CROSS Safety Report
Concern that the structural design of some recent buildings may not have been checked
A reporter, who is an experienced chartered engineer undertaking structural design, has become increasingly concerned that the structural design of some buildings may be non-compliant for a number of reasons.
Key Learning Outcomes
For building control bodies:
- Ensure that all structures are checked for compliance with Part A of the Building Regulations in England and Wales, and the equivalent in Scotland and Northern Ireland, by suitably qualified and experienced people
For owners and clients:
- Understand the competencies required of engineers for the project in hand
- All structural design should be signed off by an appropriately experienced chartered civil or structural engineer
For civil and structural design engineers:
- Ensure that there is a suitably qualified and experienced engineer with overall responsibility for design and checking
- Be aware that the adequacy of structural design submissions to building control bodies lies with the originating designer - do not place reliance on the building control review
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A reporter, who is a chartered engineer undertaking structural design over a long period of time, has become increasingly concerned that some buildings may not be structurally safe for a number of reasons:
- Failure of the client to employ a qualified engineer
- The engineer providing an incomplete design (e.g., design of beams without checking bearings, foundations, or overall sway resistance)
- Failure of the building control body to engage a checking engineer
- The client, builder, or building control officer making changes to the structural design on site, without taking advice from a structural engineer
The reporter goes on to provide further reasoning as to some underlying actions that may contribute to designs being potentially unsafe:
- Inappropriate cost-cutting by the client
- The willingness of some ‘designers’ to take on engineering design work for which they are not suitably experienced and/or qualified
- The willingness of some professional engineers and building control bodies to offer a partial service
- The willingness of some building control officers to make decisions on structural issues without taking advice from a structural engineer
The reporter also shares some of their thoughts as to those actions that would help to reduce the chance of unsafe structures being designed and constructed:
- Structural design responsibilities are often divided and fragmented and engineers need to either:
- Ensure that there is a project engineer who has overall responsibility for the design of the project including coordination of the various parts of the structure designed by sub-contractors or, where this is not possible;
- Flag up to their clients very clearly the limits of their design responsibilities and the necessity of ensuring that the structural design is properly coordinated by another party.
- Clients sometimes employ ‘designers’ who are not qualified, competent, or experienced enough to carry out the necessary design work; such designers can easily buy design software and prepare a partial design. Clients and persons carrying out building works need to be made aware of the risk of engaging such designers and be encouraged to engage chartered engineers instead.
- Building control bodies should be resourced with qualified checking engineers.
- Where building control bodies do not deploy checking engineers, they should make the person carrying out the building work aware of this fact. This should also be made clear on any ‘completion certificate’.
Expert Panel Comments
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The reporter raises a number of constructive criticisms which unfortunately are most likely familiar to many readers and are reported upon by CROSS with some regularity.
Those engineers who have been involved in checking building regulation applications will recognise the concerns of ‘partial, incomplete and fragmented design’ put forward by the reporter. Those engineers will also likely understand that the awareness of the presence of external scrutiny can impact positively on the quality of design.
The checking of engineering designs submitted under building control processes can have many benefits including, not least, the prevention of unsafe structures being erected. However, because not all building control submissions are subjected to an engineering check, the extent of reliance that can be placed on the structural quality of a building, because it had successfully gone through the statutory building standards (building control) process is potentially less clear, albeit that building control bodies have a responsibility to review all designs for compliance with Part A. Building control bodies should have access to in-house engineering capacity or buy in the expertise from an external resource if and as necessary.
The issues put forward by the reporter, and much similar feedback to CROSS, may be food for thought for building control bodies when they next consider the value derived from engineering checks by experienced structural engineers.
awareness of the presence of external scrutiny can impact positively on the quality of design
Whilst mentioned by the reporter in the context of building control checking, the wider theme of checking, quality control and validation deserves deeper thought by all. Construction engineers (temporary works engineers) are very familiar with the codified checking regime provided in BS 5975:2019 - Code of practice for temporary works procedures and the permissible stress design of falsework; under this code, all designs require a check:
- Category 1 (simple designs) - may be checked by another member of the design team
- Category 2 (more complex or involved designs) - should be checked by an individual not involved in the design and not consulted by the designer
- Category 3 (complex or innovative designs) - should be carried out by another organisation and should include an overall check to assure co-ordination of the whole design
Could a similar approach be recommended in a standard for permanent works building structures in the same way as it is in BS 5975:2019 for temporary works? Such a requirement is much harder to ignore if it is codified - once codified it becomes 'the normal way of doing things’. Other sectors, for example UK bridge engineering, have included codified checking for a very long time.
We should of course recognise that most organisations undertaking structural design have implemented effective validation regimes. A stronger regime is on its way for some permanent works design as a requirement of the Building Safety Act (BSA). Perhaps it will not be too long before the merits of codified checking (and there are many including learning and development) are recognised and formally implemented, through regulation, for the structural design of buildings.
Perhaps it will not be too long before the merits of codified checking are recognised and formally implemented
We need to find a way of ensuring appropriate quality control for design and execution including adequate design, checking, contractor supervision and independent supervision by suitably qualified and experienced personnel (SQEP). As with so much of our industry, clients are key here, including for smaller works, as they have the chance to select suitably qualified and experienced advisers.
Clients should always be concerned to understand the competence of building professionals they propose to appoint. Capability in terms of the experience, training and qualifications should be assessed alongside the proposed resourcing. Clients could also seek references to help them understand the competence of particular design organisations. The HSE has published important guidance for both domestic and commercial clients insofar as their legal responsibilities under the Construction (Design and Management) Regulations 2015 are concerned.
Firms or indeed individual engineers, performing as designers, also need to understand their suitability to undertake particular commissions. Persons must be competent to perform the duties offered, apply appropriate skills, experience and knowledge, and have full regard for safety. The Institution of Structural Engineers’ Business Practice Note No. 15: Competency, overviews issues of competency, ethics, and the need to address limitations as engineers.
Finally, and very importantly the reporter also raises the need for a project engineer to have overall responsibility for the design of the project. It is essential to appoint someone to have this accountability and to have overall responsibility (sometimes called the controlling mind). On small projects, this is likely one person, but on larger projects, depending on scale and complexity, a team of people with the requisite skill and experience to manage the risk and ensure success may be appropriate.
CROSS report Inadequate design submissions for alterations to an existing building concerned a number of similar issues.
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