Memorandum submitted by National House
Building Council (NHBC)
NHBC (National House Building Council) is the
world's most established standard setting body and home warranty
provider with over 20,000 builders on its Register and 1.7 million
homes protected with its Buildmark home warranty.
As a non-profit distributing company with over
70 years' experience working with the industry and the consumer,
NHBC is uniquely placed as an independent authority on the housing
industry.
NHBC also supports the industry and consumer
by providing essential services including building control, training,
health and safety and environmental services and by investing
in research, innovation and delivering industry solutions through
the NHBC Foundation and National Centre for Excellence in Housing.
NHBC welcomes this Trade and Industry Committee
inquiry into the UK Construction Industry. NHBC has not responded
to all aspects of this inquiry but only to the specific questions
on which NHBC is best placed to provide an expert response. Our
submission is based primarily on our views and experience of the
house-building industry. NHBC would welcome the opportunity to
give oral evidence to the Committee.
HEALTH AND
SAFETY
NHBC is the largest provider of health and safety
services to the housebuilding industry, currently supplying services
to around a third of the UK house building industry. NHBC has
close contact with a full range of companies from national volume
builders to small and medium enterprises (SMEs) and compiles accidents
statistics for the Home Builders Federation's (HBF) Health and
Safety Charter which is a part of the Government's Revitalising
Health and Safety initiative, a ten-year strategy launched jointly
by the Government and Health and Safety Commission in June 2000.
Improving health and safety standards is an
essential objective and challenge to address. NHBC supports builders
in their endeavours to improve the quality of new homes by supporting
strong and successful health and safety management. A construction
site that is being well managed for health and safety more often
than not also demonstrates a high quality of new homes.
There has been a move by the Health and Safety
Executive (HSE) over the last few years to shift progressively
away from prescriptive legislation—outlining exactly what
must be done—to risk-based legislation which leaves a company
to interpret the law in relation to its circumstances and operations.
Larger companies have the resources to employ
specialists or engage consultants to support them in meeting their
health and safety obligations but SMEs often cannot bear such
costs or deal with the often plethora of uncoordinated changes.
Whilst their obligation under health and safety law is no less
they often lack the necessary resources to devise and fully implement
a health and safety strategy.
SME's present the single largest risk group
for accidents and work related ill health. As illustrated by the
data contained in the following table:
| Proportion of self-employed and contractors employing:
| Construction work (by Value) | Workforce
| Fatalities | Injuries
| Ill-health |
| <15 | 17% | 26%
| 67% | 57% | 61%
|
| >15 | 83% | 74%
| 33% | 43% | 39%
|
"The proportion of self employed and contractors employing
more or less than 15 employees, the proportion of construction
work, the workforce, fatalities, injuries and ill-health are shown
in the table above. It is clear that those working for the smaller
companies face a disproportionately high risk (roughly double)
of injury and ill health than those who work for larger employers".
[(Health and Safety Commission Paper HSC/07/16 (9 January 2007)]
NHBC is actively engaged in meeting the needs of this market
sector by providing support which enables SME's to fulfil their
health and safety obligations. Recent research in this sector
has enabled it to devise a health and safety service specifically
tailored to the needs of the smaller organisations.
Through the Revitalising Health and Safety campaign changes
have been made to several pieces of health and safety legislation,
examples being working at height, noise and vibration. Additionally
an overhaul of the Construction (Design and Management) Regulations
1994, has produced the Construction (Design and Management) Regulations
2007. This has resulted in clients having more responsibility
for ensuring safety on their projects and designers having greater
clarity over their role in reducing hazards inherent in their
designs. In addition the changes will create a new duty holder—the
Co-ordinator—to replace the planning supervisor and new
levels of competency will be defined for all the parties involved
in construction.
Risk Factors and issues to address in the industry include:
— Lack of resourcing/understanding at SME level
and the difficulty engaging with thousands of small and micro
firms.
— Overly bureaucratic handling of health and safety
in larger firms. Excessive amounts of time and money spent in
the production of paperwork that serves little purpose often other
than to be available as evidence should the need arise. This is
recognised by the statement "any paperwork produced should
help with communication and risk management. Paperwork which adds
little to the management of risk is a waste of effort, and can
be a dangerous distraction from the real business of risk reduction
and management" paragraph 4, Approved Code of Practice to
the Construction (Design and Management) Regulations 2007.
— Fear of prosecution as opposed to ensuring worker
safety drives action.
— Lack of clear understanding of legislation/regulations.
— Migrant workers do not have localised health and
safety knowledge. Increasingly site managers are faced with the
prospect of a large number of those on site being unable to communicate
in English. As effective communication is probably the single
most important element to managing health and safety it is vital
that resources are concentrated on providing assistance in this
area. This could come nationally by encouraging non-English speakers
to learn the language and also on a smaller scale by providing
resources to enable printed and electronic guidance to be translated
into the relevant languages.
— Migrant labour standards vary greatly.
— Migrant labour will increase to plug the resource
gap in the industry but this is not being managed.
— Difficulty in educating migrant labour where there
is no common language.
BUILDING REGULATIONS
The implementation of building regulations has important
implications for the industry. In recent times the industry has
suffered from poor implementation of regulation by Government,
for example Part L of Building Regulations in 2006 and the current
introduction of Home Information Packs. NHBC believes that a regulatory
framework where the Government sets objectives, but the industry
works on methods and processes to implement those objectives,
is the most successful framework and the most likely to deliver
successful outcomes for Government and industry.
It is within this context and the debate about the quantity,
role and implementation of regulation that NHBC can help play
a vital role in the future. NHBC, in partnership with the Building
Research Establishment (BRE), has set up the National Centre for
Excellence in Housing, a new industry led partnership. The Centre
is working to identify practical solutions and address the challenges
and opportunities facing the housing sector. It will establish
a group of experts and key opinion leaders to facilitate policy
development and strategic thinking to help frame the research
and policy agenda for housing in the UK.
NHBC believes the Centre could provide the Government with
an ideal platform to consult the industry on a range of regulatory
and associated issues.
SKILLS AND
TRAINING: AVAILABILITY
OF, AND
INVESTMENT IN
SKILLS
NHBC provides strong support to the industry's skills development
agenda with its provision of training and qualifications programmes.
Our primary focus is on homebuilding, with many of our programmes
focussed on site-based management staff, but we also offer programmes
to the wider construction industry.
We are the largest provider of construction management NVQs
in the UK. We also offer our own site manager accreditation programme
which combines assessment of management and technical competence
with a check on quality of work on site and an assessment of commitment
to continuing professional development. Accreditation is renewable
every three years and is dependant on managers continuing to deliver
acceptable site quality and continuing to update their skills
and knowledge.
In addition to our qualification/accreditation programmes
we deliver approximately 1,150 days training per year. This provides
around 12,000 person days training. Subjects include management
skills, personal skills, technical knowledge and health and safety.
The availability of skills within the housebuilding industry
was addressed in Professor Michael Ball's investigation and report
for the Home Builders Federation (HBF)— The Labour Needs
of Extra Housing Output: Can the House Building Industry Cope?
One of the report's conclusions was that, while training issues
are important in the expansion of house building, it can be concluded
that skills shortages are unlikely to represent a barrier to expansion
of the house building industry. ConstructionSkills in its 2004
report "Skills Needs Analysis for Construction" estimated
that the construction industry as a whole needs to recruit and
train 88,000 entrants per year for the next five years (based
on the "most likely" growth figure of 2.3% per year).
From our experience providing training services within the
industry, NHBC believes that there has been substantial improvement
in the last 10 years in investment and training. We have seen
greater recognition in the industry that skills development rather
than "hire and fire" does have a contribution to make
to business success. The Major Contractors' Group and, more latterly,
the Major Home Builders' Group's commitment to the Qualified Workforce
initiative is further indication of this improvement.
The current structure in homebuilding (and in areas of general
construction), with largely sub-contracted labour, puts a lot
of responsibility for quality control on the site manager or site
management team. For this reason much of NHBC's training provision
is aimed at assistant site managers, site managers, project managers
and contracts/construction managers. Competence requirements for
site management staff can be divided into two broad areas—technical
and managerial.
Historically technical competence was less demanding with
construction methods for low-rise housing changing only slowly
over time. More recently, and for the foreseeable future, there
is a real need for managers to keep abreast of technical developments
around the move towards greater use of Modern Methods of Construction
(MMC), technical issues surrounding the sustainability agenda
and the move to more high-rise apartments and mixed-use developments
employing more complex and/or "commercial" methods of
construction. It is very difficult to quality control methods
of construction which are not fully understood. Structured training
programmes are required to ensure managers are competent in the
methods of construction they are overseeing. Work done by the
HBF, concerning the increased use of MMC, in a response to the
Barker Report also highlighted this need.
Equally important to site management staff are managerial
competencies. The site or project manager role is complex and
is becoming increasingly so with more apartments, more mixed-use
developments and higher densities.
STANDARDS AND
QUALITY
NHBC makes a considerable investment in the NHBC Standards,
the key on-site reference text for new home construction which
NHBC's Registered builders—currently numbering more than
20,000—agree to build in accordance with. These are updated
continually and republished annually to reflect changing trends
in housing construction which NHBC establishes through experience
of problems arising both during and in the 10 years after construction.
Possibly the best example of how Standards can help to reduce
problems for homeowners is that of "fill failure"—the
settlement of the fill placed under ground-bearing floor slabs.
Up to the early eighties there were significant failures and claims
against the NHBC warranty due to fills containing unacceptable
materials (timber, plasterboard, etc) and the fill not being properly
compacted.
In 1982 NHBC introduced restrictions on the types of material
suitable for use as fill and a requirement that the depth of fill
should not exceed 600mm, as beyond this depth it is difficult
to achieve satisfactory compaction. These changes encouraged more
attention to be paid in this area and a transition by many builders
towards the use of suspended floors instead of concrete ground-bearing
floors, which avoids the problem altogether.
As housing technology advances, NHBC increasingly tries to
be pre-emptive with the Standards—developing appropriate
requirements and guidance before problems occur. Recent examples
include:
— Light gauge steel frame housing—a new Standard
was introduced in 2005 to cover this technology, which is rapidly
establishing itself as the third most significant form of construction.
— Curtain walling and cladding—Standards Chapter
6.9, also introduced in 2005, is especially relevant for the growing
number of high-rise buildings under NHBC cover. The Chapter encourages
the specification of systems that have been appropriately tested
and introduced guidance on how interfaces between systems should
be dealt with to avoid the problems sometimes encountered where
these systems have been used in the commercial sector.
— The April 2007 edition includes a revised specification
for flat roof coverings—it restricts the specification for
acceptable materials to those which offer enhanced durability
and responds to the sustainability agenda by including specifications
for "green roofs".
RESEARCH AND
DEVELOPMENT
Two of the key challenges which the industry faces at present
are developing new methods of construction and working to improve
the environmental efficiency of new buildings. NHBC invests in
research, innovation and delivering industry solutions through
the NHBC Foundation and National Centre for Excellence in Housing.
The NHBC Foundation was set up in 2006 to address the "information
gap" in the industry on a variety of topics. Chaired by former
housing minister, Rt Hon Nick Raynsford MP, the Foundation has
dedicated itself to a programme of pragmatic, delivery-based research
of relevance to the industry. Its inaugural project delivered
a web-based resource tool on Modern Methods of Construction (MMC)
and subsequently it has delivered a research document offering
a detailed guide to MMC and most recently the first in a programme
of research dedicated to the sustainability and zero carbon agenda.
The latest finding focuses on reducing the consumption of energy
and water and minimising waste. Throughout 2007 it will also be
delivering research on renewable energy systems, site waste and
other topics of relevance to the sustainability and zero carbon
agenda.
The National Centre for Excellence in Housing, is also chaired
by Rt Hon Nick Raynsford MP. The Centre, also independent, arose
from considerable interest and support for a body with a wider
function and a significantly wider remit. The Centre is focusing
on enabling and inspiring excellence and improved standards in
new and existing housing.
The Centre brings together stakeholders and interested parties
to develop policy solutions to issues faced by the industry. The
Centre is also currently focused on the sustainability agenda
and in May 2007 is hosting a series of focus group events specifically
tasked to the zero carbon home target.
NHBC Standards also play an important role. They are reviewed
to take account of changes in materials and construction methods
and require that new systems and materials be adequately tested
and accredited. NHBC also carries out its own research to ensure
it is best addressing the issues posed by changes in the industry
and works in conjunction with Government on relevant projects.
Currently NHBC is working on the joint Department of Trade and
Industry/Building Research Establishment (BRE) project developing
certification systems for renewable energy systems.
In addition NHBC Technical is carrying out its own review
of renewable technology to deliver best practice guidance and
information to the new home building industry. NHBC's Building
Control Services department acts as a specialist advisor to Parliament
on Building Regulations and regulatory reform and change.
SUSTAINABILITY AND
CARBON NEUTRAL
AGENDA
NHBC is ideally placed to represent the views and concerns
of both the industry and the consumer on sustainability and the
zero carbon homes objective. NHBC has specialist understanding
of and involvement in the technical aspects of house building
as well as unique knowledge of consumer protection issues through
its Buildmark warranty.
NHBC supports the sustainability agenda and we are supportive
of the Government's objective to achieve carbon neutral homes.
However, NHBC has raised some concerns about the implementation
of this policy within the industry. These concerns focus on:
1. Consumer: Ensuring the protection of the consumer.
2. Science: Sound solutions based on credible science.
3. Reputation: Ensuring consumer support and backing of
the objectives.
4. Implementation: Need for nationally applied consistent
standards.
5. Partnership: Ensuring industry, Government and Stakeholders
work together.
Consumer protection must be placed at the forefront of technological
advances. We strongly believe that consumers must not be exposed
to unnecessary risks and used to trial zero-carbon technologies
and systems that have not undergone thorough testing and accreditation.
There is currently a dearth of tested and certificated microgeneration
technologies and systems. Asking consumers to pay for and maintain
products and systems that are not reliable or fail to deliver
the claimed benefits is inappropriate and could have damaging
repercussions. There are also important lessons for us to learn
from the past and from around the world.
In British Columbia a massive failure of new homes due to
water penetration, rotting and eventual failure of inadequately
designed and constructed timber frame housing systems affected
up to 10,000 homes, in a market roughly the size of Scotland.
The total cost to the British Columbian economy was between two
and five billion Canadian dollars. The British Colombian warranty
programme failed, many homebuyers faced considerable hardship
and the housebuilding industry was seriously affected for a number
of years.
Similar failures experienced in New Zealand and the USA illustrate
that change must be well thought through, well managed, and the
risks identified and eliminated to avoid causing great distress
and cost to home buyers.
NHBC has significant concerns about the role of planning
in raising environmental standards. Evidence suggests that there
is growing competition between planning authorities setting increasingly
tough, and sometimes ill thought out, targets in their planning
guidance. Given that climate change is a national and international
issue, we would question the logic of competing local targets
being set—it makes more sense to have one national target.
The fact that planning authorities have different targets
causes problems for architects and designers (often SMEs), designing
homes in more than one planning authority area. Differing targets
are also a challenge for house builders and are likely to reduce
their efficiency, reduce economies of scale and increase the potential
for defects to occur, as well as having implications for achieving
the output of new housing proposed in the Barker review.
Based on the evidence we have seen, we would question the
ability of the professionals working in planning authorities,
especially smaller authorities, to deal with the technical aspects
of sustainability. There is no doubt that building control professionals
are able to deal with these complex issues. We are strongly of
the view that most of these, with the exception of spatial issues,
should be dealt with through building regulations.
Taking a national view, it would appear that each extra pound
spent on further improving new housing may be better spent elsewhere,
eg improving the existing stock. Instruments that allow offsetting
in this way should be explored fully.
Therefore, NHBC's policy supporting the industry on sustainablity
includes:
1. Standards: Through NHBC Standards, which more than
20,000 builders apply across the industry, NHBC will continue
to work to raise standards and ensure that quality sustainable
homes are built.
2. Consumer protection: NHBC is working to protect the
consumer by ensuring new technology is thoroughly tested.
3. Science: NHBC is investing in research and devopment
through the NHBC Foundation and National Centre for Excellence
in Housing.
4. Partnership: NHBC is working with the Government, Parliament
and industry to help achieve carbon neutral homes.
4 May 2006
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