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Policy Papers

Improving Building Standards

Scottish Executive

Question 1.� Should the building standards continue to exclude issues related to the quality of construction, except in so far as the quality control is necessary for the effective function of the building in respect of the building standards?

• Difficult for Building Control Officers to define quality.� How do you define quality?

• This is about setting the minimum standards required for quality

• Safety � fire standards

• Quality is very subjective

• Do not like grey areas e.g. sizes, measurements etc but is it good quality?� This is harder to define

• How can it be written down?

• Budget and building type/practices determine quality e.g. what materials are used, cheapest?� Different standards for different price ranges?
• Generally difficult to agree quality but should include energy conservation (e.g. triple glazing, ending fuel poverty), Finishings relate to accessibility
• Items should comply with relevant British Standards
• Additional documentation to highlight best practice such as, what best standards have been developed to meet needs in the past
• If quality is to be taken into account, it must be measurable
• Market requires cheapest buildings, cheapest materials and methods, particularly in the socially rented sector
• Cheapest materials are least energy efficient and contribute to fuel poverty .:� vicious circle.�� Quality is desirable to ensure that this does not happen
• Some of the worst buildings are by private developers
• Social housing sector often better controlled (discussion, some agreement on this)
• Central heating is needed, but if poor insulation then it will cost a lot to run.� Can fit best quality central heating system but this is not necessarily functional
• We are not technical specialists, but any standard must be measurable and able to be implemented
• Building standards point the way.� Concern about varying approach
• Buildings are now more flexible.� Standards must be high enough to allow for change of use e.g. warehouse into residential flats.
• Lower quality increases ongoing management and maintenance

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Question 2. Should the building standards be the benchmark for all other legislation or guidance related to buildings?

• Regulation does override the building standards e.g. Ideally there should be ample facilities for wheelchair users but Health & Safety can override this and result in reduced facilities
• Building standards should override everything they should come first as they are done at the beginning i.e. first the building then the use of the building
• It has been known that buildings not meeting all technical requirements correctly but given relevant licence
• Anomalies in legislation at present
• Everything should relate back to the building standards
• Refer to all types and standards e.g. factories, entertainment etc
• Entertainment licence e.g. caf� taken over by a new caf�. Second bite at the cherry, normal process does not do this.� Building standards inform all activities, regulations etc but do not go far enough re sensory impairments e.g. colour contrast.
• Building standards and DDA should fit together
• Consistency throughout Scotland is required.� H&S, fire and disability all taken together but in conflict which would win?� H&S and fire for all, should not conflict but dovetail.
• Answer � YES

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Question 3. Should the mandatory building standards be written in the form of the expanded functional standards?

�������� Answer � YES

�������� England envious of Scottish situation, as England has guidance rather than mandatory standards.

�������� Part M in England. Reasonable account of normal/expected users of the finished building.� Technical standards mandatory.�

�������� Some thought that this was a move backwards, moving to a more general standard that will not meet people needs. Devil is in the detail.

�������� Functional standards must look at minute detail and be very specific

�������� Functional standards are open to debate � difficult to implement and enforce

�������� Move away from technical standards can cause problems e.g. measurability

�������� Clarification from report � duty holder must show how they will meet standards and measure performance

�������� Allowing some flexibility for builder to show how to meet them

�������� Cynical view of how people will avoid meeting general standards e.g. never intended disabled people to use the building.� Necessary to avoid generalisation of standards.� They have to meet DDA and technical measurements and aspirational, barrier free best practice - things that all functional standards must meet.� Tests = access and usability

�������� Decisions on public interest is political, this brings unease, surely political can be dangerous and needs �beefing up�

�������� Should be in consultation with appropriate groups (clarification, this is in the report, political process will be democratic process)

�������� Stick to technical standards that can be laid down.�

�������� Functional standards too airy-fairy, too open to interpretation.�

�������� Something that can be measured.

�������� Some basic minimum technical standards to back up the functional standards.�

�������� BS8300 disabled access to the built environment could be used as the benchmark

�������� People accept BS, but some of this is too general and open to interpretation

�������� Must comply with DDA is other standard

�������� How do we count functional standards? DDA is a catch all, but secondary. Up to courts - what is a reasonable adjustment? This is a problem with DDA.� Physical barriers relate to building regulations, exemption for 10 years before adjustment needed.�� Would apply to functional standards rather than technical standards

�������� Need mandatory technical standards.

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Question 4.� If expanded functional standards are made mandatory, should they be accompanied by: a) a set of advisory performance requirements which will have been developed from the existing Technical Standards, and/or, b) advisory prescriptive specifications for the most common building works?

�������� No flexibility regarding access.� Access fundamental principle regardless of building type.� Need detailed standards for accessibility

�������� 1 exemption in the report is that the power to relax is reserved to Scottish Ministers, this is a move up.�

�������� There is a worry about Scottish Ministers taking these decisions.� Developers will not like it as could take 2 weeks via building control system, but potentially months/longer through the Scottish Ministers

�������� Difference between different local authorities re what is a relaxation, there is a freer view or interpretation in some areas

�������� Local authorities have different relaxations of standards.� Regulations tightly written but room for change.� Problems not new buildings but changing existing buildings

�������� Option 4 b) suggested by 2 people

�������� Might be desirable for advisory specification for some things but not for accessibility or usability. This must be mandatory for access and usability

�������� Accessibility is not negotiatable

�������� Appreciate need for flexibility only where appropriate

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Question 9. Should verification continue to be undertaken only by local authorities?

�������� YES, definitely, absolutely

�������� Cannot pressure Building Control Officers

�������� Local authorities are accountable but other people only accountable to their employers

�������� Clear regulations help enforcement

�������� Best value � determine best method of enforcing consistency.� Consistency is important, consistency not obtained at present, tighter guidelines needed

�������� Issue about current process opened up to scrutiny � delegated to building control offices.�� Hard to get process opened up to local disability groups and others with an interest

�������� Building Control Departments, one office usually specialising on access, all officers should be able to do this, all officers should have a desirable degree of knowledge and understanding

�������� Delegating governance locally, resource level, quality and service allowing for local flexibility

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Question 10.� Should competent individuals be allowed to register as Approved Certifiers of Design for part or all of the design process?

�������� Who defines competent individual?

�������� Good idea if a body of people can do this, quality standards likely but vested interest also

�������� E.g. NHBC in England

�������� If this is to be done, sit it with Building Control in Local Authorities, they can take it out to local access groups

�������� Need measurable standard for consultants in Scotland

�������� Centre for Accessible Environments has access consultants register (England and Wales) but early days

�������� Agree, but robust process for certification required

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Question 18.� Should a national building standards body be created?

�������� This will create a new quango, not transparent or accountable

�������� Need to take into account Crown buildings and increasing private finance of public buildings but don�t want quango

�������� Difference between Scotland and England � how to take it into account

�������� How could it be set up?

�������� Get lots of professionals on it, technical role

�������� 1 voice from 15 with practical point of view, may end up with token disabled person

�������� Sub-committees suggested in report.� One on access to represent across the board, physical, sensory, learning disabilities

�������� Situation in England and Wales � Building Regulations Advisory Committee, look at things in isolation

�������� Note of caution re access sub-committee

�������� Better to have a some voice than no voice at all

�������� Can�t view full picture from looking at these questions in isolation

�������� What type of agency is proposed?

�������� Executive distancing itself from responsibility

�������� New building standards Advisory Committee, and sub-committee, should report direct to Executive, not to an Agency

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Question 19. If a national body is created, which of the following roles should it undertake? (Discussion on suggested roles a) to h) as listed in part 3 of report)

�������� Defining access standards? Include access as integral part

�������� Training, advice and information given by any new organisation

�������� How do you become approved?

�������� Accessibility information and process to the general public

�������� Audit Scotland does some auditory work on LA�s, is this duplication? Re Best Value coming in

�������� Competency � who has the power of competency?� Other bodies can sit in judgement

�������� Problem of tension between assistance and adjudication

�������� National body � publishing results and findings, monitoring and auditing

�������� They are going to be a very busy bunch

�������� Conflicting roles � advisor, influencer and judge in one.� Auditing role will be more administrative rather than standards of buildings

�������� Agency has teeth plus powers � need Act of law to give teeth, function, power and duty of government

�������� Responsibility should be with government department

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Question 20.� If a national body is created, what other roles should it undertake? (Continuation of discussion at Question 19.)

�������� Reviewing guidelines on an annual basis

�������� Testing standards against usability, are they working?� Monitor and review them in practice

�������� Guidelines and procedures need review

�������� Monitoring a function is very difficult

�������� Best Value process should address some quality issues, may have a role here

�������� Promoting and disseminating and encouraging good practice

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Views on other principles

Chapter 6, Buildings in Use

�������� Enforcement and implementation

�������� General issue � meeting building standards seen as relationship between LA offices and builder, no role for rest of local community

�������� Timescales, currently hard to stop a building or change a building or for people with an interest to check a building in progress

�������� Local access groups etc to look at public buildings for public use, nothing in report about this

�������� Hard to get things changed

�������� Visit by Building Control Officer is only a snapshot � need better checks

�������� 3 month delay in system looking at plans

�������� Need resources in enforcement, more Building Control Officers

�������� No legislation to enforce building standards

�������� Enforcement is a big issue, lot of this good stuff but if not enforceable, then useless (note resources required)

�������� Fire regulations enforced

�������� No enforcement in terms of access possible

�������� Can enforce minimum standards but these are poor and need to be better/higher and include things in them so they can be enforced

�������� If we have Design consultants, things could be better

�������� Currently down to people on the ground being good at their jobs

�������� No law to stop building at present

�������� Improved installation and design, some form of policing people doing things without warrants.� Approval can be withdrawn, procedures and monitoring?

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Wish List.�

�������� Training for all including builders, architects etc on disability access. Mainstream the issue

�������� Access issues integral part, mainstream � all buildings accessible, access not a separate issue

�������� 2m x 2m functional, accessible toilets

�������� Building standards - officers not able to enforce accessibility, should be able to

�������� Whole building accessible

�������� Principle � standard maximum rather than minimum access for all, everyone benefits. Highest possible standards.

�������� Design taught properly to planners, architects etc

�������� Standard list of definitions � what is barrier free accessibility?

�������� Ensure clarity and transparency

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Scottish Disability Equality Forum

Working together for the disability movement

SDEF is a recognised Scottish charity no. SC031893

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