How British Standards and Approved Document Guidance Continue to Help Raise Industry Installation Practices for Competent Person Scheme Registrants
Calvin May, Technical Standards Manager, describes the origin and purpose of the approved documents & how they have since improved industry safety and standards.
Any person carrying out construction works in a property in England and Wales is required to ensure the works are in full compliance with Building Regulations legislation; in particular Statutory Instrument 2010/2214.
This legislation covers all individuals undertaking installation works of heating appliances within a dwelling, from registered industry professionals to DIYers, and in simple terms means any installation of a solid fuel heating appliance must meet the five principle requirements of the Building Regulations that are referenced further on page 9 of guidance document Approved Document J.
The Building Regulations stipulate the five following requirements for the safe and efficient use of combustion appliances as follows:
- J1 Air Supply – Combustion appliances shall be so installed that there is an adequate supply of air to them for combustion, to prevent overheating and for the efficient working of any flue
- J2 Discharge of Products of Combustion – Combustion appliances shall have adequate provision for the discharge of products of combustion to the outside air
- J3 Warning of Release of Carbon Monoxide – Where a fixed combustion appliance is provided, appropriate provision shall be made to detect and give warning of the release of carbon monoxide
- J4 Protection of Building – Combustion appliances and fluepipes shall be so installed and fireplaces and chimneys shall be so constructed and installed as to reduce reasonable level of risk of people suffering burns or the building catching fire in consequence of their use
- J5 Provision of Information – Where a hearth, fireplace flue or chimney is provided or extended, a durable notice containing information on the performance capabilities of the hearth, fireplace, flue or chimney shall be affixed in a suitable place in the building for the purpose of enabling combustion appliances to be safely installed
To support installers undertaking the installation of combustion appliances to effectively meet the Building Regulations, the 1984 Building Act permits local government to approve and issue guidance documentation containing practical design, installation and commissioning guidance for heating appliances. The full suite of guidance documents helps to set a standardised industry approach to how installers may meet compliance with all parts of the Building Regulations requirements.
The installation guidance contained within approved documents is developed through the Building Regulations Advisory Committee (BRAC), which is fully supported through input by industry representatives and expertise from organisations such as HETAS, who strive to work for consumer safety and the wider public interest in the safe, efficient and environmentally responsible use of biomass and other solid fuels.
Why Approved Documents Play an Important Role for compliance
The Building Regulations were first developed and published for use as early as the 1960’s, and set out the general requirements including constituted workmanship of building work, exemptions, notification procedures and requirements for specific aspects of building design and construction.
As time progressed, building methods, construction materials and safety considerations developed and the building regulations system found new ways in which to support installers undertaking construction works further by providing guidance information. These guidance documents, now known as approved documents, were developed with continued safety in mind, verified by substantial input and research by industry members with the aim to reduce the risk of non-compliant work, offering working methods for some of the more common building situations.
Over time, Approved Documents were developed further to embrace innovation and new construction material practices, leading to new revisions with amended requirements. A large majority of the housing stock in the UK still include substantial number of older style properties that the Building Regulations at the time would not have covered, meaning installation guidance contained within approved documents over time is still of significant value even today.
The aim in publishing approved documents is to provide, in ordinary circumstances, guidance to achieve compliance with specific aspects of more common building situations. The guidance should be considered alongside installation practices contained within manufacturer installation and operating instructions.
An example of the development of Approved Document J can be seen through recent developments of CO safety and awareness within Approved Document J below:
Although the legal requirement stipulates for a carbon monoxide (CO) alarm to be present in the room in which the appliance is installed, the way in which the requirement is written allows for differing interpretation to be applied. This is where additional guidance aids in providing a means to meet the J3 requirement, allowing for the positioning of a CO alarm in a place that will avoid dead spots, and at a distance that upon activation gives the consumer the maximum alert time to vacate the premises as necessary. The measurements given would have been determined by support from industry research and verification, providing robust guidance in which to follow to meet regulation J3.
It is important to note however that simply following approved document guidance does not automatically result in compliance being met in all cases, and is the responsibility of the person carrying out the building works to ensure compliance against the regulations. This is not to say that approved document guidance shouldn’t always be followed, however it simply means that additional guidance may be required where the situation calls for it to.
Other Requirements Available in Which to Meet Compliance
Although approved documents provide a means of meeting compliance in most cases, the route in which approved documents can be amended and developed to embrace innovation and change can at times be a long and drawn out process. An example being the last revision of Approved Document J taking place some 10 years ago!
Innovation in solid fuel appliances has meant more efficient closed roomheater appliances are available on the market, which may under certain circumstances not suit the general guidance in current approved documents which is aimed more towards older style inefficient open fired appliances in masonry constructed properties.
The slow update of Approved Documents is at odds with the innovation of appliances and building structures so industry looks for alternative approaches to be considered when installing modern solid fuel appliances efficiently, whilst still providing safe operation for the consumer.
Looking at page 40 of ADJ, the guidance allows for alternative approaches to be considered in the absence of core guidance within ADJ, particularly the use of British Standards BS 8303, which covers appliance installation practices, as well as BS EN 15287-1 which covers chimney design, installation and commissioning practices for solid fuel.
British standards are developed through UK industry committees and the British Standards Institute (BSI), and a review is programmed on a 5-yearly basis on whether to confirm the current requirements as applicable or to choose to review and further develop the standard as innovation takes hold. This allows a shorter timescale in which to provide additional guidance on meeting Building Regulations compliance for industry.
In some instances, BSI installation standards may contain more in-depth guidance on compliance with the regulations, and can at times be chosen to take precedent over absence information within approved documents, and provide an alternative approach in which to meet compliance for the installation. HETAS currently lead and support on a wide number of BSI committee technical meetings, in which to ensure a technical, balanced and impartial viewpoint is put forward upon development of these documents.
Whilst updates to standards can be quicker than updates to Building Regulations, there can still be a lengthy formal review and update. Where there is a more immediate need, HETAS provides another level of support through detailed technical notes and other installation codes of practice to support its registrants. These publications are developed and peer reviewed will the help of the industry through the HETAS Technical Committee.
It is important to note that in most cases, conflicts between BS standards and Approved Document guidance are rare, however in circumstances whereby each document provides a different method for compliance with the regulations then either requirement may be deemed as suitable. As a proactive approach, HETAS will always promote the more stringent position of the two, as this poses a reduced risk in terms of safety for the end-user upon operation of the appliance.
Obligations to Follow Approved Document or British Standard Guidance
Building Regulations set out the legal requirements that relate to compliance that must be met. Following approved guidance documents or relevant standards will in most common building situations result in compliance to the Building Regulations. However, there is no simple answer to the obligations in following approved documents or British standards for installation works, and it is important to be reminded that ultimate responsibility of compliance lies with the person or persons carrying out the building work.
HETAS promotes following approved documents, relevant standards or detailed guidance / codes of practice offered by HETAS as it offers proven methods and techniques that don’t require further verification. If an installer chooses to meet compliance by an alternative method, they need to retain evidence that such a method is acceptable and if required by Building Control or a HETAS inspector provide that evidence.
HETAS, as a recognised competent person scheme (CPS) operator, is required to ensure registrants are working to relevant minimum technical standards for the categories of work they are registered for, and that they apply their competence with the work they carry out. The HETAS CPS scheme abides by a Minimum Technical Competence (MTC) criterion set by the Ministry of Housing, Communities and Local Government (MHCLG), who are responsible for the Building Regulations, and responsible for authorising CPS operators such as HETAS.
HETAS provide a technical helpline to our registrants offering support to comply with the Building Regulations and the MTC’s, contact of which available exclusively to HETAS registrants, full details are available in the HETAS Technical Area.
Meeting Compliance Outside of Current ADJ/BSI Requirements
There may be occasions when approved document guidance or BS standards do not contain relevant reference to unique installation opportunities. This may be down to an innovative appliance, flue system or even building construction type not yet covered by recognised standards.
HETAS, as the organisation to promote safe, efficient and environmentally responsible installation is continually looking to develop supporting technical documentation which promotes best practice for appliances in these situations, in order clear up interpretation and allow pragmatic approaches to be taken to increase the means of meeting Building Regulations compliance.
All documentation is developed with full input and peer reviewed from industry stakeholders through the HETAS Technical Committee (HTC), which includes representation from notable installers, chimney sweeps, retailers, manufacturers and notified laboratories. This wider representation ensures all viewpoints of the industry are taken into account, whilst at the same time allowing for HETAS to consider an overall impartial and balanced technical lead.
New Technical Notes (TN’s) are continuously being considered and developed for a number of scenarios, not explicitly covered within ADJ or standards. More recent technical notes include the following:
- TN0020 – External Air Supply Technical Note
- TN0022 – CO Alarms Guidance on Positioning
- TN0023 – Installation & Guidance in Leisure Accommodation Units
- TN0024 – Installation & Guidance for use of insultation board materials
For more information on British Standards and Approved Documents, visit the Technical Area of the HETAS website or call the HETAS technical helpline (please have your registration details available for verification).