‘Asking the right questions’: meeting building safety requirements

As chair of the new Industry Competence Steering Group, Hanna Clarke has a crucial role to play in making sure the construction sector comes together to improve competency and meet the requirements of the Building Safety Act. Alex Smith speaks to the artist turned safety expert with a painter’s eye for detail

The formation of the Industry Competence Steering Group (ICSG), in January this year, signalled the start of the latest chapter in the drive to improve competency in the construction industry. Its work will have consequences for the 3.1 million people working in the UK construction sector, as its remit is to raise competency standards across the whole built environment.

To ignore the ICSG’s guidance is to risk breaking the law, as the Building Safety Act – introduced in October 2023 – has competency requirements for all individuals and organisations working in construction, with few exceptions. 

The ICSG is chaired by Hanna Clarke, digital and policy manager at the Construction Products Association (CPA), who sat on the ICSG predecessor, the Competence Steering Group (CSG). This was set up by the Industry Response Group after Grenfell to look at competences of those on higher-risk buildings.

The CSG addressed competency shortcomings identified in the 2018 Hackitt review, Building a safer future (bit.ly/44Qc90o), and set up 12 working groups that – from June 2020 until October 2023 – published competency standards and frameworks for construction disciplines, including engineering.

Following its work responding to the Hackitt review, the CSG is now transitioning into the ICSG, which has a remit to develop new standards, competence frameworks, accreditation procedures and learning materials. The working groups will remain, to continue instilling competence in their sectors, but some have moved.

Current activity of working groups

  • Working group (WG) 1: Engineers. Developing training for all building types following focus on higher-risk buildings.
  • WG 2: Installers. This includes subgroups such as interiors, envelope, civils and building services, and these are grouped around building ‘super systems’.
  • WG 3: Fire engineers. Now working within WG1.
  • WG 4: Fire risk assessors. Creating a new standard BS8674: Framework for competence of individual fire risk assessors – Code of practice, because, currently, there are no standards for fire risk assessors.
  • WG 5: Fire safety regulators.
  • WG 6: Building control professionals. Now sits under the ICC.
  • WG 7: Designers.
  • WG 8: Buildings safety management. Developing PAS 8673.
  • WG 9: Site supervisors.
  • WG 10: Project managers. Under the chair Gill Hancock, at the Association for Project Management, this group published a Competence Framework for Project Managers in the Built Environment in England (bit.ly/CJCompPM).
  • WG 11: Procurement.
  • WG 12: Construction product competence. Currently developing BS8670-2, which is due in autumn 2024.

‘Two years ago, the Competency Steering Group decided that it needed to be long term and continue to work collaboratively with the industry on competency,’ says Clarke.

‘The CSG broke ground in bringing so many siloed sectors together in unprecedented collaboration. ICSG’s task will be to build on this, bringing in more disciplines and stakeholders, and increasing our engagement and visibility.’

The CSG created Working Group Zero, an oversight committee that looked at how competency would be regulated. Out of that came the Industry Competency Committee (ICC), which sets the competency standards and will be advising the Building Safety Regulator. The ICSG will look to raise industry standards and find where the gaps are in competency, says Clarke.

‘The ICC is like a mirror that is held up at industry, and it will challenge us,’ she adds. ‘We can give guidance and identify the areas where the problems are, and where we need support We’re looking to provide a much more joined-up approach.’

Defining competence

Hanna Clarke has gone from fine art to construction

The CSG published three reports, including Setting the bar (bit.ly/44ReBUC), which defined competence as ‘the combination of skills, knowledge, experience and behaviours that enable a person to undertake responsibilities and perform activities to a recognised standard on a regular basis’.

A similar definition is in the Building Safety Act: it requires ‘appointed individuals to possess the required skills, knowledge, experience and behaviours for their roles, while organisations must demonstrate and evidence their (and their supply chain’s) capability, competence and capacity to fulfil their obligations under Building Regulations’.


The liability is now high if it’s seen that you are doing things that are outside of your demonstrable competence

Clarke says the focus on behaviour is key: ‘Individuals must not work outside their ceiling of competence.’

She gives an example in the finishes and interiors sector, where a ‘Responsible No’ initiative (bit.ly/4buf812) is encouraging organisations to state when they are not competent to do work, rather than just saying ‘it will get the job done’.

‘The liability is now high if it’s seen that you are doing things that are outside of your demonstrable competence,’ warns Clarke. ‘If you say you can do something, you must back it up, whether you’re an individual or a team.’

Competency standards

Working Group Zero also led to the creation of a Code of practice for core criteria for building safety in competence frameworks, BSI Flex 8670.v3 (bit.ly/3WQCFFa). Flex is a more open approach to developing standards that allows feedback to be adopted by authors before the final standard is published.

Compliance with the standard can be achieved by mapping new or existing sector-specific frameworks against the core competence criteria and scope.

‘BSI 8670 is vital to know,’ says Clarke. ‘It’s a glorified checklist for the building safety principles you want to include in any competency framework. If any building services industry framework does not reference BSI 8670, the Building Safety Regulator will want to know why.’

The standard formed the core of the  UK Standard for Professional Engineering Competence and Commitment Contextualised for Higher-Risk Buildings  (UK-SPEC HRB) published by the Engineering Council. It sets out competences expected of engineers who work in the built environment sector, particularly on HRBs. Assessment to UK-SPEC HRB, and admission to the Engineering Council’s HRB Register, provides assurance to building owners that an engineer is competent to carry out work that complies with Building Regulations. CIBSE is one of three institutions licensed to award professional HRB registrations (bit.ly/CJHRBreg).

The flex standard will be published as BS 8670-1 and will sit alongside BS 8670-2 (bit.ly/CJBS86702), which is a standard being developed by Working Group 12, the products group. It will feature the core requirements for construction product’s competencies and frameworks, and is based on a CPA white paper authored by Clarke, Built environment – proposed construction product competence standard.

There are five levels of competence for a range of activities, such as product performance. Levels are graded from E to A, and someone with the highest level of competence can understand the systems and rules, and sign off the product. It means organisations can communicate the levels of competence at which designers and installers are working to the rest of the industry.

A new BSI technical committee, CPB/1 Competence in the Built Environment, manages standards output and has published PAS documents for the two dutyholder roles defined in the Building Safety Act – principal designer (PAS 8671) and principal contractor (PAS 8672) – and a PS 8673 for those managing safety.

Clarke has an unusual background for someone working in building safety. She has a fine arts degree and was an exhibiting artist when she got interested in construction processes while temping at a facilities management company. ‘I was an administrator, but I got curious,’ she says. ‘I kept asking questions about whether we’d done this right. I got into compliance and then data architecture, and started building planned maintenance systems for different buildings.’

She joined the CPA as an executive assistant and project coordinator, and became involved in the competency steering group. ‘The irony of this whole journey is that I can prove my competency to no-one,’ she says. ‘My competence is in asking people a lot of questions and saying “have we thought about this”.’

About the author
Hanna Clarke is digital and policy manager at the Construction Products Association