Self Certification Schemes - Be Careful, read the 'small print'
In a self-certification scheme an installer, or one of his personnel, issues a ?Certificate of Conformity? (CoC) that says that the work has been carried out in the appropriate manner. The ASFP believes, however, that such CoCs are worthless because they do not carry any independent verification of the work.
There are Government backed self-certification schemes for other industries, for example FENSA for replacement glass, but currently there are no such schemes for passive fire protection in the UK. If you are offered the services of one, or invited to join one, you should ask if it has the 'endorsement' of Government - for England and Wales, which would come from the Department for Communities and Local Government. If the proposed scheme does not have this endorsement you should ask why not, since Building Control or the Approved Inspector on a job is likely to ask you this question and will want to know why the scheme hasn't been placed before Government for scrutiny.
The ASFP believes that all passive fire protection work should be carried out by third party certified installers.
The Association assumed, perhaps naively, that most people in the construction industry understood the concept of third party certification for installers of fire protection systems. A survey carried out by the ASFP contractors' committee, however, found that there was a lot of confusion in the market and in particular from the main contractor and property developer base. Thus, it is time for a basic course in the nomenclature!
You may well ask why the market should have any knowledge of the term 'third party certified'. For that answer turn to 'Approved Document B' (ADB) of 'The Building Regulations 1991 - 2000 Edition', which says:
'Since the performance of a system, product, component, structure is dependent upon satisfactory site installation, testing and maintenance, independent schemes of certification and registration of installers and maintenance firms of such will provide confidence in the appropriate standard of workmanship being provided'.
And in the edition that takes effect in April 2007...
'Building Control Bodies may accept the certification of products, components, materials or structures under such schemes as evidence of compliance with the relevant standard.
Similarly, Building Control Bodies may accept the certification of the installation or maintenance of products, components, materials or structures under such schemes as evidence of compliance with the relevant standard.
Nonetheless, a Building Control Body will wish to establish, in advance of the work, that any such scheme is adequate for the purposes of the Building Regulations.'
The ASFP considers that these ADB statements are the best practise and that the construction industry should be striving to ensure the highest level of fire safety of the UK's buildings. Indeed, all ASFP installer members are third party certified or working towards third party certification.
But it's not just Approved Document B. The insurers say in Principle 11 of the Fire Protection Association's 'Design Guide - Essential Principles':
'All fire protection products/systems shall be installed by adequately trained specialist installers. Installers shall be third party certified to install the specific product/system when an appropriate scheme is available (e.g. FIRAS or LPCB).'
So where does the market's confusion come from? Well, many respondents to the survey thought that approved or recognised applicators as appointed by manufacturers of products were, in fact, third party certified! This is not of course to say that product manufacturers don't train their installers properly, but this does not extend to them randomly inspecting the installed product on-site!
Some other respondents to the survey thought that the carrying of CSCS (Construction Skills Certification Scheme) Cards by the operatives meant that their company was third party certified. The CSCS scheme aims to register every competent construction operative within the UK not currently on a skills registration scheme. Operatives will get an individual registration card (similar to a credit card) which lasts for three or five years. The CSCS card also provides evidence that the holder has undergone health and safety awareness training or testing. The CSCS initiative is supported strongly by the ASFP, but the scheme registers operatives and not companies and does not provide any inspection of work or company systems.
The ASFP has been heavily involved with the Construction Industry Training Board in the design of the Level 2 and 3 NVQs in Passive Fire Protection. Level 2 is for installation Operatives and Level 3 for Supervisors. These NVQs demonstrate the competence of the employee and this is assessed by on-site visits and it is the latter that has led to the confusion in some quarters that these constitute some sort of certification/inspection. It does not! The NVQ demonstrates that the holder has been assessed to have a basic competence level in at least two out of the seven possible fire protection modules. The seven modules currently include the application/installation of structural cladding, intumescent coatings, fire rated ductwork, fire stopping and penetrations/cavity barriers, fire rated walls and linings, fire rated ceilings and spray applied materials. The NVQ is a valuable tool in looking at the competence of a company's workforce, but it does not ensure that the work on-site will be of the standard required by the client.
So, we've looked at what third party certification is not, so what is it?
In the opinion of the ASFP third party certification schemes mean a combination of site inspections, quality management system audits plus the assessment of the competence of the workforce. Such schemes ensure that passive fire protection installations have been conducted by knowledgeable contractors to the appropriate standards. In addition, these schemes offer a meaningful certificate of conformity that is backed by a third party (the scheme organiser) and this will add confidence to the client that the passive fire protection in his or her building has been installed properly. Given the increased responsibilities of the 'Responsible Person' under the Regulatory Reform (Fire Safety) Order, it would seem sensible for them to insist upon the use of third party certified installers for the passive fire protection in their buildings.
So if you're offered the possibility to join or support a self certification scheme, the advice from the ASFP is to be careful and read the small print to see if it has the backing of Government. If it doesn't, you should reject it and think seriously about a third party certification scheme.
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