30
ROUND TABLE REVIEW
Gateway 2. This was especially useful given the “congested” nature of product data at such interfaces, she said.
Jamie Chubb said that manufacturers of different packages “did have an appetite to engage, but the bit that’s unclear is how they go about that engagement,” in terms of increasing coordination around complex areas of structures. The issue of design responsibility for those elements, as well as who “owns the data,” was also a critical challenge, said the architect. Lastly, Lee Carron, client relations manager at Premcrete homed in on the issues of specifi cation changes, particularly for “critical systems such as waterproofi ng or gas protection.” He asked: “How do we determine whether a change to a specifi ed product or system should be treated as a major change or a notifi able change to an approved submission? Is there a risk that the original design, testing and compliance evidence rigour can be lost in a substitution?” Jamie Chubb responded saying that an “economics and market”- based mechanism to controlling change was unlikely, instead saying that the industry “generally just needs to have an enhanced awareness of unforeseen implications of even well considered change – that might still be a valid change.” He added: “It could be an equal performing product, irrespective of whether it’s cheaper; it might be a supply issue.”
Open data
IT systems were at the core of resolving some of the issues of expediting projects’ passage through the process, but as Jamie Chubb said, the Regulator had some work to do here. “I think they probably need to improve their IT. If we’re going to sit on our side of the fence with rigorous and organised systems, they need to learn from us – we can help them do it.” He added, however, that the currently rather clumsy way of uploading information had to be refi ned: “We need a better way of uploading information in a way that’s easy for them to navigate, rather than just putting it in a single folder and hoping they fi nd 6000 documents easily.”
RECOMMENDATIONS FOR INDUSTRY & GOVERNMENT
• Sara Dawes, Leviat: It would be helpful just to have a bit more positive feedback from the Regulator.
• Mark Batchelor, The Hyde Group: Remember we need to get people into these homes; if we’re just replacing stuff, let’s get on and do it.
• Lee Carron, Premcrete: We need consistency in responses and the guidance – that is coming. And we want to get to the point where culturally this is what happens on all projects, not just HRBs.
• Stewart Kerr, Pennington Choices: It’s about creating a two way collaboration with the regulator and industry, so that both learn at similar paces – it’s about understanding the issues in the regulator that we don’t get to see.
• Michele Pecoraro, P+P Architects: Publish a good example of a BSR application.
• Li Yen Lim, Freeths solicitors: The thought process needs to be captured; why are we doing it this way and why not the other way? It would be good if the Regulator did give some encouragement and some feedback in that sense.
• Jamie Chubb, PRP Architects: I’d like to see the Regulator open up a little bit more to early engagement; and we need to recognise there is a resource issue at the Regulator.
• Louise Flower, MacConvilles: It’s really good to view suppliers as designers. That’s a huge improvement, from a Principal Designer point of view.
• David Atkinson, Metsec: Identify any superfl uous information so we can streamline what everyone’s having to do, and early engagement with expert knowledge, fi nessing details on specifi c project designs.
A more challenging proposition for improving the process, he
said, was to publish all approvals so the industry could learn from them. “I don’t see why we don’t – and if they genuinely recognise there is a difference of opinion on how a regulation is being interpreted by the industry, can we have a bulletin that says so? Not a consultation!”
He said that because “people are clearly getting it wrong,” there was merit to the suggestion of at least publishing some best-in- class approvals,” adding: “I think it’s in everybody’s interest to have transparency on submissions and decisions, not just for improvements in the process. Finally, this transparency should extend, he said, to giving tenants “access to the information that sits behind the safety of their property.”
AVOIDING THE DATA DUMP
Sara Dawes of event co-sponsor Leviat said the company was determined to not ‘data dump’ on the Regulator
Chubb concluded that the industry needed to work together in a spirit of mutual learning, while accepting that everyone was on a learning curve, but that “some of the requirements need to be relaxed.” And, in order to establish best practice, he asserted that we “need to move beyond going back over historical approvals and asking why this one, and not that one – and accept there was a learning curve on both sides.”
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