checking was carried out by experienced Building Standards Surveyors. One project was checked by the structures and bridges engineer Evidence competence of In the case of the engineer the person involved was a SER member, although working for the Local authority. The remaining projects used experienced personnel, but there was no way to control or record their competence or experience to do the checking. Completion project files of The files were generally completed, although some projects were still in progress. Issues verifier by In five projects the verifier requested further information from the applicant concerning structural design. The level of detail required varying. In three simple cases no further information was requested. Any involvement from other parties The involvement of the authority’s engineers was acknowledged in one project. Otherwise only in-house verifier staff were involved. Other comments NA raised 61 Table 5.7: Summary of certifier 1 projects review Category Description and comments Types of projects The projects undertaken by the firm were mainly non-domestic, therefore seven of these were provided with two being domestic. The complexity varied with most being medium, one was high and two low. Approach taken to certification In all the projects reviewed the process was that a structural engineer undertook the design, a senior chartered engineer undertook a design check and then the certifier reviewed the design for compliance with the regulations. The certifier was involved in each of the projects from an early stage. In all cases a checklist was completed for the certification of the process. Evidence competence of In all cases the same certifier of design was involved, who had the competence to certify all types of projects. The firm has been audited by SER and no issues have been raised as regards the certifiers competence. Completion project files of All project files were complete and as expected, with drawings, specifications and calculations included. One project supplied, the school, was not yet completed, but would be certified on completion of the design. raised by or other None of the projects had any issued raised by the certifier or indeed any other party. The certified design was accepted without further explanation or provision of information. Any involvement from other parties The designer and a checker were involved in all projects. The firm exercises a significant degree of checking and control over their design and certification work, including ISO9001 certification. Other comments The firm, although large, currently retains only one certifier in Scotland, although they are seeking to recruit a further certifier for the office and have a SER member in an English office. Issues verifier parties 62 Table 5.8: Summary of certifier 2 projects review Category Description and comments Types of projects The projects were of varying type and complexity. Six projects were domestic, including new build and extensions. The three non-domestic included alterations, conversion and new build. The degree of complexity varied, three highly complex, four medium and two low. Approach taken to certification The same approach to certification was taken in all projects no matter the complexity. In all cases designed by engineer, check made by engineer and certification by SER engineer. Evidence competence of The certifier was the same in each project and their competence to undertake all complexity of projects was approved by SER. Completion project files of The projects were complete in all cases with drawings, specifications and calculations being available. raised by or other There were no issues raised by verifiers or other parties in any of the projects. The verifier accepted the design, without the need for further information. Any involvement from other parties The designer and a checker were involved in all projects. The firm exercises a significant degree of checking and control over their design and certification work, including a form of QA that is in line with ISO9001. Other comments The firm, although medium in size, currently retains only one certifier in Scotland, although they are seeking to recruit a further certifier for the office. Having only one certifier gives a degree of vulnerability should they leave the firm. Issues verifier parties 63 Table 5.9: Summary of certifier 3 projects review Category Description and comments Types of projects Only three projects were offered for assessment, one of low complexity, a domestic extension, one of medium complexity, a retail store refurbishment and one which was of high complexity, a four storey residential unit for school. . Approach taken to certification The company operates a Quality system modelled on the SER system. They considered this the best way to bring a measure of consistency to the approach to all types of projects. There is still some flexibility within the system for individual engineer’s judgement but the broad approach is determined at an early stage and the project is then designed to conform to the normal checks required by the quality system. Evidence competence of The majority of staff are all highly experienced and competent to run projects without supervision but the Quality system ensures that standard checking occurs to avoid oversights. When new staff are appointed, the interview process is not considered sufficient to fully assess competence and therefore they would be required to work with other engineers until their competence is accepted. Completion project files of The project files for all projects were complete and as expected. Issues verifier parties raised by or other No issues were raised by the verifiers in any of these projects Any involvement from other parties The calculations in each of the files were signed off by a chartered engineer acting as a checker and then signed off by the certifier. Other comments The company has two checkers in the office where the interview occurred and six in another office in Scotland. This provides good cover for illness, holidays and staff changes. 64 Table 5.10: Summary of certifier 4 projects review Category Description and comments Types of projects The certifier undertakes work only on low risk projects (Risk Class 1). The three projects presented were all domestic, although two were new builds. Approach taken to checking The sole practitioners approach was mainly as designer and certifier. This was undertaken within the scope of the SER guidance for low risk projects. Evidence competence of The certifier is a member of SER as well as a chartered structural engineer. The certifier is competent to undertake the low risk projects that are certified. Completion project files of In all cases comprehensive completion of the projects was found. The SER audits have dealt with any deficiencies in this regard. raised by or other The verifiers accepted the certified designs without question. Some discussions as regards information for on-site checking had previously taken place, but this was not common. Any involvement from other parties There was supply of information from suppliers, particularly on timber frame design. This was checked by the certifier in order to determine compliance with the regulations. Other comments NA Issues verifier parties 65 Table 5.11: Summary of certifier 5 projects review Category Description and comments Types of projects The projects were mainly domestic, with a mix of new and alterations and extensions. There were two non-domestic properties, the first a shed construction in steel frame and then an alteration and extension to a hotel. The complexity was low and medium across these projects. Approach taken to checking In all cases the certifier was also the main designer, although some supplier design packages were also involved. The projects typically came from a few architect firms that the engineer regularly worked with. In most cases the full design was completed before building warrant application, but otherwise staged warrants with Schedule 1/ Form Q were used. Evidence competence of As a sole practitioner the certifier was competent to undertake the work at the risk levels. The certifier has substantial design experience and appropriate levels of training. Completion project files of The files were complete. The certifier had developed a filing system that was suited to SER audits. A checklist was used for each project in order to check and control relevant items. raised by or other This tended to be focussed on differences between certified design and the as-built situation. This was often a result of a design change that had not been notified to the certifier. Any involvement from other parties Timber frame or steel frame designs were supplied by manufacturers in a number of projects. These then required to be checked by the certifier through software or hand calculations. Other comments NA Issues verifier parties 66 6 Discussion The scheme for certification of design (building structures) has been operating since 2005 and coincided with the introduction of the legislative requirements of the Building (Scotland) Act 2003. The Act introduced the option to have certification of design as a means to determine compliance with the building regulations. Prior to 2005 there was a self-certification scheme for structural design; this was not supported by legislation in the same way as the current Structural Engineers Registration (SER) scheme, but was administered by the local authorities. Since the introduction of certification of design for structures it has become the predominant way in which compliance checking is carried out. As a result local authorities have tended to lose expertise in structural checking from within the verifier team. The research undertaken here had the aim of better understanding the certified and non-certified routes to compliance. In particular, it was seeking to determine if the approaches were as robust and could withstand scrutiny. This section of the report discusses the findings with reference to the objectives of the research. 6.1 Robustness of the certification approach The objectives set out were as follows: “Identify the key attributes that support the robustness of the scheme. This should look at the level of competency of the certifier and the level of checking undertaken. Consider and report on the consistency of the certified approach taken by Approved Certifiers.” The objectives have been addressed through a review of relevant literature and by undertaking interviews with a range of certifiers. The interviews with Approved Certifiers of Design included sole practitioners, medium sized firms and large multioffice companies. Level of checking The review of SER guidance documents on the running of the scheme have indicated that the approach to certification and the level of checking involved in projects will vary 67 depending on the complexity of the project and the risk involved. Clear guidance is given to certifiers and to certification clients in the guidance. The guidance was based on BS EN 1990:2002 Eurocode- Basis of structural design with four levels, as follows: DCL1 – Self check: the certifier is also the designer. DCL2 – Simple check: the certifier is not the designer. DCL3 – Intermediate check: more involved check on calculations and designs, certifier is not the designer. DCL4 – Extended check: separate detailed check by someone not involved in the design. Three risk classes were also identified, as follows: RC1: Low consequence for loss of human life and economic, social or environmental consequences small or negligible. RC2: Medium consequence for loss of human life, economic, social or environmental consequences considerable. RC3: High consequence for loss of human life or economic, social or environmental consequences very great. DCL1 and DCL2 typically match up with RC1. Whilst DCL3 accords with RC2 or RC3; DCL4 is most likely to be RC3. However, the interviews and reviews of projects demonstrated that DCL1 could be used for RC2 as well as RC1. Sole practitioners were involved in some design work for new housing where they were also the certifier. This tended to involve only one or two house developments rather than sites with dozens of new homes. There was a general perception that certification of design is carried out for more complex projects. However, the interviews demonstrated that Approved Bodies as well as sole practitioners undertook certification of smaller works such as domestic alterations and extensions. The sole practitioners interviewed included such projects as a significant part of their workload. The SER guidance documents and their audit procedures are thorough and well explained. They require Approved Bodies and certifiers to undertake the appropriate levels of checking for their projects and to record all relevant information. A checklist approach is used by scheme members to record that compliance checks have been 68 carried out and completed. The projects reviews indicated that the checklists were substantially completed as required by the scheme. Competence The competence of Approved Certifiers of Design is addressed in SER scheme guidance documents. It is relatively straightforward in that scheme membership is restricted to chartered engineers who are Members or Fellows of IStructE or ICE (i.e. MIStructE, FIStructE, CEng MICE, or CEng FICE). In addition, certifiers must satisfy the following: generally, to have a minimum of five years relevant experience of the design of building structures, gained after award of chartered membership of ICE or IStructE o The interviews found that all certifiers comfortably exceeded this level of prior experience in structural design. It should be noted that as the SER scheme has only relatively recently been introduced that many experienced engineers were available to join the scheme. These engineers were already used to the self-certification of structural design that preceded the SER scheme. In the future as the experienced engineers retire then there is a need to replace them with younger more recently chartered colleagues. The SER scheme will need to ensure that in the future the stated levels of experience are continued. to agree to adopt appropriate procedures to satisfy themselves of the compliance or non-compliance of design work described in an application for building warrant or amendment to warrant; o The interviews and projects reviews indicated that Approved Bodies and certifiers had procedures in place for compliance checking. All sizes of firm had to adopt as robust a level of checking for certification. Although the amount of compliance checking varied substantially by the size and complexity of the project the files still had to be completed to reflect that all relevant design aspects had been checked. to declare that they will only certify if they have sufficient knowledge and understanding of the Building (Scotland) Regulations 2004, the Technical Handbooks; relevant codes of practice and design guides; o The sole practitioners typically restricted their certification work to RC1 or possibly RC2 only. The works were alterations and extensions, as well as the construction of one-off new build houses. The restrictions on the sole practitioners seemed as much to do with the insurance liability as their competence and experience to undertake larger projects. The sole 69 practitioners would refer larger projects to larger Approved Bodies that they knew in their area. to agree to undertake appropriate CPD and to declare at annual intervals their CPD record; o Members of the scheme were able to demonstrate that CPD activities were undertaken, it is a core requirement of the SER scheme. to declare their experience and expertise in specified aspects of structural design of buildings and to take account of this declaration in their certification practice; o The scheme ensures that certifiers do not work outside of their competence, based upon qualifications and experience. The SER audit process ensures that any project undertaken can be audited in order to ensure that the certifier remained within their level of competence. to undertake to understand the Scheme’s requirements as described in this Scheme Guide; o Certifiers interviewed were able to demonstrate good knowledge of the scheme’s workings and its limitations. The membership described a number of examples where clients and others lacked knowledge about certification. In general, the public were not informed about building standards or the role of certification. to undertake to abide by the Code of Conduct; o The interviews demonstrated that members were aware of the code of conduct and understood its importance. to keep a logbook that details all certificates issued together with a record of the basis of decisions on compliance and details of any 3rd party relied on in making decisions on compliance; o The Approved Bodies and Approved Certifiers typically retained a substantial amount of information on file. The projects were controlled by a checklist or a certification plan. Decision making was typically transparent and evidence provided in files to show where third party information was relied upon. to agree to submit evidence of their certification practice to audit by SER on request, including the logbook of certificates issued. 70 o The scheme members were able to show evidence of being audited and to taking action to address deficiencies in their certification practice. The SER audit process has resulted in improved practices across the range of members interviewed. The research has provided evidence to demonstrate that those involved in certification of structural design within the SER scheme have the competence to undertake such work. The scheme provides control over the work undertaken and has measures in place to ensure that certifiers do not work outside of their competence. The 6.2 Robustness of the non-certified approach The research required a review of the non-certified approach, with the following objectives being relevant: “Identify the key attributes of the verification role undertaken by local authorities when work (that could be certified) is not certified. This should look at the level of competency of the verifier and the level of checking undertaken by them, or by others contracted by the verifier. Consider and report on the consistency of the non-certified approach taken by verifiers.” It was immediately clear in the survey, interviews and discussions with representatives of the Building Standards Managers that there was no consistency in the approach to the certification of structural design across the 32 verifiers. The individual verifiers all had procedures in place to deal with structural design checking, but it varied across the verifiers. In recent years a number of factors have meant that the ability for all 32 verifiers to undertake structural design assessments across all types of projects has been impacted. The level of fees available for small works, the introduction of the SER scheme and the economic recession have all impacted on the local authorities and their ability to assess structural design. Only a small number of authorities have Building Standards Engineers (civil and structural), others use engineers (civil and structural) in other departments of the same authorities. However, the use of external consultants or other authorities is essential to delivering the service. Building Standards Surveyors are used by verifiers to undertake structural design checking, but this was found to be almost exclusively in low complexity projects. Where a verifier had Building Standards Engineers then Surveyors were not used for structural checking. The research has confirmed that the non-certified approach is typically only used for low complexity and low risk projects. This was confirmed in the verifier survey and also through the interviews with verifiers and certifiers. Larger buildings with greater complexity are almost exclusively certified using the SER scheme. House-builders and any new build non-domestic properties use the scheme for certification. 71 Where local authorities had ‘in-house’ engineers then they demonstrated their competence and experience to carry out such works. The staff had degree level qualification in civil and/or structural engineer and had years of experience in both preparing designs and in undertaking checking. These staff used software and manual checks on calculations to check designs submitted. Project files were completed and all authorities had systems in place to undertake compliance checking across the range of standards. It was clear that Building Standards Surveyors were less comfortable with undertaking structural design assessments than other parts of the building standards. The main area of concern raised by the reviews was when Building Standards Surveyors were undertaking the structural assessments. This applied to low risk works, such as minor alterations to buildings. At present more experienced surveyors have had training and education in structural performance, however, more recent graduates do not necessarily have such a background. As a result, in the future the ability of surveyors to carry out even the most basic checks on minor works will be uncertain. There was also no evidence presented that Building Standards Surveyors as opposed to engineers undertake appropriate CPD and training on new developments such as changes to Section 1 or the introduction of Eurocodes. In two local authorities interviewed there were Building Standards Engineers employed. These members of staff were able to demonstrate competence and experience in structural design checking, they also kept up to date with new developments. The competence demonstrated in structural design checking of these staff provided a robust approach. However, where verifiers did not have in-house Building Standards Engineers then the robustness of the system was less certain. Although the other authorities typically put measures into place to control the checking process it was often left to the Building Standards Surveyor to decide on what was appropriate. Overall the local authorities lack consistency in the approach to checking compliance of structural design. This means that the overall robustness of the approach is reduced. Although there is no evidence that this has resulted in safety concerns the role of the verifier is substantially impacted and any further erosion in capacity will impact on the public interest. The Building Standards departments demonstrated that they seek to do the verification process overall in a good and efficient manner. However, there is a need to ensure consistency of approach to structural checking across the authorities. The consistency is best addressed by the competence of those undertaking the work and producing appropriate guidance for operation of verification, as opposed to insisting that the same resources are made available in all local authorities. To improve robustness of the approach guidance on risk assessment and the development of a parallel set of risk classes to the SER scheme is necessary. The guidance would then cover the competence of the engineer and checking procedures 72 necessary for different levels of risk. It is also important that the process is transparent and can result in an ‘open source’ of information being supplied to the applicants. Respondents to the surveys and questionnaire indicated that not just the structural design, but all aspects of design must be dealt with using the same level of checking across all authorities. A consistency in the service offered would assist building warrant applicants. The local knowledge of verifiers was also shown to be an essential component. In many of the smaller works no structural design information was supplied with the warrant application. This resulted in an unnecessary and costly chase for information. As a result fees were seen as too limited to undertake all checks required, even on simple works. In addition, many designers were not identified on drawings or calculations of small works. This meant that assessing risk was difficult. 6.3 Gap between certified and non-certified work The relevant objective was as follows: “Consider in terms of the “public interest” whether there is a gap between the robustness of certified (non-verified) structural designs and equivalent noncertified (verified) designs.” The research has demonstrated differences of opinion between verifiers and those involved in the certification of buildings as to whether or not there is a gap between the two approaches. The verifiers consider that although the approach is different and indeed that there is an accepted lack of consistency amongst verifiers that the end product is the same. The Approved Certifiers take a different view and consider that there is much more done in certification and has to be seen to be done. In certification the certifier must be involved at an early stage and may indeed be the designer. The checking process can be carried out as the work progresses, allowing design changes to be made or calculations to be re-run. In non-certified work the verifier does not see the design until it is completed and submitted. This means that all checking of the design is retrospective. The understanding and interaction that certifiers should have with the design team is not the same as the interaction with a verifier. Whilst the research demonstrates the differences and the gap between the two approaches, in terms of the public interest the key issue is that buildings are fit for purpose, including safe to use. Any measures undertaken to align the approaches should be proportional to the scale of the issue. One of the most important aspects should be to ensure that compliance checking, by either route, is proportionate to the work being undertaking, but that the risks are managed going into the future. 73 6.4 Alignment of the approaches The relevant objectives were as follows: “Where gaps are shown to exist, identify ways for certification and verification to be further aligned to improve compliance with the Building Regulations. Identify whether any additional levels of certification or verification checking are needed for work covered by the scheme.” It should not necessarily follow that because there is no known difference in building performance that there is equivalence between the two approaches. It should although be recognised that the two approaches can never be entirely equivalent due to the different starting points for compliance checking. However, there are several aspects in which the approaches can be aligned more closely and these are discussed in this section of the report. Competence The research has demonstrated that the project Building Standards Surveyor is the decision maker with regards to the compliance checking of non-certified designs. The surveyor will undertake checks to assess the type of project and the complexity or risk involved in the structural design. Where there are Building Standards Engineers (structural or civil) then there is not so much a decision to be made as the engineer will always check the design, no matter the type or complexity of the work. If there is no Building Standards Engineer then it is necessary to refer work to other departments, authorities or external consultants. If the surveyor has appropriate experience then they will undertake structural checking themselves. The Building Standards Surveyor typically only checks structural design for low complexity buildings as shown in the survey and interviews. Appropriate guidance on processes for structural checking of design would assist in ensuring consistency of approach amongst the 32 verifiers. The Approved Body or the Approved Certifier of Design makes the decision for certified work on the Design Check Level and the individual competence of the certifier that is required. The guidance on checking and the roles of various parties in different types of projects is clear and appears to be followed. Any scheme member not adhering to the guidance will be found on auditing and corrective actions will be necessary. In order to align the approaches the competence of those checking non-certified structural designs should be controlled by each verifier. This should be on the basis of the risks involved in each project, with the risk classification being adopted from the European Standards and the SER scheme, or a similar classification being developed. 74 The verifier should then have an ‘approved list’ of staff and consultants who could undertake the checking at the different levels of risk. For each ‘compliance checker’ a record should be kept of their qualifications, experience, training and CPD. On an annual basis of small sample of their structural compliance checking work should then be taken for audit. The risk classifications and competence criteria and how to assess this for individuals should be centralised under the control of the Scottish Government or an appropriate organisation working with BSD. Appropriate training should be provided for those involved in compliance checking. The training would be appropriate to the types of projects that they assess for compliance. Resources would therefore need to be provided for this purpose. The training should apply to all local authorities no matter how they manage structural design checking. The verifier should retain the list in the public domain in order to ensure openness and transparency to the public. It should be updated as any changes are made. Guidance In order to support alignment of the approaches it is important that consistency is improved. This guidance should not cover the detail of how to technically check structural designs, but instead it should cover the following: The risk classifications for projects and how to assess risk The competence required for individuals assessing compliance at different risk levels Project checklists for compliance checking of structural design Technical guidance to be referred to by those undertaking compliance checking Flowchart and procedural guidance in order to meet the needs of the service level agreements offered to the public by building standards Auditing of non-certified work on an annual basis Examples of the use of the procedure in compliance checking for different complexity of building. The guidance should be developed and kept up to date by the Scottish Government working in collaboration with the Building Standards Managers at the local authorities. The guidance would be risk management based advice, but would not result in all local authorities having to have the same resource of engineers. It would be combined with 75 the ‘approved list’ of compliance checkers resulting in improved consistency amongst local authorities and greater alignment with the certification approach. Local authorities should be provided with incentive, e.g. additional resources for training and audit management, to adopt the procedures, guidance and ‘approved list’. The discussion above addresses measures to raise the bar on compliance checking of non-certified work. The measures are proportionate and recognise that local authorities have varying degrees of resources at their disposal. It should also be recognised that there are costs involved in the certification approach. In most instances the certifier can recover these costs through professional fees. However, for small building work the clients are often individuals who cannot finance certification fees. It may be possible scope to reduce certification requirements in the SER scheme for very low risk work. This would ensure that the economics to do low value work are more attractive. This could apply perhaps to alterations and extensions of a certain type or upper work value, but not to any new build project. Efficiency may be found by reducing the checklist for small works or limiting the structural checking to a similar level undertaken in local authorities for similar non-certified work. Changes to the scheme scope and approaches would require to be undertaken by SER as the scheme custodian and provider, in association with BSD. The support of the verifiers would also be essential to the success of any such move and the confidence that the scheme would still supply the same level of safety in the public interest. 6.5 Findings The discussion presented above has provided the basis for the findings. The discussion used the evidence from the research to assess the gaps and how the approaches could be better aligned. At the same time the limitations on the two approaches mean that complete alignment is not possible. A number of findings are therefore made with regards to improving the alignment between the two approaches. Guidance The approved list of those undertaking structural checking as well as the associated auditing and training should be supported by guidance for the verifiers on structural checking of design. The guidance would be procedural and process as opposed to technical, it would provide a methodology for risk assessment. The areas covered have been set out above in section 6.3. The guidance should be for use by all local authorities and would be maintained by the Scottish Government working with the Building Standards Managers. Competence of structural compliance checkers After completion of the guidance it is suggested that each verifier should maintain an approved list of those undertaking their structural design checking. The competence of 76 the individuals on the list should reflect the complexity of structural design and the risk involved in the project. It may still be acceptable for those undertaking checks to be experienced Building Standards Surveyors, but they would be required to have prior training or education in structural engineering and to maintain their knowledge and skills. For more complex projects or higher risk projects then those undertaking the structural checking should be suitably qualified engineers (civil or structural) with design experience. The approved list does not mean that all local authorities will need to retain Building Standards Engineers (civil or structural) as it is recognised that for many authorities this would impact on resources. However, the fees structure should be reviewed in order to re-align the certified and non-certified processes. The approved list should be available to the public either in an open source system or on-demand. As well as basic information on those undertaking compliance checking the list should be supported by CVs, training records and a statement of competence related to project complexity and risk that they can address. Training and CPD The approved list of those undertaking structural checking should be supported by appropriate training for the individuals. The training would ensure that surveyors and engineers keep up to date with new standards and are competent in the use of structural software or other tools. The training needs of individuals should be monitored on an annual basis, most likely in association with the recommended audit process set out below. The amount of training and CPD should be proportionate to the level of checking that the individual is carrying out and their prior experience. Auditing The approved list approach should be accompanied by an audit of compliance checking projects on an annual basis. This audit would address all levels of risk as well as include technical and procedural matters. The audit would highlight areas of improvements required. It could also identify any training issues required for those compliance checkers. Alignment of low risk projects The SER scheme describes different levels of risk in projects and gives options for the role of the certifier in projects. Low risk projects fall into the category that the designer is also the certifier. This effectively involves a self-check on the design being necessary. Whilst this is appropriate for low risk projects the scheme processes expect 77 a substantial amount of checking. It is recommended that the SER scheme, Building Standards Managers and BSD investigate the requirements for checking of structural design for low risk and complexity work. 78 7 Conclusions The aim of the research was to address the certified and non-certified approaches to the structural checking of design. Standards 1.1 and 1.2 of the building regulations set the structural performance requirements of buildings in Scotland. These technical standards reference a range of other standards and guidance that can be used in design and structural checking. To date the research did not find evidence that the different approaches result in differences in the ultimate structural performance or safety of the public. However, the two approaches have substantial differences, not least of which is the point in the project that the structural checking is carried out. The following conclusions are made from the research: The SER Scheme for the certification of structural design has been shown to be robust and to set high standards for Approved Bodies and Approved Certifiers of Design. It covers the competence of those within the scheme and sets standards for certification activities. There is flexibility in the scheme operation, which is based upon risk assessment of the complexity of the project and the impact of any failure, with different options for the certification process. The higher risk projects are typically only undertaken by Approved Certifiers of Design, and involve separate designers, checkers and certifiers in accordance with the advice in European Standards. In non-certified work the process is typically controlled by experienced Building Standards Surveyors. Each verifier has their own approach, with only a few having experienced Building Standards Engineers (civil or structural) in the verifier team. All verifiers indicated that they took measures to ensure that competent individuals undertook the structural checking. However, the assessment of competence was by the individual verifier with no evidenced of consistency being presented. There was lack of consistency and indeed transparency in the approach amongst the verifiers to structural checking. The approach typically reflected the resources available to the verifier, with the smaller authorities in particular having less resource of qualified civil or structural engineers to call upon. However, all verifiers interviewed had procedures in place to manage structural checking. The scheme sets a template for consistency in the approach for different Approved Bodies and Approved Certifiers of Design. It is clear that over the years a robust approach to auditing the membership has improved standards 79 and consistency between certifiers. Although the Approved Bodies and certifiers found the audit process difficult it had benefits for the membership that were ultimately invaluable. There was no evidence that the end products of certified and non-certified approaches were different. However, there were clear differences in the approaches. The certified approach is more highly regulated by the scheme and there is scope to improve the consistency of the non-certified approach. A number of findings have been presented by the research, which are aimed at closing the gap between the approaches. The findings are achievable and proportional to the levels of risk involved in structural checking. There is scope to make the non-certified approach more consistent and transparent. At the same time the SER scheme may be able to consider reviewing its requirements for lower risk work to encourage certification of this lower value work. 80 Appendix 4.1: Survey response information Survey participants The 32 Scottish local authorities were surveyed by BRE. The number of authorities responded were 23, which is 71%. The information provided in this appendix are additional comments that were provided on the questions posed in the survey. The comments are provided for information in addition to the summary of response data provided in section 4 of the report. Question 1 - comments Text books. Very little compliance checking done in-house only when done in accordance with the small buildings guide applications or very minor works that can be checked using span tables etc. SER Certification is used regularly; structural calculations are used very in frequently. The checking of significant projects that are not certified is undertaken by our in house structural engineer or on occasion an external SER Engineer so that they would have to answer this. We use the technical handbooks and Small Buildings Guide and other available technical guidance for smaller jobs as required. Local knowledge of the ground conditions. Manufacturers lintel span tables, BBA certificates or similar (for example for conservatory roofs) the answers above are combined. A Building Standards Office may have a general awareness of the requirements of Eurocodes whereas the Structural Engineer in our Property and Technical Service. Certifiers are less likely to use the small Buildings Guide. Our response is a collective response from Building Standards and our Property and Technical Service who check structural calculations when they are submitted. Building Standards Officers for example use Structural Eurocodes less than the Structural Engineers in Property and Technical. Likewise the Structural Engineers will generally use the small buildings guide less frequently than a Building Standards Officer”. We have a subscription to IHS Technical Index. 81 Question 2 - comments SER certifiers would check all but very low complexity work. Please note Building Standards Surveyors will only check structural design for compliance with small buildings structural guide. Any calculations received in support of application are sent to neighbouring authority. For those projects in which structural calculations are required, use is made of SER registered engineers to check and comment on the calculations. For projects that do require design checks, SER certification is used significantly to demonstrate compliance for all complexities of projects, while structural calculations are rarely used and where calculations are used they tend to be for low complexity projects (mainly domestic alterations and extensions). Another manner is SER certification. Applications checked by BS Surveyor include simple calculations and applications which may have no structural input but this is still checked. All applications regardless of scale or complexity receive a structural check which might be as little as a cursory glance, i.e. a cut down of a window to form a door utilising an existing lintel. If structural calculations are provided in support of a building warrant application, regardless of value or complexity, they will be checked by the Structural Engineer in the Local authority’s Property and Technical Service. I found this question quite hard to answer in a definitive manner. For example if structural calculations are submitted to us, regardless of complexity of the project, it is most likely that the calculations will be checked by our in house engineer. Likewise there may be examples whereby the structural design is checked by a professionally qualified Building Standards Officer using a variety of tools such as Small Buildings Guide and other appropriate documents. The vast majority of work carried out by Building Standards is of a domestic nature and does not require the input of a structural engineer and whilst there are some signs of the number of SER certificates submitted falling it is still the most common method of showing compliance. The question has been answered for work that is not covered by a SER Certificate. Building Standards Surveyors will only check simple structural work against the Small Buildings Guide, where works do not meet this guide or are more complicated an SER certificate is asked for. Where calculations are provided they are always checked by the in-house engineer who is SER registered. Where a local authority application has structural work this will always go out to an external consultant who is SER certified. 82 Question 3 - comments No comments were given. Question 4 - comments No comments were given. Question 5 - comments Lack of information on drawings for inspection purposes. Lack of performance specifications. Occasional informal clarification of loadings used in design. Quite often the plans submitted for building warrant do not correspond to those submitted by the structural engineer. Rarely, but has happened on a couple of occasions, both concerned with obvious errors in the structural drawings/specifications .e.g. When an engineer has certified a design and issued design drawings for an extension to a property which is known by building standards to conflict with local knowledge of the house construction i.e. Specifying concrete lintels in a timber framed building. In relation to an application Warrant to redress a design fault as a result of a structural failure (collapse) on a certified project. Same Engineer but insurance claim and investigation by in-house engineers found errors in design, No assurances given that the remainder of the project was not impaired by this error, reported to BSD and SER no action taken. Warrant for replacement certified by SER certificate from same engineer (concern raised to ascertain if design errors had been removed when undertaking the new design to those imbedded in the original. Otherwise all SER submissions are accepted on verification with the register. We are not permitted to question design covered by SER certificate. We do however on occasion have to ask for the submission of additional supporting information to accompany the design certificates. Local knowledge of ground conditions, original building construction, nontraditional housing and when stated assumptions known to be incorrect have been brought to certifying engineers attention. There have been occasions where clarification has been sought on the scope of the work covered by the certificate and instances where poor design coordination has led to confusion e.g. discrepancies between architect and engineer drawings and specification. 83 Work to be covered by Schedule 1 has required clarification. Details required allowing satisfactory check to be carried out on site. Number of certificates to cover all work i.e. new builds, alteration and conversion. Appropriate structural information to allow checks to be carried out on site. Structural details which are inappropriate. Engineers being unaware of the level of information required to be submitted with the building warrant application. What can and cannot be dealt with under Schedule1. Usually requests for additional information to allow for Reasonable Enquiry on site. Because the BW application does not contain any structural drawings to allow a builder to construct the structure. Lack of supporting information to allow verifier to check work on site. Changes in the method of construction employed on site with regard to the abutment of masonry block work in lieu of the toothed in approach specified. Question 6 - comments No comments were given. Question 7 - comments No comments were given. Question 8 - comments Sometimes gaps in the design calculations in the interaction between new work and existing elements. Marrying of architectural and engineer’s drawings can cause issues on site if contractor is not fully informed. In the main, calculations are found to be correct but we still have a duty to verify. A large percentage of calculations are submitted by private individuals who may not afford the applicant the same protection as the certified route - however, it is likely to be a lower cost for the design. Have had several customers who will not provide certificates of design but instead provide structural calculations for verification. Will have these calculations verified by an external certifier which very often results with the cost for consultation being greater than the application fee received. 84 Calculations should be laid out to easily understand where loadings are from. Reference should be made to the relevant parts of British or European Standards. The numbers stated in Q7 relate to specific individual projects but do not account for the number of reassessments by our in-house engineers due to initial errors and or inaccurate design assumptions. As noted in the answers above, for projects in which structural calculations are required, structural checking is carried out by use of consultant engineers (SER registered) to check and comment on the calculations. Please note the figures in answer to 7 above include all amendments which may have little or no structural assessment. Knowledge that snow loadings in Eurocodes are higher than former BS for local area. It is my contention that the levels of checks carried out on non-certified work is commensurate with regards the complexity of the work and the risks involved. Much of the work carried out by verifiers of a small scale domestic nature and poses no significant risk in respect of structural stability. Question 7 only includes instances where calculations have been submitted and does not include checks performed by Building Standards Surveyors where works have fallen within the small buildings guide. Recording systems do not allow for an accurate estimate of questions 6 and 7, but more SER certificates are received than calculations. 85