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How tweaked guidance led to combustible insulation on high rises

A sentence swap in building guidance was hardly noticed but had huge consequences. Peter Apps finds out who was asking for it. Illustration by Sonny Dhamu.  Pictures by Rex Features and Alamy

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The plastic insulation industry supported a quiet change to building regulations 13 years ago which opened the door for the use of combustible insulation on high rises #ukhousing

How tweaked guidance led to combustible insulation on high rises

In 2005, deputy prime minister John Prescott’s office considered a tiny change to the wording of official building guidance and almost nobody paid any attention.

The change – to Approved Document B, the official guidance to rules on fire safety – was to move a sentence on large-scale testing from one paragraph, 11.5, to another, 11.7.

This tiny alteration was to have huge ramifications - opening the door for the widespread use of combustible insulation in cladding systems on high rises across the UK.

So, what was it? In short, the change – as it was finally included in the guidance from 2006 onwards – permitted the use of combustible insulation materials on tall buildings, provided they passed a large-scale test known as BS 8414. This replaced the previous position which had simply banned their use on buildings over 18m in height.

“Once the door was opened in 2006 by that subtle change in wording in Approved Document B, the whole thing just unravelled,” an industry source has told Inside Housing.


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What has never been previously reported is why this change was made, and who was asking for it.

Inside Housing can finally answer that question. After an eight-month wait, which required the intervention of the Information Commissioner’s Office, we have received the submissions to the 2005 consultation on this guidance.

These reveal that the alteration in wording was supported by the British Rigid Urethane Foam Manufacturers’ Association, or BRUFMA, a lobbying group set up to represent the interests of the plastic insulation industry.

This landmark change, in the guise of a quiet tweak to a complex document, must be placed in context to be understood.

This is really a story which begins with the government of Margaret Thatcher in 1985 (see timeline). In that year, the government passed the Building Control Act – which swept away some 300 pages of prescriptive regulation and replaced them with just 24 pages of headline ‘performance’ standards.

In the context of the fire safety debate post-Grenfell, the crucial line was B4, which demands that the walls of the building “adequately resist the spread of fire”.

To support this high-level guidance, the government also committed to publish ‘Approved Documents’. These would contain guidance notes approved and altered by ministers without the scrutiny of parliament which set out how to meet these regulations. They are minimum standards in all but name.

In 1999 what these standards said about cladding and insulation came under the spotlight. This was because of a fire at a tower block in Scotland, Garnock Court, which spread rapidly up the building via combustible window panels, killing a pensioner with disabilities.

A parliamentary inquiry decided against banning combustible cladding systems. Instead, it accepted the recommendation of the Building Research Establishment (BRE) that if combustible materials are to be used to clad a high-rise building, they must be subjected to a large-scale test which the BRE had designed. The newly privatised organisation – until 1997 a nationally run laboratory – would charge manufacturers to run this test on their products.

By 2005, this test – which was set out in British Standard 8414 and became known as the BS 8414 test – was an established part of the system of building regulation. It was a means to clear combustible cladding materials, but it could not be used to give a pass to combustible insulation.

This changed in the 2006 version of Approved Document B. This came at a time when climate change treaties were setting increasingly tough standards for insulation – creating a booming market for the sale of insulation products. The document was updated to change the wording around large-scale testing – to make it an option for combustible insulation as well as cladding panels.

The consultation on the 2006 version of the document ran in 2005. Inside Housing first requested the responses to this consultation submitted from the industry in January. In February, the Ministry of Housing, Communities and Local Government responded to other questions but did not provide this information.

Inside Housing appealed and in mid-August, following a complaint to the Information Commissioner’s Office, the information was finally released.

Towards the end of the BRUFMA submission is the following line: “Paragraph 11.7 – we support the introduction of BS 8414-1 2002 where BRE conducted a test programme to support the introduction of a large-scale test for facades.

BRUFMA was responding to a draft version of Approved Document B, which the consultation respondents were being asked to assess.

 

Listen to a podcast on our major investigation into building regulations below

 

This draft version, available through government archive websites, shows the reference to large-scale testing crossed out in paragraph 11.5 – where it would have applied to cladding materials only – and introduced in 11.7, where it would now applied to insulation.

This change was never listed on the summary of significant changes, nor did the consultation document itself draw attention to the change.

BRUFMA’s support of it – the only response seen by Inside Housing to even mention it – was a throwaway line towards the end of its response in the ‘any other comments’ section.

But its effect would be significant. When the final version of the document was published in 2006, it gave even more backing to the BS-8414 test, applying it to both cladding materials and insulation.

This was not all the responses from the plastic industry asked for. BRUFMA and the BPF submitted responses supporting a document recently published by the BRE titled The Production of Smoke and Droplets from products used to form wall and ceiling linings.

This document, written for the government in 2004/5, assessed the necessity of introducing limits on the amount of smoke and burning droplets which could be produced by materials used in walls and ceilings. All European countries bar the UK and Ireland, the report said, had some sort of standard. While this would not have impacted cladding systems, introducing one would limit the use of plastic insulation products inside buildings.

But the report advocated against doing so. It said the standards would “have a significant impact on product sales”.

“The most demanding option could potentially affect sales with an annual value upwards of £249m,” it said. This was weighed against the impact on safety. “The benefits in terms of lives saved or reduced injuries… are considered to be low,” it reads. “Using accepted valuation techniques… the annual benefit is estimated to be £174,000 per year.”

This was the report BRUFMA, BPF and others from the industry supported. Asked about it this week, a BRE spokesperson says: “The outcomes of the cost benefit analysis in the BRE report (a government pre-requisite to introducing any new regulatory provisions) are a snapshot in time. They relate to the information that was provided/available then. As with any such analysis, the balance of costs and benefits changes with time as they require re-visiting on a regular basis. The results from 2004/05 when the work was carried out, will not be valid today."

The rise of large-scale testing

1985

A new system of national building regulations is introduced for Britain, replacing regional systems in London and the four countries of the UK.

1999

A fire at Garnock Court, Scotland, spreads via combustible materials in window panels, killing a disabled man. At a parliamentary inquiry, a new system of large-scale testing is proposed to clear combustible cladding systems for use. This is introduced, but initially only for cladding.

2000s

A series of climate change agreements leads to new insulation targets for residential properties, leading to an insulation boom.

2005

Official building regulation guidance is quietly changed to permit combustible insulation on high rises if it passes an official test.

2014

The insulation used on Grenfell Tower– Celotex RS5000 – passes one of these large-scale tests when combined with cement fibre cladding. The test would later be withdrawn for ‘inaccuracies’, but Celotex immediately markets the product as “suitable for use” on high rises.

2015/16

The refurbishment of Grenfell fits Celotex RS5000, a small amount of Kingspan insulation and styrofoam window panels to the outside of the 24-storey building.

14 June 2017

A fire starts in a fridge-freezer on the fourth floor of Grenfell Tower, igniting the cladding and insulation and engulfing the building in flames. Seventy-two people are killed.

But without these standards for the inside of buildings and with a new testing regime in place for the exterior, the use of combustible insulation boomed.

The guidance, which used the phrase “assessed from test data” as opposed to assessed from a specific test, encouraged the industry to use combinations of products in cladding systems which had never been tested together.

This process – known as ‘desktop studies’ – was formalised by guidance from the Building Control Alliance in 2014.

That same year, a company named Celotex was able to secure a pass for its polyisocyanurate insulation through the BS 8414 test when combined with cement fibre - a test later withdrawn for ’inaccuracies’. It responded by marketing the product as “suitable for use” on high rises.

In 2016, this plastic insulation was fixed to the walls of Grenfell Tower and covered with polyethylene-cored cladding panels. A year later, the worst fire in this country in modern times killed 72 people.

Did the change in 2005 contribute to the environment that allowed this to happen?

The BRE has always rigorously defended its testing regime. It points out, correctly, that no system passed through a BS 8414 test has ever been involved in a deadly fire. The problems arise when materials cleared through BS 8414 are combined with other combustible products.

Simon Storer, chief executive of the Insulation Manufacturers Association – to which BRUFMA changed its name last year – adds: “We would still support BS 8414 and large-scale testing as the best route to ensure the fire safety of buildings. If the alignment used on Grenfell had been tested to BS 8414 standards it would not have been allowed.”

He adds that BRUFMA was “extremely small” in 2005 and it would be “remiss” to imply that they were particularly influential in lobbying for change to building regulations.

Nonetheless, the government is now preparing to ban combustible materials from the walls of high-rise buildings outright. In doing so, it will be reversing the position supported by the sellers of plastic insulation thirteen years ago

The Paper Trail: The Failure of Building Regulations

Read our in-depth investigation into how building regulations have changed over time and how this may have contributed to the Grenfell Tower fire:

Never Again campaign

Never Again campaign

In the days following the Grenfell Tower fire on 14 June 2017, Inside Housing launched the Never Again campaign to call for immediate action to implement the learning from the Lakanal House fire, and a commitment to act – without delay – on learning from the Grenfell Tower tragedy as it becomes available.

One year on, we have extended the campaign asks in the light of information that has emerged since.

Here are our updated asks:

GOVERNMENT

  • Act on the recommendations from Dame Judith Hackitt’s review of building regulations to tower blocks of 18m and higher. Commit to producing a timetable for implementation by autumn 2018, setting out how recommendations that don’t require legislative change can be taken forward without delay
  • Follow through on commitments to fully ban combustible materials on high-rise buildings
  • Unequivocally ban desktop studies
  • Review recommendations and advice given to ministers after the Lakanal House fire and implement necessary changes
  • Publish details of all tower blocks with dangerous cladding, insulation and/or external panels and commit to a timeline for remedial works. Provide necessary guidance to landlords to ensure that removal work can begin on all affected private and social residential blocks by the end of 2018. Complete quarterly follow-up checks to ensure that remedial work is completed to the required standard. Checks should not cease until all work is completed.
  • Stand by the prime minister’s commitment to fully fund the removal of dangerous cladding
  • Fund the retrofitting of sprinkler systems in all tower blocks across the UK (except where there are specific structural reasons not to do so)
  • Explore options for requiring remedial works on affected private sector residential tower blocks

LOCAL GOVERNMENT

  • Take immediate action to identify privately owned residential tower blocks so that cladding and external panels can be checked

LANDLORDS

  • Publish details of the combinations of insulations and cladding materials for all high rise blocks
  • Commit to ensuring that removal work begins on all blocks with dangerous materials by the end of 2018 upon receipt of guidance from government
  • Publish current fire risk assessments for all high rise blocks (the Information Commissioner has required councils to publish and recommended that housing associations should do the same). Work with peers to share learning from assessments and improve and clarify the risk assessment model.
  • Commit to renewing assessments annually and after major repair or cladding work is carried out. Ensure assessments consider the external features of blocks. Always use an appropriate, qualified expert to conduct assessments.
  • Review and update evacuation policies and ‘stay put’ advice in the light of risk assessments, and communicate clearly to residents
  • Adopt Dame Judith Hackitt’s recommended approach for listening to and addressing tenants’ concerns, with immediate effect

CURRENT SIGNATORIES:

  • Chartered Institute of Housing
  • G15
  • National Federation of ALMOs
  • National Housing Federation
  • Placeshapers

 

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