Building Control Officer issues: Conference April 2014
by Bregs Blog admin team
IBCI Conference Sligo: April 2014
In the course of the conference of the Irish Building Control Institute conference, which was held in Sligo on the 2nd-3rd April 2014, many issues were raised by speakers and the delegates which confirmed the belief that there was a great deal of uncertainty about the implementation and implications of SI.9 that needed to be resolved.
Among the issues that were raised were the following:
1. Building Control Authorities
Resources: There were repeated calls for the Building Control Authorities (BCA)to be properly resourced with the appropriate number of staff. Aside from the additional administrative duties it was envisaged that 15% of buildings would have to be be inspected 4 times. The department officials stated that there would be no increase in central government funding. The allocation of resources was a matter for each local authority.
The code of practice or “framework” for the guidance of BCAs in the operation of SI.9 is still in draft form and had not been made available to the BCAs.
It was noted that there was no representative of the building control officers or the fire officers (who will be responsible for implementing the code) in the steering group which was drafting this document.
The following are proposed section headings for the Code of Practice for BCAs which is urgently needed:
- Purpose of Framework
- Regulatory Design Principles: Regulatory Oversight
- Role of Building Control Authority: Overall Role
- Commencement Stage – Validation
- Construction stage – assessment and inspection
- Completion stage
- Risk Assessment: Aims, Benefits and Risk assessment approach
- Consistency and Standardisation
- National Co-ordination
- National Building Control Management System
- National & Regional Inspectorates
- Standard Approaches
- Administrative Validation
- Technical Assessment
- Commencement Stage
- Submission to Building Control Authority
- Construction Stage Inspection
- Inspection & Completion Stage
- Submission at completion
- Validation and Registration of Certificate
- Prior Notification of Submission of Completion
- Phased Completion
- Assessing Fire Safety Applications
- Assessing Disability Access Certificate
- Archiving of Records
The department officials hoped to issue a draft of the Code of Practice soon but there was no commitment as to when it might be finished and issued formally. In the meanwhile there was concern that there may be 34 different interpretations of the regulations given that there are that number of authorities. There was urgent need for the following:
- Training & Information for all required including BCA staff
- BCO inspection staff need to be instructed not to issue directions on site
- Standardised written QA procedures required
- Need for regular CPD updates
- Consolidated Regs (Draft DoECLG) required
- Coherent Framework including inspection policy required and implemented by Local Authorities
Clarification is urgently required on the appropriate qualifications of personnel appointed to act as building control officers within local authorities, given the very strict rules applied to Assigned Certifiers and Design Certifiers under SI.9. A program of training and continuing professional development needs to be undertaken for building control officers.
2. Online Registration System
There were numerous reports of glitches in the operation of the on-line registration system. It was seen as a work in progress and a number elements are still subject to further development including the following:
- Completion Certificates
- Short Commencement notices
- Translation to Irish
- Online Help
- Accept Roles Online
- Dublin City Payments
- Update Project Details
- Additional Roles
The following elements remain to be done and were seen as Phase 2 of the system:
- Completion Certificates
- Risk Analysis
- Integration of Fire Safety Certificates
- Integration of DAC’s?
3. Fire Safety
Concern was raised by speakers and delegates about the lack of con-ordination between a number of existing process and the requirements of SI.9.
Where a Completion Certificate is issued for a building which does not comply with a fire safety certificate issued for the same building. Which takes precedence and what should the BCA do about it?
There is provision under the “pre SI.9” regulations for a regularization certificate, but this is not provided for under SI.9. How is that to be resolved?
Procedures for applications for fire safety and disability access certificates are different and un-coordinated with the procedures set out in SI.9
In formulating the risk assessment process to determine which buildings will be inspected, it appears that the work already done on a system of fire risk assessment (known as PRIME) has not been integrated into the process of risk assessment currently proposed under SI.9.
Integration of the requirements of SI.9 with other existing legislation:
- Fire Services Act
- Pre-Incident Planning
- HIQA Registration
- Multi-Unit Developments Act
4. Self Builders
While it was stated by department officials that the question of the status of self- builders had been clarified by the Minister and that he had made it clear that they could sign completion certificates as “competent builders”, there was little evidence that anyone actually believed that. The representative of the Society of Chartered Surveyors (who is a member of the department’s advisory group) expressed the opinion that self- builders would be playing “Russian Roulette” unless they engaged the right supervisory /professional staff. A number of speakers and delegates called for clarification which would put the matter beyond doubt.
In summary there was a significant number of questions raised that remained unanswered. There was a general expectation that it would take another 6 months to clear the majority of those issues.