For well-documented reasons, in recent years there has been a focus on the compliance of life safety elements of buildings – specifically related to fire doors in this article.
Building Regulations 2010 Approved Document B – Fire Safety states that “Independent schemes of certification of installers (TPC) can provide confidence that the required level of performance for a system, product, component or structure can be achieved.”
So, is TPC adequate?
In essence, ‘Building Regulations’ is suggesting that using TPC Installers will provide a suitable installation.
But the Building Safety Act 2022 (Primary Legislation) states in Item 35, 5C
(2) A “competence requirement” is a requirement relating to—
(a) the skills, knowledge, experience and behaviours of an individual.
Is this really the case, though? Does TPC provide this?
We have spent a combined total of 25 years inspecting building sites across the UK, operating as independent inspectors usually on behalf of the client.
We are yet to see a 100% compliant fire door installation.
Just to be clear, we are not talking about existing buildings; we are referring to new-build sites (or major refurbishment schemes on existing buildings), on many of which the installers have been TPC.
How can this be?
Surely when an installation company signs up to join a TPC scheme, they are effectively making an ongoing commitment to ensure that every fire door they install will be fully compliant in every respect.
If they are not doing so, then what is the point of TPC?
Is TPC, as it stands fit for purpose (Does it meet the requirements for ADB)?
Before we look into this in any depth, it is perhaps worth mentioning that for any project where Building Control is involved, the Building Control body themselves should establish before the commencement of the project that any particular scheme is adequate for the purposes of Building Regulations. This means then that before a project commences, the Main Contractor should discuss with Building Control the suitability of any proposed TPC scheme to be utilised before it is officially adopted.
How often does that happen?
TPC installation schemes are, in effect, Competent Person Schemes, as membership of the scheme implies that scheme members and their operatives are competent to install fire doors; their documentation and management systems have been checked and verified along with their training records, toolbox talks etc. The TPC has a nominated ‘scheme manager’ whose role it is to oversee the actual installers (up to 20 individuals) and ensure all installations are compliant.
This is where we believe the problems lie with the majority of TPC installer schemes.
MHCLG / DLUHC guidance states that Competent Person Self-Certification Scheme operators “should assess applicants as being technically competent against agreed minimum competence requirements. For applicants, this should be before registering them with the scheme. The assessment must include an on-site assessment.”
The guidance also states that “Scheme applicants cannot be certificated until they have been assessed against the technical competence requirements of the Minimum Technical Competence (MTC) assessment procedures for assessing competence against National Occupational Standards (NOS) for specific types of work.
Further MHCLG / DLUHC guidance on minimum competence requirements for work undertaken through competent person schemes approved under Schedule 3 of the Building Regulations (England and Wales) states the assessors themselves must have “competence in the area of work being assessed” which may be “in the form of a qualification or certificate issued by a recognised awarding/certification body”, and of course should possess a suitable assessor qualification.
The NOS for fire doors is very comprehensive and ultimately combines at least three NOS documents relating to Health, Safety and Welfare, Conforming to Work Practices and the actual installation of timber-based door assemblies and doorsets. These NOS combined effectively form the basis of qualifications related to timber fire doors, whether it be either City & Guilds or NVQ formats.
Surely then, if TPC installer schemes do not include on-site assessments for the individual installers – by assessors that are qualified in the discipline of fitting fire doors themselves – then the TPC Scheme itself cannot be considered fit-for-purpose in as much as it does not comply with MHCLG / DLUHC guidance as no one in the TPC scheme has been assessed against NOS – which is a requirement for scheme operators.
Is there a better solution?
We believe so.
Personal Qualifications.
We believe that anyone installing life safety components (fire doors) should hold a personal qualification regulated by an approved body. This qualification should obviously include the theory and practical element related to fire doors – how they are constructed, the components required and the relevant legislation – but we must emphasise – critically the qualification should include a real-life on-site assessment of the individual carrying out the actual task of installing fire doors, and the whole assessment process should be recorded, traceable and where required repeatable.
Only by observing an individual fitting the product on site can the assessor be sure that they are both fully conversant with the product and have the required level of knowledge and skills but also that they can indeed carry out the work in accordance with NOS requirements.
Training centre assessments are not a suitable environment as conditions will never reflect the reality of a building site with the day-to-day pressures and unexpected issues most will be familiar with, and of course, the training centre environment does not satisfy MHCLG / DLUHCguidance which specifically requires “on-site assessments”.
Only by ensuring installers are qualified to install fire doors and have an acceptable level of knowledge and skills can we have any degree of confidence going forward that fire safety compliance in the built environment is of an acceptable level.
We have formulated the IFSS qualification in timber fire door installation specifically to satisfy the requirements of MHCLG / DLUHC guidance.
Applicants are expected to have an existing carpentry/joinery qualification before embarking on the training course to satisfy NOS requirements. The course then builds on this basic carpentry / joinery knowledge and provides an extensive knowledge base on fire doors.
The course is designed to effectively help the student absorb the course material and embed it as knowledge and skills to be drawn on when required.
At the end of the course, we have two multiple-choice question sets designed to ensure the student has attained the required level of knowledge. The pass mark is set at a high level because, ultimately, fire doors are a life-critical component, and any qualification related to their installation must ensure the holder has a comprehensive understanding of both the product itself but also the importance of compliance.
Any less stringent a format we would consider to be sufficiently robust and not fit for purpose.
Upon completing Part 1, the student can then book Part 2, the on-site assessment, during which the assessment our assessor will satisfy himself, drawing on the relevant NOS, that the student has the required level of technical knowledge and, of course, the practical skills to ensure a compliant installation.
Only then will the student be determined as competent and presented with their Firequal certificate and, of course, their ‘competent person’ ID card.
These cards are definitely not easy to get – but the effort is worth it!
There are, of course, fire door courses available that claim to make someone “competent” through an online-only course (we believe such courses do not make people legally competent). We agree with MHCLG / DLUHC that such courses are not fit for purpose.
If you would like to learn more, visit the website.
