We don’t have a revolution, but we must embrace reform

Reform is on everybody’s radar and not just on the political scene, but let’s leave the latter to the politicians.

Since the Grenfell tragedy, there has been a mood to reform the way the built environment is designed, built and occupied towards enshrining skills, knowledge, experience and behaviours into measurable individual competence and organisational management of competence. 

Revolution was not considered, although aligning to the Scottish building warrant scheme would have revolutionised building control in England and Wales. The “superior” Scottish arrangements were alluded to in the report Building a Safer Future (Interim Report). These references were not repeated in Building a Safer Future: Final Report. C’est la vie!

Let me reflect on what reform is. Reform is the process of making deliberate changes to improve something that already exists rather than replacing it entirely. At its core, reform acknowledges that systems, institutions or practices are imperfect, but fundamentally worth preserving. 

Reform assumes continuity matters; that stability, order and accumulated experience have value. This suggests an incremental approach, which can make reform slower and more complex, which I think is what we have been witnessing. This approach often results in changes that are more durable and widely accepted. Let’s hope so.

All the above applies to where we are; the industry has embraced continuity with added regulatory controls that overlay the established processes and new dutyholders in the mix. Reform also operates on an individual level as distinct from a societal level. 

Conscientious professionals accept they must change habits, attitudes or behaviours they recognise as flawed. It is their responsibility to change and challenge flawed behaviours. This personal dimension highlights an important aspect of reform: it begins with recognition. 

Whether as a society, an organisation or an individual, reform requires honesty about shortcomings and the drive to improve. It also involves discipline and patience, as meaningful change rarely happens instantly). But for complete reform of an industry to take place, some pre-conditions are still missing – for example, mandating the competence of safety critical dutyholders to see off, once and for all, those who choose the lowest (and presumably most economically beneficial) path.

Reform is not without challenges. Resistance often comes from those who benefit from existing arrangements. There is also debate over how much reform is enough. Too little may be superficial, leaving deeper problems unresolved, while too much can undermine stability and provoke backlash. As a result, reform can be contested, shaped by competing visions of what “improvement” truly means.

Since 2017, there has been a lot of work done to set out the vision for the future, not least through the influence of APS Honorary Fellow, Dame Judith Hackitt. There is currently a plethora of committees and other groupings wrestling with proposed reforms, and quite possibly a danger of parallel groups creating slightly different propositions. 

That is why the APS initiative in gathering most of the key sector players into an Industry Task and Finish group to support the Industry Competence Committee guidance on an organisational competence framework is such an important development, resulting in a single pan-industry collaborative approach supported by broad consensus. The resulting guidance should encourage meaningful dialogue, compromise and collective responsibility.

The four jurisdictions in the UK are taking slightly different approaches to reforming their approach to regulation – building regulations and regulation of the professions. This is a shame because a UK-wide approach would have been preferable all round, although alignment across the nations is being promised. 

Building Regulation reform in England and Wales was modelled on CDM 2015 to a large extent, yet unlike CDM it does not apply throughout the UK. CDM has not been plain sailing, with three iterations to date, but the second review of CDM 2015 – the post implementation review (PIR) – has just been issued by HSE and the conclusion is that this iteration remains fit for purpose. The PIR announcement can be found on page six of this edition and APS will be examining and reporting back on its impact in the next edition of Project Safety Journal.

So, CDM 2015 will not be reformed, but some issues were identified in the PIR that may require adding to or revising L153 or providing further specific guidance. Where reform will touch CDM 2015 follows from the work being done on competence responding to the Grenfell Stage 2 Inquiry Report, and of course BS 8670-1 that outlines core competence criteria for building safety.

The PIR specifically mentions early input in projects from a competent PD and the competency requirements for the PD role. 

This does point to a clarification of appointment of the PD “before construction begins”, which is an obvious gaming opportunity for the unscrupulous, and a structured approach to PD competence. APS members are, of course currently assessed at IMaPS and CMaPS for their capability to undertake broad CDM 2015 duties. The assessment is not role specific.

And so CDM 2015 dutyholders will be touched on in the wider reforms that the post Grenfell era is facing.

A final word on competence: “I hear and I forget. I see and I remember. I do and I understand.”

This saying is sometimes attributed to Confucius (wrongly it seems), but it emphasises that the foundation stone of competence is showing evidence of doing – only saying.

Let APS and our members and registrants embrace reform and continue our path of delivering a safe and healthy built environment for all. 

Andrew Leslie is the CEO of the Association for Project Safety.