Air Quality Matters

#50 - Peter Rankin: Transforming UK Building Safety - Regulation Reforms, Ventilation Standards, and Collaborative Innovations

Simon Jones Episode 50

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Join us as we explore the significant transformations in building safety regulations in the UK with Peter Rankin, a leading expert from the Health and Safety Executive. Following the tragic Grenfell Tower fire, sweeping changes have reshaped the landscape of building safety, led by the establishment of the Building Safety Regulator under the Building Safety Act. You'll gain a deeper understanding of how these reforms centralize responsibilities within the HSE, impacting building standards and the multi-faceted role of the regulator in ensuring safety beyond just fire and structural concerns.

Peter Rankin provides a fascinating insight into the challenges and innovations in  building regulations, particularly focusing on ventilation standards. We discuss the intricate balance between technical accuracy and readability in building guidelines, highlighting the importance of accessible guidance for those involved.

This episode also delves into the modernization of these regulations, especially in the digital realm, emphasizing the vital role of effective communication and the untapped potential in government messaging to enhance compliance and performance in the industry.

The conversation extends to the imperative of improving indoor air quality standards and the importance of re-evaluating ventilation systems. With a view towards infection resilience and pollution control, we consider the implications of updated standards, innovations in building design, and cross-industry collaborations to foster a safer environment.

This episode is packed with valuable insights for anyone invested in the future of building safety and regulation, offering a comprehensive look at how these changes are shaping industry practice and public safety.

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HSE - Building Standards 

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Simon:

Welcome back to Air Quality Matters. I believe we already have the tools and knowledge we need to make a difference to the quality of the air we breathe in our built environment. The conversations we have and how we share what we know is the key to our success. I'm Simon Jones, and this is episode 50. Coming up a conversation with Peter Rankin, head of Energy and Environmental Standards at the Health and Safety Executive in the UK.

Simon:

Following the Grenfell Tower fire in 2017, significant changes have been made to the building safety regime in the UK. The Building Safety Act established the Building Safety Regulator as part of the Health and Safety Executive. This new regulator took over many of the responsibilities previously held by MHCLG, that's, the Ministry of Housing, communities and Local Government and local authorities, particularly for higher risk buildings. The Building Safety Regulator now has several key responsibilities regulating higher risk buildings, overseeing the safety and standards of all buildings, and assisting and encouraging competency among the building environment industry and registered building inspectors. The building environment industry and registered building inspectors. This transition represents a significant shift in the UK's approach to building safety, moving from a system primarily managed by local authorities and government departments to one with a dedicated regulator within the HSE structure.

Simon:

Peta has been at the heart of building standards for years and particularly, from my perspective, standards around ventilation. So it was an enormous privilege to finally sit down with him and chat about this new reality for building standards, what it means for the sector and, at a higher level, a view from inside the machine of building standards. We talk about or at least I talk about a lot the intent of regulations, how we construct language around these things and communicate it, and I and Peter share a lot of common grounds here. If you're interested in how we improve buildings over time and solve the challenges we face on the ground, I think this is a fascinating episode. Thanks for listening. As always, do check out the sponsors in the show notes and at airqualitymattersnet.

Simon:

This is a conversation with Peter Rankin. You've had a bit of a big move recently, right, and brought some people with you, so I thought that would be a really good place to start. Is it's quite unusual for something like building standards to fundamentally move from one place to another in government circles? Tell us a little bit about that. What was the kind of the idea behind that?

Peter:

officially, yeah, exactly. So. The Building Safety Regulator was established in 2022, and that changed a lot of things. I think probably most people who are aware of the Building Safety Act probably think of it as an act that was dealing with fire risks, but also structural risks in high-risk residential buildings high residential buildings but the Act actually did a lot more than that. It does a lot more than just looking at those particular types of buildings as well.

Peter:

So a couple of things that it did was one introduced a new regime to look at the competency of building control assessors that sits in a different team. It also abolished the Building Regulations Advisory Committee, which was a statutory committee that was there as a group of experts to directly advise the Secretary of State on building regulations and building safety matters, and established a replacement committee, the Buildings Advisory Committee, a very similarly named committee that was set up to directly advise and give technical advice to the building safety regulator, and that's a committee that that is comprised of of experts from industry. The part, uh, the part of the change that influenced me and and my team was that, um, the building safety regulator was was established as the technical authority on buildings to give independent advice to ministers, to the department and to the Secretary of State, but also to be able to run our own agenda and decide where is the best place to spend our resource and to spend our staff time in looking at not just building safety matters.

Peter:

There's a very wide duty that the building safety regulator has, which is to keep the safety and standards of buildings under review, which is section five of the Building Safety Act. So that's huge. It's beyond fire safety and structural safety and it's beyond just those high-risk residential buildings. That was a big focus of the Building Safety Act but not the only.

Peter:

Thing that the Building Safety Act did and it's the first time in in in in history that I'm aware of that these functions have been moved out of central government since uh, probably since the introduction of of of the national building regulations standards in in the 1960s. So it's a huge, it's a big change, and my focus and the team's focus in the last year, since we've been here about 18 months now, has really is mostly to be honest, being to make sure that that transition is has happened smoothly, but there hasn't been a gap in government function in respect to the technical standards and technical advice that ministers get on buildings, and I think we're moving to a place where we're able to play our own far now, actually, and realize a lot more of the benefits of us being now in an arm's length organization that we're able to decide where to best focus the resources of government in its technical expertise of buildings to fulfil that function that's set out in the Building Safety Act, which is to improve the safety and standards of buildings.

Simon:

And where is home? So where is that now? Did you consider yourself part of the building safety regulator or part of the HSE? Uh, yes, where's home for you now? In that sense, yeah, yeah, yeah, so so the building safety regulator is.

Peter:

Is the regulator named in in the act? Uh, that sits within the hse, um, and and I am an hse employee and employee and my whole team is so absolutely we are a core part of the health and safety executive. Now, myself and my team were previously part of what's now called Ministry of Housing Communities in the local government. It was the levelling up department at the time when we moved. It's changed its name a number of times over over the years, sure, uh, so, so, yes, we're absolutely part of uh, part of hse.

Peter:

I think that's brought quite a number of benefits actually, in that we've that the building safety regulator. We haven't had to stand up a whole new organization completely from scratch. We've joined a well-established, well-functioning regulator that's got a fantastic track record in in workplace health and safety over the last 50 years and there's a lot that we've gained and there's a lot that we've learned, that we're able to learn from the success of that regulator and to apply it to the safety and standards of buildings, regardless of tenure. So it's a big change for me and it's a big change for us as a team, but it's also quite a large change for the HSE as an organisation. Like I say, for almost the entirety of its 50-year life it's been focused on improving workplace health and safety, which it's done a fantastic job at. But now it's got this other brand-new remit as the building safety regulator as well, and under a different Act of Parliament than the Health and Safety at Work Act.

Simon:

But there's lots of parallels and there's lots of sense of the of the uh, of this function.

Peter:

Being at the hsc, I've always seen the building regulations as being uh, as being sort of almost an equivalent to the Health and Safety Work Act, but for buildings, but for homes and other types of buildings.

Peter:

So we've made some really good connections and things here, particularly with colleagues looking at workplace health and safety, obviously. But the other huge benefit as well is that the HSE has a fantastic science capability with and has a big facility up in Bu, in buxton, um with with the laboratories and testing capability, um, lots of people much cleverer than myself with with with phds and lots of letters after their names, uh, so, so, so in in a sense, it, it, it feels, um, it feels more like a home for my team, who are mainly people from various different technical backgrounds. I've got architects, public health experts, energy experts and we can have lots of these peer-to-peer conversations with an access to other expertise around the organisation. So that's been a real benefit as well and we're doing lots of new research that we wouldn't have been able to do actually in the department because we wouldn't have had access to it.

Simon:

I mean there's loads to unpack there but you can see so much crossover between the HSE and building standards, particularly perhaps from the lens that I tend to look at stuff through which is ventilation and health. Obviously there's enormous crossover with workplace health and safety and workplace health and well-being. Um, it seems like a very natural home in that sense. I imagine there's other parts of building standards that are perhaps a little less of a glove fit um thinking. Things like energy and things like that might be a little bit outside of the hse's realm, perhaps particularly from a um a ventilation standards perspective.

Simon:

It. It's always felt a little like in standards a little less so in the uk but perhaps in other jurisdictions that the non-residential sector has been a bit of a tack on to guidance um and it's always kind of there's always been this straddling somewhere between hse and and workplace health and safety and engineering sibsy type guidance, part b and a and all of that kind of stuff and then a kind of a nod to it to some degree within building standards. So I imagine that closer tie to hse must be very, that that could be very powerful from a, a workplace ventilation and an air quality perspective, going forwards from a standards perspective, having that link yeah, we certainly hope so.

Peter:

yes, yeah, and I'd say that's quite a good observation to be honest that the building regulations guidance through the approved documents tends to be quite focused on domestic, particularly for ventilation, and I think there's a number of reasons for that. I think the professions are different. Domestic installations you tend to get a different profession. You don't always get a proper ventilation design. Non-domestic buildings I think there's a perception that a lot of them look after themselves, in that there's industry standards that people are building to.

Peter:

You'll often get a consultant involved who will make sure that it's well ventilated and it's built to the right standard. But also there's just such a huge range of non-domestic buildings.

Simon:

I was going to say, you know I mean whatever about the range of residential scenarios. You're effectively talking about boxes with people in them, whether they're in flats or houses or whatever. You go into the non-residential sector and you you know schools, factories, clinical environment, you know it's just endless. So you can't very difficult to capture that in a kind of an approved document, so to speak.

Peter:

Yeah, exactly, and I think, when, as far as non-domestic buildings are concerned, I think my philosophy would be that government wants to give, um, give guidance on the overall standards, and there is a regulation in place. Of course, that applies to non-domestic buildings the same way that it does domestic buildings. Um, the regulation is very simple, as, when ventilation is concerned, it's um, uh, as, as you all know, simon, there's, there's, there's one ventilation requirement on the performance of your ventilation in the law, that is, um, that there should be adequate ventilation for people in the building.

Peter:

That's all the law says yeah, and it applies to uh, to most types of buildings um and for non-domestic buildings, I suppose it's similar in a lot of ways.

Simon:

Actually, I'd say peter, in the sense, if you look at how health and safety at work acts tend to work, they tend to have that kind of we call it green box or gray box regulation, but they tend to have that kind of plain english thou shalt provide safe blah, dee blah, you know, for people at work that's when codes of practice and guidance then fall in behind those kind of generic statements to fill in the gaps, to say, well, this is how, in normal circumstances, we would expect you to achieve that, that kind of prima facie compliance element.

Simon:

So there's a lot of analogies in the structures in the sense that you kind of got these very high level legal frameworks that virtually nobody reads um, and then you have the structures below that in guidance documents and approved documents and codes of practice and so on. In both sides that um start to put meat on the bone and provide people with a frame of reference. It'll be really interesting to see over the next decade whether there's how that crossover manifests between approved documents and the type of guidance that comes out of HSE typically. Yes, yes.

Peter:

And in fact in the past the HSE guidance through the approved codes of practice and building regulations guidance, have often looked to one another, possibly in an informal way, but sometimes when you dig under it you find that the acop actually says, uh, says something, or sets a standard, and and you dig into it and find out why it's set a particular standard and it's and it's because we'd set it originally in the approved document. Um, uh, it's, it's it's kind of merry-go-round over time.

Peter:

Yeah, it's funny how some of these things work and I think the um, the influence of standards making and and writing standards is sometimes so great that that, once it's written into a government approved standard, people often take that as um, uh, as read you know, uh, and and sometimes when you dig into where the, where these figures have come from, because you know if you look across the approved documents we've we've got we've got things that that uh, um, you know you've got to put numbers against things.

Peter:

I think ventilation actually is in a pretty good place and we had a fundamental look at it a few years ago. But across some other things, you look at where these numbers have come from and it's unclear because it was developed 20, 30 years ago in some places. Because it was developed 20, 30 years ago in some places, and so I think it's really important actually that we do periodically undertake a sort of fundamental back-to-first principles. Look at all of the things in guidance, because there is that risk that things are taken as authoritative because it says it in an approved document. And that was one of the things actually that I looked at when I first joined government in 2015 in the department was to undertake a fundamental review of approved document F and picked it, absolutely picked it all apart, right the way back to first principles and the equations and things that underpinned the, the, the pattern book that everybody was using when, when, when they're designing new homes.

Simon:

There's a book somewhere, peter, I'd say that that, that that job of picking that apart, cause a lot of those original first principle numbers were lads in white coats from the BRE in the mid eighties walking around doing calculations on the back of a fact packet and sticking fingers in the air and trying to agree first principles back in the early days. And I think this is the challenge and this is the, I think the interest, fascinating thing when I talk to you is the the evolution of these standards, because they take time and we'll come on to that later in the podcast, but it's an enormous process. There's lots of consequential impacts of changing standards that have to be thought through, a lot of systems thinking, so this stuff can't just be happening every year. And the challenge is that time moves on and you blink and a number that was determined in the mid 80s or the early 90s, all of a sudden you're in 2024 and you're going where did, where did we get that from, like, where was, where did that idea of?

Simon:

I remember back 10, 15 years ago there was a question brought up, quite an innocent one, when we were starting to insulate attics about where did we determine how big the strip was supposed to be on the soffit for attic insulation, because we're now covering that up with insulation and people are having to put tile vents in what's the equivalent, what are the actual formulas and maths for that? And all of a sudden you're into trying to dig out historical papers, trying to determine who came up with that original formula for an air change rate effectively in a in an attic space, and you realize 20 years have slipped by and people have left yeah, yeah, absolutely.

Peter:

And and a lot of the time, uh, when you're writing a technical standard that there there isn't an answer, lying about no, and you can't do the research because it's going to take two or three years, or perhaps even longer, and several hundred thousand pounds. So the the trick is to get a bunch of people around the table and and pick out something that we think is reasonable. Um, and, and that's that's to be honest, that that's some of the basis behind some of these figures that have got sort of unclear origins and generally, over time, you sort of find out whether it's about right.

Simon:

Yeah, and I think that's been one of the realisations that I've made over time around advisory documents like approved documents or technical guidance documents and so on, is that they are reasonable assumption documents. You know they're premier fascia documents, they're documents that are there to guide us, to provide a frame of reference that there aren't necessarily. You know. The numbers that appear in them, while they may look definitive, are anything but often. And I think when you start to understand that, like the fundamental intent of these documents, why they exist, it changes your worldview of standards a little bit, about why we see some of the problems that we see, why the supply chains are set up sometimes in the way that they're set up.

Simon:

Um, because we can't. You would take something like ventilation is a really good example of that, something with so many confounding factors, like natural ventilation, where we don't know what direction the wind is going to be, we don't know how hard it's going to blow, we don't know how many people are going to be in a building on a given day, we don't know exactly where the air paths or leak points are within a building. Yet in a document we've got to try and provide a tool for somebody to say how big a hole I should put in a wall and where it should be, and that number is taken as a benchmark. Yet when you think, when you systems think that through, there's a lot of very broad assumptions that go into that very precise number.

Peter:

And that's a challenge, isn't it?

Peter:

yeah, yeah, yeah, that's the challenge is is we're writing a, we're writing a standard that's meant to be applied to all homes or in in all homes in normal circumstances, we say, yeah, um, uh, so, so. So if you're building a home that that broadly fits with uh the circumstances for for which the approved document standard is written, we've got to put a number against that, but it will have all those assumptions against it, and I think, and I think possibly there's been a slow but steady cultural change in uh in the construction sector, probably over the, probably even before the time that that I started working in it, where I think people are uh are less likely to have a professional doing a ventilation design that's willing to go against what the approved document says or that takes its own path, and I think that's not something that I think is desirable. Actually, I think the approved documents should be seen as guidance, which is what they are. It's guidance on how to let's take approved document F guidance on how to, in normal circumstances, construct a building that's going to be adequately ventilated, but there are lots of other. There are lots of other ways that you can ventilate a building and I think if people were were willing a bit more to to go back to first principles and to um to present alternative solutions to billing control.

Peter:

I think that would be really beneficial and that's possibly part of the evolution of the approved documents. That's maybe missing in some respects now is that I think in the past you would have had that innovation, you'd have had a bit more of that innovation, and then the next update, the next revision of the approved document then adopts that innovation as the new minimum standard, because that's been out there, that's been proven and it's been tested. That's been out there, it's been proven and it's been tested. But it's my personal feeling that I think people are much more or much less willing to take that risk of doing something different and rely very heavily on what it says in the approved document.

Peter:

It would be nice if that culture shifted a little bit actually and I think it will.

Simon:

From a personal perspective, I think the way the built environment is moving and our ability to measure outcomes in ways that we couldn't have even conceived 10 years ago will fundamentally shift that perspective. I think a little bit. We've seen that with energy. Our ability to much more precisely understand the performance gap when it comes to energy use in buildings has changed, I think, a little bit. Where those risks are taken that people can are making their own decisions and are prepared to be accountable outside of guidance more and more.

Simon:

Air quality, of course, is very complex and very difficult to measure and there's a lot of things beyond the building that impact it. So it's very difficult to stand over an air quality outcome as a designer because so much of it is outside of your control. But there's certainly no excuses from a ventilation performance perspective to be able to stand over outcomes. You know, largely speaking air movement is measurable. We should be able to make the decisions to say look, this is what we decided we want. So I think we'll see that cultural shift.

Simon:

But it is that and you must have had this conversation over and over again that the fundamentals, the philosophy behind what is a minimum standards premier fascia document for is it the target or is it the backstop? You know, and in a, in a construction sector with a supply chain, there's always that friction of well, you tell me what I'm supposed to do and we'll do that as fast and as cheaply as possible because we're under so much pressure. The other direction there's always going to be. That friction isn't there with standards and codes of practice and guidance that people are looking for, a toolkit, an answer to say if I hit this number or if I do it that way, that's my accountability covered.

Peter:

You know, I've done my job yeah yeah, yeah exactly, and and uh, I've always been clear, and and I'm sure the organization would be as well, that the approved documents are a minimum standard, uh, and if people go beyond that, that's fantastic, you know.

Peter:

But I think what you've said is is really important actually is is that, as much as we might like people to go beyond the minimum standards when it comes to, when it comes to house building, I think because of just because of the way that the house building market works, in that, you know, you'll have a um, there'll be a plot of land, okay, and house builders will bid for that plot of land, and whoever can pay the most for that plot of land gets the plot of land and can build houses on it.

Peter:

How do you bid the most for the plot of land? It's, frankly, by building houses with the best profit margins, and that's not a system that encourages people to go beyond minimum standards. If you want house building that goes beyond minimum standards, you're generally hoping to have a progressive landowner who insists on higher minimum standards at the expense of getting as much value for their land as they can. So, as much as we'd like people to go beyond minimum standards, there is that just fundamental way that the house building market works. That doesn't necessarily encourage that kind of innovation and investment.

Simon:

Yeah, and there's a nuance to it as well in that you know, what we don't want to end up in a scenario of is that there's a, a minimum standard, a calculation that you need to get over the line of, and you just double that. As long as there's no major cost implications to you, I'll just double those numbers. So I know I'm not going to get a call back or be held accountable for being below that minimum. Um, with something like ventilation that has an energy impact potentially, you know so. So what we don't want to see equally out the other side of it is to say, well, look, I need to get over x to be compliant with the guidance document. I'm just gonna add 50 to that to make sure I don't get that callback. You do that at a large scale in house building and there are some unintended consequences of that approach.

Peter:

Yeah, To be honest, I would see the forces there acting in a different direction, because I think, for a house builder, what are they going to get callbacks on? And when it comes to ventilation systems generally, it will be householders who are upset that their ventilation system is making too much noise, and we've certainly seen from some of the studies that we've done in the past a culture of installing and commissioning systems to reduce the amount of complaints that you'd get from householders, particularly from fan noise.

Peter:

But that's obviously not a ventilation first or a ventilation led way of commissioning and designing a ventilation system. It really has to do both and that's quite. That's quite difficult actually making. Installing and designing a ventilation system. I say it's quite difficult. Installing and designing a ventilation system, I say it's quite difficult.

Peter:

Installing and designing a ventilation system that gives you enough fresh air but also isn't noisy and works for the householder needs a level of understanding from the installer. It needs to be designed. I think that's the first point is that a lot of these systems isn't designed. I think that's the first point is that a lot of these systems isn't a design. It's a notes on a drawing somewhere and the installer has to figure it all out and that's not the way that you're going to guarantee or make it likely that you're going to end up in a situation where you've got a well-designed ventilation system that meets all its purposes. So certainly, like I say, in the past we've definitely seen that commissioning for noise, turning fan speeds down to reduce householder complaints, but at the expense of good ventilation.

Simon:

Yeah, it's a really good point that you make and I think that there's two parts for me with guidance documents. There's the intent of the document. Is that clear to people what the document is for, how it should be used and interpreted so that people have the best chance that they have to understand what the regulator wants, what building standards require, so that the policing side of it is as light as possible? And one of the things that I know you spent an inordinate amount of time, particularly in the last couple of iterations of the building standards document, is refining the plain English nature of that document and trying to both restructure it and reword it in a way where that intent is as clear as possible.

Simon:

Because traditionally, particularly approved documents and guidance documents are hard going. I mean ventilation has always been one of the easier ones, to be frank. I mean the poor sods that have to wade through Part B I always feel very sorry for because there's so much interpretation required within them. But Part F is probably one of the easier ones, ironically, but even still, people have found them traditionally very hard going and the the I think my view anyway is that the latest iteration of of adf is probably one of the most well-written guidance documents that I see within that the islands of the UK, scotland, wales and Ireland in how it's set out so that somebody with relatively low technical experience can navigate that document and have a sense of what the intent is. Yeah.

Peter:

I'm glad. I'm glad because, like you say, I spent a lot of time. I spent a lot of time on that document. So when I and this was years and years in the making when I first joined MHCLG, I picked apart the entirety of approved document F and rewrote it from scratch, which doesn't happen very often with approved documents. What you find with old approved documents is every approved document has a lead author, and they still do. But I think what you found in the past is that a number of the approved documents so there's an approved document for each part of the building regulations, as you know, from part A structure to part S electric vehicle charging Each of those approved documents you could tell who'd written it because each author had their own style, and in the mid-2010s we did a lot of work with our publisher actually, in trying to develop some common principles to try and standardize the way that those approved documents are written, try and make it much more plain English.

Peter:

I think approved document F was a technically sound document.

Peter:

I think the previous version was the 2013 version, I think, but in a lot of respects I think it was written a bit like a textbook with lots of background information, and I came into the department and I'm looking at a landscape in ventilation where the big challenge isn't necessarily the technical requirements of approved document F themselves, it's compliance and it's checking.

Peter:

So it's getting people who are installing ventilation systems to be able to understand what it is they need to install and what the performance needs to look like. Getting building control to be able to understand what it is they're checking and to see whether it's compliant. And getting a household and I think that the panacea is that a household will be able to read the approved document and to know whether they've got what they should have got from the person who was carrying out the building work. So we actually stripped quite a lot out of the approved document. Indeed, these things tend to grow over time because you add more and more things. Yeah, but we stripped a lot of the background, descriptive stuff out of the approved document, which was all very, which was all valid and it was all right but my philosophy was really what do those three different parties need to know the person installing and designing, the person checking and the householder.

Peter:

Actually, they don't necessarily need to know the background of ventilation principles. You can argue that some people in that chain should, but they don't. But the approved document, I think, has a specific purpose which is there to try to try to maximize the chance that that ventilation installation and design is going to lead to good outcomes for the occupier and I think it being absolutely clear in its purpose and what the standards are I think is more important than some other things, think is is more important than than some other things. Another interesting thing we did with the approved document was to the. The previous standard approved document F had lots of different tables. So when you were doing a natural ventilation design you'd look through all these tables. You get to a different part of the table. It would tell you your total ventilator area for the building, um, which was, which was very precise um and and was was sort of academically the right answer. But we took that away and and thought actually is that you know, however many pages in the approved document of different tables and cross-referencing.

Simon:

And the notes and clauses which you had to understand, to understand where and when to apply bits. Yeah, it gets complicated right quick, doesn't it?

Peter:

Yeah, yeah, quick, doesn't it when you yeah yeah, so so was that? Was that too complicated to to think that all those parties would install and check things and and know whether they've got the right installation? Could could we actually maybe even compromise a little bit on the on the flexibility of the standard, because that gave you lots of different ranges of triple ventilator areas. So we made the decision to try and just standardize it as this is the ventilation provision you should have in a bedroom. That's it, one figure. This is the ventilation provision you should have in this type of room rather than having to cross reference lots of tables and that might mean that you might have a slight over provision of ventilation compared to the previous system.

Simon:

yeah, but practically you're. You're drilling down into that philosophical question of who's this document for, yes, and what's the most likely route to a decent outcome. And the reality of it is, if a builder who's dipping into a toolbox because he doesn't, doesn't naturally know what the answer is, has to be able to reference that information easily, and somebody coming along behind them like a building control officer has to be able to understand if that's been applied correctly. And a homeowner, potentially, as you say, all the way downstream, needs to be able to look at the, the product that they've ended up with as a whole and understand to some level whether they got what they paid for. Um, if, if there are too many formulas and tables behind that, it makes it very difficult to get that outcome ultimately. But but that's I mean that's a really interesting.

Simon:

It's a really interesting philosophical point for, with these layers, who those documents are intended for, not just the intent, the technical intent, but like who are they intended for and the requirements that have to sit somewhere anyway. So, for example, you can only take the plain english. So far, I guess. But at some point there are standards behind the language you use in guidance documents, things like shall and should, and all of that good stuff which there are various iso standards for, um, there are.

Simon:

There is a playbook here that you have to follow at some point. So you've got this balancing act between your obligation as a standards authority to present stuff, stuff technically correct from a language perspective but make it readable so it doesn't turn into and I'm sorry, scotland, the scottish building standards wedge, where you just end up with this behemoth of a document that gets very difficult to navigate through and you know itemoth of a document that gets very difficult to navigate through and you know it changes and you can't find where very difficult to see where that change is. You've got a balance. It none of this stuff happens in isolation, does it no?

Peter:

no, no, no, no, exactly, and, and, and, like you say, uh, we've plain English edited approved document F as we have done for other approved documents.

Peter:

There's other approved documents that you get to go through the process, actually, but approved document F is one of the front runners is one of the front runners, but, like you said, there's also a process of making sure we're very precise with the language that is used and we have our own internal protocols of when you should use the word should and must and things that you would never even think about, like the use of the word may, things that you would never even think about, like the use of the word may, yeah.

Peter:

So a lot of the proof documents in the old style would say the designer may do this, for example, and that's a very ambiguous statement because may actually has two meanings.

Peter:

Yeah, a statement because may has actually actually has two meanings yeah, the the designer might do something, or the designer is permitted to do something, and, uh, and and, and, if you, if you open up one of the old approved documents and you just control left and search for the word may, it, it, it can pop up all over the place and then, and then you read it with that new perspective and think, actually, I'm sure the author, you can see what intent the author had. If you try and read it from the other perspective, you can come to a completely different conclusion. So, yeah, so that that um, that that plain english, all that logic, checking uh, is, is, is a, really is a really important part of the standards making process. And and uh, I really I really enjoy it to me, as it probably sounds really dull to a lot of people, um, but but coming up with a, with a product that's um, that does its job really precisely and well, I think is um, is is really satisfying to me yeah, and I, and I get that completely.

Simon:

I mean I, you know, I'm a, a systems thinker and you know a document like an approved document sits in a point of time in history in context of where the sector is at any given moment. So it's framing and it's and it's it will be viewed differently as time moves on. So it's a fluid it's within a fluid process, it it has a particular purpose for particular people and very small changes can have systems impacts downstream that are, without spending real time, buried in that document, and those industries are very difficult to foresee. And you know, and I'm, I, I stay in lane, I'm a ventilation and air quality person and, yes, you know, I look at standards in many different countries, um, but even something like adf, which I've been reading for years, as you can imagine, um, you still reread sections of it because you're asked a question. You go.

Simon:

You know, I never thought it would be viewed like that. Actually, that's a really good point. There's a consequence of that. Or where did that number actually come from? Why are we saying that? And what would happen if we thought about that differently, thought about that differently? You know those when you're deep in those documents, as I often am and I'm you're up to your neck in it. I imagine that is very interesting because you you find these nuances constantly. You know it's very difficult to make a perfect document in that sense, yeah, yeah absolutely and and the and the.

Peter:

I mean you'd be surprised. You might be surprised at how little time of all of the stuff we've got to do we spend editing the approved documents. I think, yeah, I think that's it's probably. I do less of it these days because I've got a reasonable sized team now, but but actually even they probably spend the majority of their time, uh, doing all of that stuff up front to get to the point where we can change standards?

Peter:

um, and I do. I do wonder how it looks to the outside world actually that I often hear frustration from the outside world about how long things take and how long change takes, and I think that's probably quite difficult for people to appreciate. Why can't you just change this in the approved document? Why do you have to wait for the next review?

Simon:

I think people get a sense that there are consequences to industry. That requires a process of public consultation. And you know the consultations are a processing of themselves. You know somebody's got to sit down and reimagine certain elements of it, write that down. There's an internal process that goes on you know I've been involved in those as well and and then it goes out to public consultation and then that has to be reviewed.

Simon:

Somebody at some point has to make you know so, like I think people get, that those things can take a year or two to work through, particularly big documents or changes that are going to have big consequential impacts. Yeah, but you've described to me in the past as well there's a lot of stuff going on in the background outside of those consultations where you're having to systems thing, impacts on public health, safety, the financial implications to the exchequer of a certain thing, a single document. I imagine there's a whole bunch behind it in the back office that you have to process and work through. That this stuff does not happen in isolation, that you have to present a case for almost every change and try and work through some of the downstream positive or negative impacts of that yeah, yeah, exactly, so so I think there's there's.

Peter:

If you look at the process of updating government guidance on on the building regulations, um, I think I think you can take it way.

Peter:

You know, if we take it way further back than the point where you'd ever get to a consultation, yeah, you'd look at.

Peter:

So I I'm looking at.

Peter:

You know, one of the main things I look at is simply where we're spending our resources.

Peter:

So I have a team of 12 people who are great, but they're looking across all of the different parts of the building regulations aside from fire and structural safety, which sits in a different team from from moisture, um, through toxic substances, energy efficiency, ventilation, um, drainage and water, electrical safety, right the way down to, uh, electric vehicle drive points. So so we've got to. So there's a point where we've got to decide and plan out how we spend that resource, how we spend our limited research budget and limited bandwidth and, like you say, we can't whimsically change individual parts of the guidance or the regulations because of the impact it has. I really strongly think this is writing building regulations standards is is one of the most influential chops in government, because these homes these homes hopefully will last for generations and we do have to account for the impact of any changes that we're making to standards, of any changes that we're making to standards, like you say, where it's relevant, we'll quantify and monetize health impacts.

Peter:

Generally, when we're updating period documents, we'll be monetizing benefits and of course, we'll have to monetize the costs as well. And then, generally, when you're talking about building regulations standards, the largest costs land on the house builders and there is a consequential effect on the economy. Construction accounts for about 7% of the economy, but also governments of any colour, over the last however long you go, have always wanted to build homes and there's a large reliance on the private sector to build homes as well. So we do need to quantify where we're adding regulatory burden, quantify the impact that's going to have on house building rollout. We want to be a proportionate regulator and make sure that what we're doing is proportionate regulator. Um, and make sure that what we're doing is proportionate, and that does involve a lot of work to um to quantify all of that and demonstrate proportionality.

Peter:

Um, and there's a whole government machine as well, uh, to to work before you can even get to a consultation stage. Um, we are the building safety regulator. Is is arm's length from central government and that's great and I have much more freedom now to decide how and where we spend our resource and our research budgets than we did previously, when we were sitting under a minister. But ultimately, the approved documents and the building regulations themselves still need to be signed off by a minister. So there is still that check and I think that's you know. You can argue that's right. The ministers are the people who are publicly accountable, not us as civil servants. The civil servants. So, um, uh, but, but, but but that yeah, that that can take a lot of uh of time and and research and and we've got to work with working groups. There are so many interested parties as well that there's there's always the risk with any change that um, that there'll be winners and losers.

Peter:

Um and I think we've talked about it in the past, haven't we as well where we can change one line of a guidance document that might seem innocuous, but actually that's somebody's whole business that's affected by that. That's affected by that. We can. You know, it makes and breaks businesses the guidance documents that go along with the building regulations. So we have to be really careful about the impact of our work, which is one of the reasons that there's such a big process. But it's that, yeah, it's, it's, it's, it's all. It's all there for it's all there for good reason yeah, and if it was easy everybody would do it.

Simon:

Uh, and it's, it's also, you know, important work, you know. So it does need to be thought through. Is your sense, is your sense from within that you know I'm speaking to your World Ventilate Day that ventilation and air quality has ratcheted up the importance level within these standards and guidance documents, that it's taken more seriously now perhaps than it was 10, 15 years ago as a fundamental pillar of the built environment. Have you seen a growing recognition in the importance? You certainly see that in the intent of the document and the importance it places on measuring and checking. But within the kind of the government circles and the civil service machine, do you get a sense that ventilation and air quality is has moved up a little bit?

Peter:

I think air quality and the quality of people's homes um absolutely has, has has risen, uh on the agenda and in the last, in the last few years, um, particularly in the social rented and private rented sectors, but that applies to building regulations as well. So there's definitely more interest.

Peter:

There's more parliamentary interest as well, which, to be honest, has helped ministers of various different persuasions to understand the importance of ventilation and indoor air quality, but it's hard for ministers actually to sometimes to be able to find the time to focus on the stuff. They've all got very wide ministers have always got very wide portfolios that cover a vast number of things and something very technical and detailed like the standards for ventilation, the approved documents, documents, um. Actually, really, minister's role is is we're, we're there to support, to support ministers, and support the government's agenda, um, and and that, and that definitely includes um building homes that are of good quality, uh, and that are safe and healthy places to live, um, and so, yeah, absolutely we've definitely seen, uh, definitely seen that rising up the agenda over the last, the last few years and one of the things we've seen a real shift in, particularly in the guidance documents over the last few years, is an increasing emphasis on testing and performance.

Simon:

Uh, and that's been quite clear, whereas before it was more about this is what you should be achieving. There wasn't much about the process of how you check that that's what you've got. That's been a real shift, hasn't it, particularly in the last revisions, and I and I think, if the consult as the consult, we're out of consultation at the moment and again there's, you know, potential shifts there as well that there's a growing recognition on the importance of it's about what you've got, not what you said you'd give. Um, yeah and that. But that is a big change for industry because at the moment currently there's very little testing of the performance of those systems. As much as we've been saying you should commission ventilation systems, for what is it now? 10 years or so? Um, there's very little of that actually happening meaningfully. Um, whereas the guidance documents now is really, really screwing down on that and saying like this is this is what we expect to be done.

Peter:

Yeah, yeah yeah, so as you know, we updated Approved Document F in 2021. We consulted as part of the Future Home Standard consultation, which ran from late 2023 and it closed in January of this year. As part of that consultation, we've proposed another update to approved document F in certain respects. Like we said earlier, we've already taken a fundamental look at the air quality principles behind approved document F and I think this iteration is looking at ways that we can improve the compliance and actual realized performance of systems. So there are a number of proposals in that consultation that aim to achieve that. There's some additional testing requirements in situ. Testing requirements in situ, but also what we tried to do is to put some extra guidance in there about the competency of the people carrying out the work. So, if you look at approved document P, okay, for example, which is electrical safety it's not that different in the way that it works from approved document F.

Peter:

There's a functional requirement and this is how you achieve that functional requirement for electrical safety, in the same way that there's a functional requirement for ventilation safety.

Peter:

And yet we often get the question well, people undertaking electrical work need to be qualified and people undertaking ventilation work don't.

Peter:

But that's only the case because of a cultural view of these systems and we're lucky enough to have a fairly professionalized electrical safety sector with well-established competent person schemes and building control bodies who will take it quite seriously if somebody tries to do an electrical installation but doesn't have the right qualifications, whereas on ventilation the structures and the regulatory systems are similar but there's certainly not a culture with a long history in England of people having qualifications to install ventilation systems and probably not a culture of building control taking it as seriously if somebody unqualified is installing a ventilation system. So one of the changes we've made and it might look quite subtle to some people, but we've tried to put some more guidance up front to say these are the additional checks that you should be carrying out if somebody without the right badge is installing a ventilation system, because that is a risk. I mean people don't have to be qualified to install ventilation systems. You can install a fantastically performing ventilation system without being part of a competent person's schemes, but it should, in my view, mean that your building control body is uh is is seeking additional uh evidence from you to make sure that they know your ventilation system is compliant, in the same way that they would for for for electrical safety yeah, and it's all.

Simon:

It's always dangerous drawing analogies between trades, but you know, nonetheless, we've got a history in this part of the world of trades and qualifications and skills in things like electrical works, plumbing, gas, all of these things that sit within the mech and the lek world. And ventilation, just by the nature of where it's come from, historically, has effectively come from a few holes in walls and an electrician chucking the odd bathroom fan in in the mid 80s to now them being a fundamental pillar of building performance. And the reality is is we simply don't have events, you know, certainly a residential ventilation trade out there with associative qualifications. So it's, we are a product of where we've come from. That's not necessarily by design, it's just where we are, the. The challenge is is how do you navigate that through standards, documents and I think what the? What the documents are trying to do and it's an approach I often talk about with clients is it's very hard for us to have control of the middle ground, but what we can control is the competency of design and the intent of design. What are our expectations about the accountability of the person that's deciding, whether that's designing a full mvhr system for a house or actually just simply making a choice as to what bathroom fan to put in your bathroom when you're getting it replaced. What is that bookend? How do we create accountability around that? And, at the other end, how do we create accountability over the performance of that product and did it meet the design intent? And so, to some degree, you can let the the supply chain sort itself out in the middle without getting involved in the whataboutery of which fan you should be installing, what the performance of x, y and z is at the end of the day, which fan you should be installing, what the performance of X, y and Z is at the end of the day. If someone's accountable for the design and what you expect and you check that that's what you've got, the middle probably sorts itself out to a large degree.

Simon:

And the reality is ventilation won't blow you up, doesn't leak water well, shouldn't it has.

Simon:

But generally speaking, you know you don't get calls on a saturday afternoon that water's pouring through the ceiling because of ventilation systems and it doesn't tend to electrocute people. You know it's. It's a there's a different level that the challenge with ventilation is that it's the single largest environmental risk we face as a human species air quality and the impacts are felt 30, 40 years down the road when we get it wrong. So while you may not there may not be fires and damp and mold or structural failures or water pouring through ceilings the damage can be equally as profound. And I think that's the problem that we've got is that that competency is based on a deferred risk. That's just not been that visible up until now, and I think that's been the change within the built environment is that we're starting to recognize that hang on a minute, while I might not be having water pouring through my ceilings that the impacts of poor ventilation are equally as profound. You're just not going to see it in the same way, and that's the challenge.

Peter:

And, like you say, ventilation in a building that was built in the 1970s probably happened by accident and we're increasing air-tiny standards and insulation standards for buildings. We can no longer rely on that accidental, incidental infiltration of buildings to make them healthy places to be. It's a system, uh and and it needs some understanding and uh and it needs to be designed and it needs somebody in the in the construction process uh to to take account for it.

Simon:

basically, yeah, no, I agree, I mean it might. It might be a bit of a a philosophical question to ask you, but some, some things won't change. I think some things will have to stay the same. There always has to be the law, the regulations, that the legislative aspect of standards, that I think that there will always have to be guidance documents or codes of practice or approved documents to help frame that law in a way where people understand the intent behind that law, in a way that they can apply it. But but I've said this to you before in in 2024, the way we absorb information is not 50 page pdf documents anymore. Yeah, right, and the the.

Simon:

The question is, I suppose, what happens next? And is that the place of building standards to be imagining that or writing that new wave of information? Or is it? Should it be structured in some other way where other organizations like SIBS and the BIS and those kind of industrial organizations fill that void? Fill that void. But there's no question, you know, the trades and the professionals coming through now absorb and learn information in very different ways and our access to information and how we use those toolkits are very different now than they were even five or ten years ago. Is that something you're considering in your kind of longer term view of how standards are constructed?

Peter:

Yeah, it's absolutely something that the regulator is going to look at in the longer term. We won't change things overnight but, like you say, I think that a system where we're writing documents that are either printed documents or a PDF I'm not sure that that's really the way that people on construction sites these days are interacting or want to interact with something to tell them how to do something. So there is a sort of longer term intent to look at some of the fundamental principles behind the standards. Should it be a PDF document, like you say, or a printed document? What's the role of government in writing guidance and what's the role of industry? My personal view is that government's always going to have a role in writing guidance, but that industry can take a greater role in some respects and there are some good practice examples actually in some areas, and I'll take the IET.

Peter:

I'm going back to electrical now, the IET's on-site guide for electricians. I think it's fantastic and it's a little booklet like that that an electrician can flick through and find the relevant bits of the building work, the building regulations and the relevant parts of the guidance to help them understand how to do a particular job. Maybe that kind of document wants to look at a digital future. But that's a good example of some industry leadership there, actually, in trying to distill the information that's in the approved documents, because if you're doing building work, actually you need to comply with all of the different parts of the building regulations. If you're doing building work, actually you need to comply with all of the different parts of the building regulations.

Peter:

I don't think it's. You know, I can't be naive and think that somebody installing a ventilation system in an existing building, for example, is going to read through probably thousands of pages of building regulations guidance to find the relevant bits. It's just it's, it's just not going to happen. So so I think that there is a, that there is a modernization exercise that will be valuable, and to look at what digitalization could could be valuable as well. But, like I say, I, I think, I think there is a role for industry as well in in helping people to apply uh to, to apply the standards in the way that they're intended, without without relying on everybody having spent months and years reading through documents to find the right bits.

Simon:

Yeah, no, I agree, and I think both can be true. You know, I think industry will always step in and there are some excellent guides for different aspects of things. The challenge is how that's coordinated and to make sure that there aren't gaps and that it's done in a way that feeds into the latest. You know framing from standards and the regulator and I guess, interestingly, I mean to bring it back to the HSE. The HSE has got a long history of not just the law and the guidance but also a lot of supplementary information, different ways of communicating.

Simon:

You know, think of health and safety at work, um, all sorts of posters, campaigns and badges, and you know stickers and information material and you know they've worked very hard over the years to try. And you know whether it's farm safety or building safety or whatever it is like that there's a whole infrastructure within the hse of communicating risk. Yes, and this is what it's about. You know it's about risk communication, both construction risk but also health, longer health term risk. There's a lot of, there's a lot of uh dots be joined, I think, potentially going forward.

Peter:

Yeah, yeah, and I think there's a lot of untapped potential there for my areas of work facing and public messaging machine that we have used for communicating messages around high-risk and high-rise buildings, for example, and the new regime that's coming in but perhaps we haven't yet used to its full extent when we're talking about the technical aspects of the building regulations. So that's definitely an area potentially for future and looking at how, how government and the regulator can get messaging out there about, about, about building regulations compliance and that, that and that looks at all buildings and that looks at all of the functions of buildings, including air quality and all of the other standards stuff that we do Because, like I say, it's not just fire and structural safety. There's lots and lots of stuff that we do as an organisation to try and improve the standard of buildings.

Simon:

Yeah, from a ventilation perspective. What's your sense of what the what next is for standards in that sector? Like you say, not a lot has materially changed in the numbers, let's say in the standards. We're pretty confident that they're broadly where they need to be. You're shifting the dynamics on performance checking and control and skills. Where does it go next, you think? Are you looking at things like ongoing performance and maintenance and things like that, or so, the, so the um, I mean the.

Peter:

The very next thing that will change is uh, is implementing uh, or at least responding to the government consultation that was carried out that we talked about, that concluded in January this year for the ventilation standards, I think. Beyond that, we are we're doing a research project at the moment, actually, on looking at health and indoor infection and the interaction between that and ventilation. When we did the 2021 standards, that was, we were sort of coming out of the COVID pandemic, or at least the peak of the COVID pandemic, and because of that, we included some guidance and might not be that widespread that this is not. We included some guidance in the non-domestic standards about how to reduce the risk of uh, of airborne infection, in offices, and you could apply that to other similar types of buildings. Frankly, we had to do that in quite a rush, as you can imagine. Um, there's a global pandemic going on yeah, I was gonna say you and everybody else on the planet.

Peter:

Yeah, there was a there was a whole flurry of of research going on that none of which had come to uh come to fruition really, um. So so we had to make our best estimates, essentially, essentially, on what was going to be a proportionate and useful set of standards to make for these types of buildings. We included for the first time in building rigs requirements to install air quality monitoring, so CO2 monitoring in non-domestic buildings. So co2 monitoring um in non-domestic buildings. So what we've decided to do in the last, in the last year or so since we've got here, actually is is to to say, okay, we made those changes, um, but let's actually and this is sort of a little bit back to front, actually let's look at the underlying science and the evidence to make sure, one, that we've got that right and we've got that at the right level.

Peter:

But, two, to look at um, to look at opportunities, uh for improving indoor air quality, with a focus on uh in infection resilience, uh in future, and that's and that's not just a covid thing either um, having healthy office places where people aren't spreading coughs and colds around uh should, should be beneficial um, you know, regardless, um, so that, that, so that's going on and that and that, and that is one of the real benefits again that we found of being at the HSE, because the HSE carried out lots of this research during COVID and have some great health expertise. I've already done lots of studies on things like UV filtration and the effectiveness of ventilation in reducing infection spread within buildings. So that project's ongoing and, yeah, it's not at a stage where we can share stuff yet, but I'm hoping we'll be able to publish that in the new year and I think that may well be the basis that we build on the next version of regulations and guidance.

Simon:

Yeah, and I think that follows an international trend of you know we've seen standards like ashray 241 um being produced that are trying to create and understand, you know, infection resilience in buildings and you start to introduce interesting concepts we've never really had before, like equivalent air change rates. You know, if you're not actually exchanging outdoor air, are you doing something that's equivalent to that with air cleaning and filtration? Looking at things like the modes of operations of buildings, are there different modes in different infection risk profiles that might mean a building operates differently from one time to another? I think all of these, I think what's great about all of those conversations is it makes us rethink. Some of those basic numbers and basic principles of ventilation go actually, you know, in the context of something like a global pandemic, really makes you rethink. You know what a building's for. You know, and I think that's interesting. Yeah, I mean what.

Simon:

One of the interesting things that must be on your horizon as well is the environmental data we're getting out of buildings as well and the impact that has on reframing. What an outcome is. You know, the building standards are typically being based around ventilation performance, based around ventilation performance, but increasingly we're able to see through things like CO2 monitoring, actual air performance in spaces or air quality performance, and that changes. And you started to do that a little bit in the annexes of the building standards, started to define pollutants a little bit more seriously, but that's got to be a trend that's going to continue. I guess over the next few years is increasingly will start to determine outcomes based on an air quality outcome as much as whether or not it did half an air change an hour or 10 liters a second per person. It'll actually be more about what was the result in that space. Yeah, yeah.

Peter:

Like you say, it's maybe hidden in an annex of a proof, document F, but at least we've set out the parameters to say this is what we think the indicators of good air quality are, and these are what we think is a good minimum standard for indoor air quality, and that's what the approved document is there to try and achieve as an outcome. So previously, previous iterations, the approved document basically provided ventilation to control for moisture so that you don't get condensation.

Peter:

Yeah, um, and and and that was always taken as a sort of as a proxy for everything else. So if you control for more, if you control for moisture and ventilation, then everything else is probably okay. Um, but we tested that and looked at that and I think that probably is the case for most things. But like everything in the approved documents, it's based on some assumptions and if you've got particular pollutant-producing activities or furniture or materials in your building, actually that's something that you might need to be a bit more careful about. Certainly the outlier when we looked at all these pollutants was formaldehyde. So really, if you have a building where you've got furniture and wood products that are producing formaldehyde, you probably shouldn't rely on the ventilation standards in approved document F if they're producing it in significant quantities to give you good air quality. Um, uh, actually that that needs to be looked at both at source control but but also perhaps providing um, perhaps even, you know, boost ventilation for the first uh for the first couple of years while these product products are still off yeah, I was.

Simon:

I was going to say that actually In these conversations I've had a couple of times recently has been about again a kind of a bimodal operating setup in buildings that if there's a particular risk, you recognise that and deal with that accordingly, and formaldehyde is a good example of that. In new buildings or recently renovated buildings or buildings that have been recently furished or refurbished, it may well be that the baselines in approved documents you need to be considered in the context of that risk. You know the previous podcast guests and and the evidence certainly seems to be suggesting that we understand a lot more where the harm is coming from from pollutants in the indoor environment and things like particulate matter, formaldehyde, combustion products, no2 and radon and so on. We understand much more, can quantify the risks and particulate matter seems to be heads and shoulders. The big concern and my guess is one of the things that will have to be re-evaluated over the next decade is how we deal with cooking pollutants and background rates in kitchen areas and things like that, that that it presents such a risk in the built environment, particulate matter that and you know yourself.

Simon:

You know that the cooker hood is the least considered piece of ventilation equipment in the home, you know, and in a lot of circumstances you're lucky if it was ever even connected properly. Um, yet it may well be one of the most fundamental pieces of equipment in the home. So a lot of work going on in the States at the moment trying to determine standards for cooker hoods, actual capture efficiencies and air change rates and the kind of things that we need to understand. To set the benchmarks we need to, because at the moment they're largely aesthetical decisions. Set the benchmarks we need to because at the moment they're largely aesthetical decisions. You know, is it a wooden one for my country kitchen or a metal one for my modern kitchen, or the cheapest possible one if I'm chucking up houses? There's very little consideration at the moment for those.

Peter:

Yeah, yeah, and and something that we're very alive to um, historically, the the approved documents have have not really looked at particulates and I've always put them in a too difficult bracket. Um, because, as you know measuring particulates? You don't, you? You can't really differentiate between the bad ones and the good ones. Um, but I think, I think there's there's a body of evidence out there that makes it too difficult to ignore in the next review, I think.

Simon:

And so measurable. Now I think that's half the problem, peter is that we can measure them increasingly easily and accurately.

Peter:

Yes, yes. So yeah, we definitely want to. In the longer term, we want to have a look at cookers. The longer term, we want to have a look at cookahoods. Uh, um, yeah, not not just performance in terms of capture, efficiency and things, but but also are people practically able to to use them? And that's that's one of the things on my mind is, um, uh, are people minded not to turn their cookahoods on because they're too noisy? Uh, could, could we set standards? Could we set standards there, for example?

Simon:

yeah, no idea, and there's a lot of work going on, I think, at an industry level, particularly in the states at the moment, on that um. So I'd say there'll be some good movement in that direction. Um, to bring it back, you know, as we kind of wind up, peter. Um, you've now moved across to the hse. As you said, this first kind of 12 months or so has been getting your feet under the table and understanding how to work with new colleagues and bring your team across. I get and obviously we've had the grenfell inquiry and the the building safety act and all of that happening at the same time. Do you get a sense? Now is the next phase that you're now moving on to, moving on with the workload and getting your head up and seeing what's next yeah, yeah, definitely, that's definitely the case.

Peter:

Um, um, we are, we are plowing our own furrow. Now, on on on projects. I'm, I'm, I think I'd be. It would be naive to assume that, uh, the landscape of things won't change. You know, um, because this is like I said at the beginning, this new regulator and taking some of these functions out of central government for the first time in modern history can't be underestimated how big this is.

Peter:

The Grenfell Phase 2 inquiry reported in early September, like you said, the Prime Minister made a speech in Parliament to say that the government would respond to that within six months. The government needs to get on with that. The Building Safety Regulator is here to support that kind of response and to implement government policy on that. So we will have to wait for the outcomes of that, but I expect that will involve quite a bit more change. But in terms of the project work that we're doing as a team to uplift and to keep the building regulations and standards under review and keep them technically sound, I'd say we're definitely in a new business-as-usual kind of mode now, which is different to how it works in the department and we're able to focus on various different areas that we might not have been able to in the past, but we still, like I said, we still have to work with central government and we're still partners with them.

Peter:

But, yeah, yeah, government and we're still, we're still partners, partners with them. Um, but yeah, yeah, there's, and there's lots, there's lots, uh, there's lots still, to be honest, to to to establish, but lots of work to to be done. Uh, and and, and I think you know, I'm glad for us to be able to have a greater focus on the technical standards themselves. I think that's been one of the changes actually in us moving over here from not being in a ministerial department anymore. We would have, in the past, spent quite a lot of our time the technical team dealing with parliamentary business, parliamentary questions, correspondence to ministers and so on, and I think that had its own benefits in that you've got your technical people there directly interfacing with the minister, but it did take up quite a bit of our time.

Peter:

We're much freer from that now than we used to be. We're much more free now to um to undertake work without having to ask a minister for permission. Um, every time we want to do something, to make sure that it's still in line with their agenda, um, and and and. We're here to uh. We're here to look at things from an objective and technical perspective, and I hope that's going to be a benefit to the system moving forward. There's lots of parts of the building that need attention, and I think this function of government, now being arm's length from the ministerial department, will allow us to continue spending our resources in a way that's going to benefit people the most.

Simon:

Yeah, and I get a real sense talking to you, uh, an enthusiasm for this new period, that that you are able to focus much more technically on stuff. You're out of the political noise to some degree. I mean that accountability is always important, but you are a technical standards writing organization. Your job is to, you know, deliver the best standards that you can. Um, and I get a sense that the hse seems like a really good home for that um, which is great to see.

Simon:

Yeah, yeah, yeah, exactly peter, it's been brilliant talking to you, as always. Thanks so much for taking time out of your busy day to spend time talking on the podcast. I think it's been a really insightful conversation for people on how this machine works, so I thank you for that. Thanks for coming on to the podcast.

Peter:

Yeah, been really great to talk now. Thanks, Simon.

Simon:

Thanks for listening. Before you go, can I ask a favor? If you enjoyed this podcast and know someone else who might be interested, do spread the word and let's keep building this community. This podcast was brought to you in partnership with 21 degrees, lindab, echo, ultra protect and imbiot all great companies who share the vision of the. Thank you.

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