Everybody welcomes certainty – but there is not a lot of it about. And that is nothing to do with the UK’s future relationship with Europe. Last year, CIBSE responded to 29 consultations and Select Committee enquiries, as well as engaging with the Independent Review of Building Regulations and Fire Safety.
A great deal of policy activity in areas relevant to CIBSE members is also under way at the moment, as we move from consultation and debate to implementation on several fronts.
While some of it is specific to England, or even to London, much has wider relevance. Many of the issues are relevant to the devolved administrations, while fire safety, reducing carbon emissions, ‘zero carbon’ buildings and indoor air quality have global resonance.
In England, several parts of the Building Regulations are under review. The Implementation Plan1 issued in December, in response to the Independent Review, committed government to a full technical review of Part B. It proposes possible changes on a number of technical issues, going well beyond the activity to clarify the current Guidance that has been under way for some time.
This process has already started, with a call for evidence2 published in December alongside the Implementation Plan. This is in addition to the changes to Regulation 7, banning combustible materials from external walls of residential buildings more than 18m high, introduced in December.3
The Society of Façade Engineering4 is already busy developing guidance for its members on the detailed implications of the new rules, but it is clear that the design of façades for high-rise residential buildings will have to change.
We need a move towards regulation of real carbon emissions in use, with incentives for those willing to lead the way
Also in the response to the Independent Review is a commitment to update Parts L and F (governing energy use and ventilation respectively). The same paragraph5 commits to a review of Part M (access) to complement work already being done in the wake of a report6 from the Equalities Select Committee on the issue of accessible toilets. It also talks of a workplan for dealing with other technical requirements, such as Part P (electrical safety), ‘in the new year’.
We will not be short of things to do on Building Regulations.
The review of Parts L and F will also address overheating risk. CIBSE has some clear goals for the review: we need a clear trajectory for improving Building Regulations over time so that all new buildings achieve net-zero carbon by 2030, with milestones for interim stages.
The next edition of Part L must drive significant further improvement in the target carbon dioxide emission rate. Beyond that, we need to see a move towards regulation of real carbon emissions in use, with genuine incentives for those who are willing to lead the way in measuring and reporting this.
What would Part L compliance based on actual performance – rather than design intentions, sometimes unfulfilled – look like? This approach would also be more in line with the greater emphasis on whole-life performance of buildings set out in Building a Safer Future.
To help drive innovation and investment, we should allow local authorities to set requirements that are more challenging than the Building Regulations, while remaining realistic.
In relation to Part F, we would like to see a focus on achieving indoor air quality and not just ventilation rates. There are advantages to performance or outcome-based regulations, but they need to define the appropriate outcomes. For too long we have focused on air movement at the expense of air quality.
It is not just Building Regulations that are addressing the quest for clean air; it has been a significant concern in London for some time, especially in relation to particulates from diesel engines.
The Clean Air Strategy, published in January, acknowledges the need to address many of the concerns that CIBSE raised in the consultation last year, but ducks the call to adopt World Health Organization (WHO) limits on pollutant levels. If we don’t listen to the WHO, then who do we listen to? For more on this topic, see page 16.
It is unfortunate that, with heightened awareness of pollution in city centres, schools and offices, we still ignore the problems of pollutants in industrial workplaces. Occupational lung disease is one of three priority areas for improving workplace health. In the UK, around 8,000 people each year develop chronic health problems from exposure to dusts and vapours in the workplace, in spite of health and safety legislation requiring employers to control exposure to pollutants.
The Institute of Local Exhaust Ventilation Engineers (ILEVE7), the CIBSE Division focused on this specialism, works closely with the HSE and wider industry through the LEV Forum to increase awareness of – and compliance with – the relevant legislation, including the recent classification of welding fumes as carcinogenic. All CIBSE members should be aware of the specialist requirements and available expertise in this area of work.
Finally for this round-up, there is the ongoing development of electric vehicles and the need to deliver the infrastructure to support them.
This will have implications for building services, with additional electrical demands needing to be serviced in and around buildings and supported by the distribution network. We can expect a lot more activity in this area and it will involve several government departments.
Cross-departmental coordination always adds to the excitement of emerging policy, so this promises to keep us engaged for a little while longer. In the meantime, there is a significant opportunity for CIBSE members to help shape the built environment in which we live and move for many years to come.
1 Ministry of Housing, Communities and Local Government (MHCLG), Building a safer future: an implementation plan, 18 December 2018 – bit.ly/2HuIYZW
2 MHCLG, Technical Review of Approved Document B of the building regulations: a call for evidence, 18 December 2018 – bit.ly/2HuK2Nq
3 MHCLG, Building (Amendment) Regulations 2018: Circular 02/2018 – bit.ly/2FWwk3s
5 MHCLG, Independent Review of Building Regulations and Fire Safety, 17 May 2018, Paragraph 2.36 – bit.ly/2KKbzXV
6 Women and Equalities Committee, Building for equality: disability and the built environment, ninth report of session 2016/17, 25 April 2017, page 39 onwards – bit.ly/2FKkVVh