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Into the Part L labyrinth
Filed: 20.04.2007
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The H&V News email bulletin this week includes reference to a presumably troubled water treatment industry. "The water treatment industry has accused the Government of not doing enough to ensure installers are kept up to date or complying with Part L of the Building Regulations."

 

Confusion

No one I have met so far genuinely has more than a vague outline of current standards, regardless of how well intentioned the people concerned are. I have to include and accuse myself, given I seem to be constantly researching information.  We are all swamped by a plethora of changing detail. What we have all learned well a few months ago, may no longer apply.

Ironically the same bulletin also refers to the Domestic Heating Compliance Guide (74 pages) published by the former Deputy Prime Minister in 2006 (now Communities). Interestingly all words in the title used as search terms at the Department of Communities yesterday, failed to confirm the existence of that document, though we have it already.

The question is, which Installers are they referring to. That is what I would like to know. The professionals already observing the bulk of standards long before the standards and Part L was first drafted, know well what is required and no doubt deliver what is required by default, including water treatment.

One trade magazine editor was able to agree that the people most likely to side-step the regulations probably don't read trade media anyway. My best guess is that the same trade media audience is largely shared by all trade media.  And that audience is far from substantial in terms of grass roots Installers. No doubt some of that audience also shares their affection with one or more trade or professional associations: The foundation pool of committed professionals is relatively small.

Energy efficiency training

Anyone remember DEFRA and the Energy Efficiency Training courses. The well publicised ambition of the Secretary of State was an army of 74000. Where they got that figure from I have no idea, but we know they have fallen well short. I know of employee operatives who have undertaken the course but for what purpose ?

How many employees are genuinely in a position to influence the essential features of an energy efficient response to a heating and hot water need. Certainly new-build systems are fully designed in advance by experts, often the boiler manufacturer. If water treatment is provided it will be introduced. If it is not,  there will be no protest.

If the Government's ambition was to round up those Installers not in the popular communication loop then clearly they failed. The only common ground for those Installers is the merchant and the merchants have their own drum to thump, which takes precedence always. I recall one major chain heavily advertising non-compliant heat-packs, perhaps to offload stock facing redundancy. Ironically at the same time B&Q were selling fully compliant heat-packs.

Too much

The Government has done plenty to ensure Installers are kept up-to-date. But the 74 pages of Domestic Heating Compliance Guide alone is far too much to consume, bearing in mind that may change or references linked from the document will certainly change.

The volume of data is now so overwhelming that people - we have said it before - simply give up trying to understand it all. They switch off and muddle through.

We were told recently on the forum that the cost of British Standards for ACS alone is £1600. I admit you don't get much paper for your £1600 but who is going to read all that anyway. That excludes one of the worst British Standards to be introduced in recent years, BS 7593: 2006 for Water Treatment.

But even those Installers prepared to try must be a minority. They wrestle with increased costs and cut-throat competition from the army of non-compliant, unregistered Installers and  pseudo-Installers.

Reality

The large majority of Installers and pseudo-Installers no doubt exist in a different world, fitting whatever appliances are required, as and when required. If they want a boiler they'll buy one. If the most readily available are condensing boilers then those will be fitted. The fitting difference is negligible.

For too many in this population, water treatment is the last thing on the shopping list. And the manufacturers cannot blame Government for failing to market Part L.  Water treatment is already a well known option and too easily overlooked.

The problem therefore rests with enforcement. Again, water treatment is the last item on the list likely to be tested by anyone routinely. Certainly not by the new breed of Domestic Energy Assessors or self-certification scheme operators.

As far as I know there is still no definitive test that can be applied to a system with water treatment added of unknown origin. If there was a simple test professional Installers could rely on, that would be a useful step forward.

The labyrinth

Too many easily forget the labyrinth goes much deeper than Part L.  Professional Installers with a wide portfolio are also faced with consents on matters not covered by self-certification schemes. The following chunk of text grabbed from my local authority website, shows a little more of the extent of Building Control interest:

Examples of works that require the submission of a building regulation application:

  • Renewal of pitched or flat roof coverings - e.g. re-tiling, re-slating or re-felting of roofs.
  • Renewal or replacement of ceilings under a roof space or flat roof (with or without the renewal of the supporting structure).
  • Renewal of cladding to external walls or dormer cheeks.
  • Renewal of a finish or cladding to an external wall area or elevation (render or other cladding) or applying a finish or cladding for the first time.
  • Re-building an external wall including the outer leaf of brickwork or stonework only.
  • Renewal of internal wall plaster or plasterboard to an external wall or where plaster or plasterboard is being applied for the first time e.g. re-plastering or dry lining of walls.
  • Renovation or replacement of a solid or suspended floor, involving the replacement of a screed or a timber floor deck.

All those matters and many more have their own compliance guides of sorts.

It could be argued that without standards nothing will get done. But I would argue the existence of standards will have little impact except where there is the most stringent of inspection and no one has time left for that. Building needs control but there is now far too much to control.

I could take you now to recently built non-compliant new homes. Nicely built and they all think they've done a good job but no one in the chain has any notion the outcome is non-compliant. Ignorance, not insolence.

Instead of having the back-bone to ban inefficient spaceheaters outright, they dribble out lame regulations to control their proliferation, in the naive belief it will have that effect, when we all know it will make no difference.

The industry needs clarity, simplification and stability.

 

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