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CROSS Safety Report

Building regulations submissions

Report ID: 65 Published: 1 July 2007 Region: CROSS-UK

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This report has been written on behalf of a group of senior local government structural engineers who refer to previous CROSS newsletters and in particular the reports relating to the poor quality of building regulation submissions and lack of checking resources.

Key Learning Outcomes

For construction professionals and clients:

  • There is always a risk that safety will be compromised when the lowest cost is the main criteria for selecting products, processes or people

  • Structural calculations and assessments should be carried out by a suitably qualified engineer for all structural works

For civil and structural design engineers:

  • Be aware that it is the responsibility of the originating design organisation in the first instance to check the design and there should not be reliance on building control

  • It is good practice to check and validate all design outputs from proprietary design software

  • If you are concerned with any of the output’s, raise this with the software technical support team and seek clarification

Full Report

Find out more about the Full Report

The Full Report below has been submitted to CROSS and describes the reporter’s experience. The text has been edited for clarity and to ensure anonymity and confidentiality by removing any identifiable details. If you would like to know more about our secure reporting process or submit a report yourself, please visit the reporting to CROSS-UK page.


This report has been written on behalf of a group of senior local government structural engineers. The group has been in existence for many years and meets regularly. It was originally established in order to standardise the approach taken to the checking of structural calculations made as part of building regulation submissions within the region. Members refer to previous CROSS newsletters and in particular the reports relating to the poor quality of building regulation submissions and lack of checking resources.

The reporters would like to make the following points regarding the quality and complexity of the structural calculations currently being submitted for building regulation approval. 

Quality of submissions

It has become apparent over the years that the standard of submissions being made has dropped significantly. This has put a burden on the checking engineers in undertaking a safety check. The reporters can verify the following increasing trends:

  • Submissions with no drawings or details

  • Submissions with missing information, many submissions are to a client brief only, i.e. "it wasn't part of my brief to design that"

  • Structural information from a variety of engineers or manufacturers with no co-ordination being undertaken of the design. No one engineer being responsible for overall stability of the building. The local authority checking engineer may provide the only opportunity to assess whether the independently designed elements will provide a building that is safe, and satisfies the requirements of the Building Regulations.

  • Submissions made by an unidentified engineer, which makes it extremely difficult when trying to query the design or chase missing information

  • Increased use of structural design software

  • Trends towards build and design schemes that are contractor led, with restricted engineering involvement

  • Submissions from unqualified persons

Complexity of Submission

It has also become apparent over the years that the complexity of the submissions has become more involved. Reasons for this include:

  • More geotechnical and foundation problems due to the development of more brown field sites

  • More submissions that are carried out on software packages. There are often problems with verifying the methodology used.

  • Speed of response required for design and build schemes

  • Increased complexity of design codes with serious implications associated with the Eurocodes. Eurocodes are likely to increase problems during what is likely to be a lengthy transition period.

  • Many domestic buildings fall outside the scope of the approved document A

  • Increased use of manufacturers' details and proprietary systems. Many checkers assume manufacturers' details to be correct. This is not always the case, and we often have cases where manufacturers have to amend their technical guidance.

There are also instances of incorrect interpolations of manufacturers' details. A recent example of this was the misuse of a lintel. The lintel took the form of an inverted ‘T’, in section and was originally shown in the manufacturer's details supporting a two leaf solid wall, with the web being restrained between the two leafs of masonry. The manufacturer was advising people that this was useable in cavity wall situation where the stem was unrestrained. An independent check undertaken on behalf of the manufacturer found in favour of the checking authority.

The structural checking of building regulation submissions has come under a great amount of pressure in recent years, which we feel has undermined the service currently being offered. These factors are identified below.

Many checkers assume manufacturers' details to be correct. This is not always the case, and we often have cases where manufacturers have to amend their technical guidance.

Methods of design procurement

The abolition of ACE (Association of Consulting Engineers) fee scales in favour of fee bidding has resulted in an over competitive marketplace, which has encouraged a general reduction in design standards especially in relation to smaller schemes. This is evident by the points raised in ‘Quality of submission’ above.

Self financing of Local Authority Building Control

Originally the building control service was a subsidised service provided to members of the public. The implementation of self-financing made local authorities streamline their service. At this point a number of trends started to develop, including:

  • The outsourcing of the structural checking service, with budget limits dictating the extent of the check

  • Risk assessment based checking, i.e. building control departments assessing which applications actually require a structural check

  • Building control officers checking simple structural designs themselves

  • Adoption of standard details

Approved inspectors

Building control departments came under further pressure to reduce costs with the introduction of approved inspectors. There is a concern here as to the level of checking undertaken by ‘one man band’ approved inspectors, especially regarding the structural elements of submissions.

There are numerous examples where the local authority has been called in by clients to deal with problems that have arisen on schemes run by approved inspectors. Two recent examples include timber rafters to a school that were under designed and deflected excessively under dead loading alone, and a gable wall that collapsed under wind loading due to no provisions for tying back to the structure.

Gershon - efficiencies within Local Government

Gershon is being viewed by many authorities as purely a cost saving exercise.

Many of the degradations in service from the self-financing are being compounded through the Gershon initiative.

A number of authorities are now entering into joint working initiatives. This in principle is a good idea however due to the way in which these business units are being established it would appear that the structural checking process is viewed as an overhead. This means that the checking process is now being governed on cost grounds alone with the level of service getting little if no consideration.

Self certification

The proposal of self-certification is a good concept, however many of the smaller designers are unlikely to sign up to this. Many of our clients have expressed the opinion that they rely on checking authorities as the only check on their designs. This is due to the fact that they undertake the work for a minimum fee and have little or no checking procedure internally.

As a result of the above pressures the following trends have now started to develop.

Outsourcing of the structural checking service

This started with the advent of self-financing. This in principle is good as competition reduces costs but where does it stop? Recent enquires into this have revealed that two authorities are having their checks done for £5 per application by retired external consulting engineers. This equates to approximately 5 to 10 minutes a check. This time also includes administration time, dealing with feedbacks, chasing consultants for missing information and reporting if indeed this is being carried out.

In order to keep costs down, practices are starting to use inexperienced staff for this element of work. There is a tendency for inexperienced staff to check what is put in front of them and not necessarily identify what is missing.

Risk assessment based checking

The reporters are aware of some authorities that have adopted a risk management approach, where calculations are not checked if they come from an engineer perceived as being competent or well known engineering company, even though the "unchecked" design may have been carried out by a junior member of staff. The judgment for this is normally based on the presentation of the submission, Le. is it submitted on headed notepaper or do they have letters after their name? If the application looks to be from a reputable company then no check is being undertaken.

The Institution of Structural Engineers is trying to bring in self certification but they may be unaware that it already exists in the form of uncontrolled internal risk management systems in some authorities.

Building control officers checking simple calculations

The reporters are aware, that in some authorities, the smaller applications are being assessed by building inspectors, many of whom appear to be using simple software packages. Even though this may appear to be an acceptable compromise we have concerns over the use of this program by staff whose first discipline is not structural engineering. A culture of checking the math rather than the concept seems to be evolving.

The reporters have received numerous examples of abuse of these types of programmes, which include:

  • No understanding of effective lengths. Due to this lack of understanding many adopt a worst case scenario, which is resulting in clients having overly expensive solutions.

  • An inability to assess load intensities, or even understand the redistribution of loads from other areas within the construction

  • Beams in pairs are designed to take equal share of the load under a cavity wall with no understanding that normally the inner leaf is more heavily loaded

  • Total misuse of programs for design of portals

Building inspectors have a fundamental inability to review local/overall stability when walls are removed in buildings. Current trends in construction leave many buildings open to this risk. Significant numbers of properties fall outside the scope of approved document A.

A couple of the authorities represented by the EPSEG are currently being forced to consider passing over between 33% and 65% of their structural workload over from engineers to building inspectors to check, when a joint working group is established.

A wider investigation of authorities in the area indicate that the percentage of applications that have a structural check carried out on them ranges from between 19% and 57%.

When considering the current short supply of building inspectors and the increased complexity of other parts of the building regulations, the reporters have to question the logic in loading them up with additional responsibilities that are not their primary function.

Expert Panel Comments

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To conclude the reporters would make the following points:

  • The complexity of submissions has increased and the quality / resources available for checking has decreased substantially over recent years. This is now giving many of those involved with the checking process serious concerns over the adequacy of current service delivery.

  • The quality of submissions is reducing, and many designs are now undertaken without the benefit of the engineer even undertaking a site visit. Simple errors regarding the design are commonplace and the local authority check can be the only process where designs from several independent sources are coordinated.

  • There is obviously a wide variation in the level of service being offered. This variation is not only between local government inspectors and private approved inspectors but also between various local authorities.

  • The reporters feel that in many instances, inadequate checking is being undertaken. This is unlikely to result in failures of buildings in the short term due to the current factors of safety associated with building design. However, a trend of reducing factors of safety could result in a disproportionate number of incidents once the design loads are achieved during a period of excessive weather or unforeseen loading conditions.

  • It is noted that most of the engineers who read the CROSS Newsletters or the Structural Engineer are professional engineers and would not be affected by many of the factors discussed above. However, the reporters are seeing a disconcerting number of poorly designed and incomplete submissions. Many recent designs are from people with limited or no engineering background. The reporters believe that we now seem to be living in a society of ‘DIY developers’ and ‘low cost engineering’ where the importance of a rigorous checking regime is both needed and expected by the general public.

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