A mission for change

Competence has become identified as the defining challenge for the construction sector in the post-Grenfell era – and one that the Association for Project Safety (APS) is determined to help the industry meet. Its efforts in setting up a register for principal designers and in leading on guidance on the management of competence for companies have been acknowledged by Dame Judith Hackitt, no less, who in September received an APS honorary fellowship (see below).

For APS, the goal is not only to raise standards but to clarify what competence truly means. As Sofie Hooper, deputy chief executive at APS, explains: “People now know that competence means skills, knowledge, experience and behaviours – and the way this needs to be assessed is through a broader process than CPD.”

APS chief executive officer Andrew Leslie adds that confusion persists. “There’s a misconception about how competence is supported, and the constant referencing to CPD I think is a major mistake,” he says.“Competence maintenance is a dynamic process anticipating that the learning will be put into practice and revalidation will be required to maintain competence, but CPD is currently mostly about providing knowledge.”

Hooper acknowledges that the industry has yet to agree the minimum thresholds for assessing competence consistently. APS has therefore been helping to shape that conversation — aligning its register frameworks to national standards (PAS 8671 – principal designer building regulations) and encouraging others to follow suit. 

“BS 8670 provides a framework,” says Leslie. “Each professional body will adapt that framework to marry in with the competences required for their members.”

That drive has taken practical form through the APS Principal Designer Building Regulations (England) Register – a scheme launched in June 2024 to allow individuals to demonstrate competence. 

“Applicants provide evidence of the work they’ve done – their understanding of what’s required of them under PAS 8671. If assessors believe the application is acceptable, the applicant will be interviewed to test what they’ve said against what’s been provided,” says Leslie.

Although take-up has been gradual: 28 have registered so far, with more in the pipeline, APS is using early feedback to refine the process. “We’re currently undertaking a review of the process to align with our experience over the last year,” says Leslie. “We’ll be relaunching the scheme with slightly amended application processes and guidance.”

He adds that APS has been working closely with the Chartered Institute of Architectural Technologists (CIAT), which has its own framework and register, to align procedures — a step that could pave the way towards a common register across multiple professional bodies. 

“The objective,” says Leslie, “is to create the possibility of having a common register of competence-assessed individuals, leading to other professional bodies collaborating towards standardised assessment arrangements.”

Hooper stresses that one persistent misunderstanding is that the Building Safety Act applies only to higher-risk buildings (HRBs). “It’s really important to stress that competence requirements apply across all buildings,” she says.

Leslie explains that the APS framework recognises two levels of assessment – for HRBs and for all other projects. “The HRB applications require additional evidence,” he says. “But competence to practise is based around a framework also delivering against the requirements of the building typology.”

Applicants must demonstrate experience in particular building types and show evidence of how they work within those contexts. “If a designer wants to move from residential to industrial buildings,” says Leslie, “they have to demonstrate they’re competent to do so.”

Alongside the individual practitioner register, APS is helping developing guidance to help organisations manage competence effectively. 

“It’s not about registration of companies as such,” says Hooper. “What we’re working on is a guidance piece that complements the work of the Industry Competence Committee around what the expectations are for organisations when they manage competence of the people under their control.” The consultation for the document Managing Competence in the Built Environment: A Guide came to a close in mid-November.

APS has brought together representatives from across the industry to produce practical guidance. 

“We’ve come together with the industry to work on a guidance piece that will provide practical tools for people to implement those expectations,” says Hooper. “If there is guidance in place, it’s not difficult to imagine that a standard will follow – and that there will be an opportunity in future for organisations to demonstrate that they manage competence.”

Both recognise that competence reform is as much about behaviour as it is about systems “It’s easy for people to do training and tick the box that they’ve done it. But the culture piece – changing the way people behave – is much harder,” says Hooper.

Progress is happening, but not fast enough, Leslie suggests. Many practices, he notes, still treat regulatory compliance as a paperwork exercise rather than a professional responsibility. He points out that under the new regime, where HRB projects have to be signed off at Gateway 2 as designed in accordance with the building regulations before they can move to begin on site, designers must provide far more evidence of compliance than before. 

“The law requires more detail,” he explains. “Previously designers might have seen a note to their specification saying ‘intumescent strips to comply’. Now they have to say what is complying and how. It’s mandatory – designers don’t have any choice.”

That shift also means new expectations for clients, who must pay for the work needed to produce compliant information earlier in the process. “It’s going to have a kickback from clients saying, ‘Wait a minute, you’re wanting more fees earlier in the project,” Leslie says. “But that’s the reality – the regulator needs the detail up front.”

Both Hooper and Leslie believe that APS can help the sector navigate this new landscape by promoting consistent standards of competence and clearer routes to demonstrate them.

“Clients – or shall we say informed clients – are looking for practices where individuals are registered with a scheme,” says Leslie. 

Hooper agrees that the goal must be to give the industry the tools to meet its responsibilities. “We need to ensure that anyone doing any building work or any design work is competent to do so,” she says. “That’s the foundation of building safety – and it’s what APS is here to support.”

Accepting her honorary fellowship at the APS annual conference in September, Dame Judith Hackitt warned that while construction has made real progress since Grenfell, it must now move faster to embed competence and culture change – echoing the call from APS leaders Andrew Leslie and Sofie Hooper for the industry to raise standards across every project.

Hackitt reflected on the long road since her 2017 independent review of building regulations and fire safety. She had expected the shock of the Grenfell tragedy to drive rapid, lasting reform, but said the journey had proved “longer and more complex” than she anticipated.

“Competence was at the heart of my report, and that was also true for the public inquiry,” she said. Both identified the same failings: poor standards, a race to the bottom, and a lack of ownership and accountability. “The similarities in our findings reinforce the need not only for change, but for change at pace – change that goes beyond simply implementing a new regulatory system.”

Hackitt said the culture she exposed eight years ago – of cutting corners, conflicts of interest and casual record-keeping – had caused lasting damage. “People should be driven by an overriding purpose of delivering buildings which are fit for use and safe,” she said.

Despite that legacy, she stressed that progress since 2017 had been “huge” and should be recognised. “We can all point to how much more there is to do, but we must also give huge credit to those who have stepped up and increased levels of competence.”

Her message to professionals was clear: understand how change affects your role and act proactively. “Be in the right place with the right skills, the knowledge and the information now required,” she urged. And while much of the focus has been on high-rise buildings, she emphasised that “the same approach, in a proportionate way, should apply across the sector”.

Hackitt said professional bodies such as APS have a vital role in accelerating progress, but cautioned that true competence “is about more than technical knowledge – it is about conduct and behaviours”. That means not walking past problems, refusing to cut corners, and upholding professional pride. Individuals also need “strong support from professional bodies” to help them demonstrate and maintain standards.

Hackitt warned that, while the creation of new standards was an important milestone, “it is the end of the beginning, not job done”. Professional bodies must now raise awareness among members, promote accreditation and ensure qualifications are earned, not “grandfathered or simply handed out”.

She illustrated the cost of poor practice with a case from the Building Safety Regulator, where a new high-rise building was refused permission for occupation after inspectors found a sprinkler pump unable to deliver water above the 12th floor. 

“The installer admitted to knowing the pump was not the right specification but installed it anyway,” she said. “This is a real live example of why competence has to be about behaviours as well as knowledge.”

Hackitt closed with a warning that some professional bodies risk losing control of standards if they do not act swiftly. “Having change imposed upon you by others, or having responsibilities handed over, is surely not where these professional bodies want to be,” she said.

“We cannot wait for the slowest ship in the convoy to hold others back,” she concluded. “I believe that APS has an opportunity to be one of the leaders in this — and I would encourage you to take that opportunity.”

Andrew Leslie, APS CEO, said: “APS is delighted that Dame Judith sees the association as one of those leaders, helping to shape competence and culture across the built environment.”

I’m on both the APS and RIBA principal designer registers, as I’m an architect by profession. 

Being on a register is a good starting point for evidencing competence, but as a company we go further – maintaining a competence document with individual CVs, skills and experience.

The new requirements are positive but complex. When CDM first came in, it took about five years to bed in – and I think it will be the same with this legislation.

The Building Safety Regulator is also still finding its feet, often subcontracting building inspectors and struggling to assemble competent teams. Even so, the bar for competence is definitely being raised.

We’re involved in a significant number of projects, mostly as principal designer, and handling about 100 Gateway 2 applications. Yet in only about half of the cases have clients asked us to demonstrate competence before appointment. We send our own competency documents, but not everyone does the same.

Any project that must comply with building regulations (England) requires clients to appoint competent dutyholders – not just for HRBs. But many are still coming to grips with the rules. 

Once appointed, we carry out detailed competency checks on designers, contractors and subcontractors – anyone with design responsibility. Technically, it’s the client’s duty too, but often they appoint the principal contractor without proper checks. Gathering evidence can be tricky, as many struggle to provide it.

There’s no single way to prove competence. Certification under BS 8670 is one option, but we also look at project experience, professional accreditations, and quality assurance processes for risk, design management and compliance. 

The new regime is reducing risk, though progress is slow. The ethos is sound; we just need to get on with delivering it properly.

Although competency for appointments has long been a client duty, the reforms after Grenfell have put a much stronger spotlight on this area. 

The Building Safety Act and BS 8670 suite have provided structure for assessing competence of principal designers and principal contractors (building regulations), yet the approach to evidencing competence still varies widely.

While the gateway process has brought real rigour for HRBs, the same momentum isn’t always seen on non-HRB projects. Many clients still find it difficult to assess competence effectively, as the process is often qualitative and there’s uncertainty about what ‘good’ looks like.

At Gleeds, we’re embedding competence through in-house training, refreshed role profiles, and assessment processes aligned to PAS and BSA guidance. Externally, we help clients develop clearer verification processes and expectations for their project teams. I’m also an external examiner for the RIBA Principal Designer Register.

Within the last 12 months, we’re being asked more consistently for evidence of competence, mostly via the client or their representatives. And we often ask others on the client’s behalf.

Upskilling started early: all our technical teams underwent Building Safety Act training. To be serious about competence, the industry needs to understand what it is. A two-week training course doesn’t equate to competence — it’s about skills, knowledge, behaviours and, above all, experience.

Competency requirements for roles such as the building regulations principal designer are still high-level in places, but as interpretations are tested, expectations are becoming clearer.