Could a new code bring clarity to construction product marketing through accurate, up-to-date and accessible information? Will it make buildings safer, and will manufacturers sign up to it?
The Grenfell Tower Inquiry brought to light deeply-disturbing allegations of malpractice by certain construction product manufacturers and some of their employees, and flaws in product testing.
With unsafe materials still lying dormant in many residential blocks, and distraught leaseholders facing crippling remediation bills, unable to sell properties until works are carried out, pressure on suppliers, and the industry in general, to prevent the same mistakes from reoccurring has never been greater.
The Code for Construction Product Information (CCPI) comes alongside a range of new measures and provisions intended to strengthen and extend the regulation of construction products, including the creation of a new construction products regulator, a building safety bill, fire safety bill and fire safety order.
Developed by the Construction Products Association’s Marketing Integrity Group (MIG), which was tasked to respond to issues raised by Judith Hackitt’s 2018 report into the Grenfell disaster, the code is being managed by independent not-for-profit organisation Construction Product Information Ltd.
Product makers who sign up to the CCPI agree to abide by 11 clauses conceived to ensure that product information meets the acid test of being accurate, reliable, unambiguous, up-to-date and accessible.
Participation is voluntary, but the aim is for organisations, including architects, contractors and clients, to insist on working only with compliant manufacturers. Individuals from over 170 organisations across the industry, including a number of major clients and contractors, have registered interest so far and the first manufacturers can register to verify their products at the end of 2021.
Main contractors and house builders, which have direct control over supply chains and can therefore enforce it as a requirement, have a powerful role to play in driving uptake. For architects, it’s more about awareness, says Adam Turk, chair of MIG: ‘During 2022, architects will start to get a choice of either receiving information from manufacturers who are CCPI-compliant, and therefore the information can be trusted, or from those that are not. We want them to ask: “are you on track to become compliant, because if not, we may not be able to use your information in future”.’
Murky waters
Disingenuous marketing practices and misleading or inconsistent product information have made it disconcertingly difficult for specifiers, contractors and clients to compare and understand products and keep tabs on what ultimately goes into a building, with potentially fatal consequences.
The Grenfell Inquiry heard allegations of how insulation makers Kingspan and Celotex rigged fire tests and inappropriately marketed systems containing combustible foam insulation products as safe to use on high rise residential buildings.
Achieving safer buildings is a hugely complex business and requires many parts of a jigsaw puzzle to fall into place. Reliable product information must go hand-in-hand with, for example, competence in the handling of construction products and the digitalisation of product information.
A key element of the proposed Building Safety Bill, currently going through Parliament, is the need to maintain a ‘golden thread’ of information throughout the lifecycle of high-risk residential buildings to ensure that what was originally designed is built to the same standard.
In this context, the CCPI could be seen as a fundamental first step in the process, says Turk: ‘You have to start with the right information about products, then you’ve got the foundation to do everything correctly thereafter. It is a cornerstone of all of the changes going on.’
Architects need to get away from a ‘cut and paste’ approach to specification, says Turk, and establish specific performance criteria at the outset, based on CCPI data, so that further down the line, if the contractor needs to make a product substitution, they can ensure it meets or exceeds those criteria, therefore holding the golden thread together.
We need to ensure we are receiving information from people who are suitably qualified and competent to make an assessment. We are getting to a point where we need to see suppliers assessing their competence to provide information on carbon and other issues
Clauses 1-3 of the CCPI require manufacturers to put in place a clear process and structure for how product information is created and managed throughout its life, including ongoing responsibility when in the hands of third parties.
Named individuals/roles must be nominated as responsible for creating the information from the outset and a competent person must sign off the final version. There must be an audit trail of processes carried out and documentation reviewed, including input from internal and external third parties.
Competence is an issue that architect BDP has been following closely, says Paul Owen, technical delivery lead at the practice: ‘We need to ensure we are receiving information from people who are suitably qualified and competent to make an assessment. Building fire safety has been the most high profile issue in recent years, but we are getting to a point where we need to see suppliers assessing their competence to provide information on carbon and other issues.’
This section of the code also requires manufacturers to put in place a formal version control process for all product information, with unique identifiers for the specific version and date of issue. Existing information on previously sold or discontinued products must also be made easily available.
In addition, all misleading or ambiguous wording, phrasing or imagery must be replaced by ‘plain English’ using industry terminology and abbreviations and accurate depictions of products.
Opaque messaging
Proof of stated claims in marketing material is vital to specifiers and Clauses 4 to 7 focus on the essential product information that must be provided when making product comparisons and selections for projects.
Claims of compliance to any certification, classification, or industry standard must be backed up by valid and demonstrable documentation that’s made available, in full, on request and/or on the company website.
Any other claims of product performance must be supported by specific documentation, referenced back to a valid dated test or specified technical assessment, with additional info on the type of test, date passed, under what standard, and by whom etc.
Manufacturers must always be specific to the intended application and, where known, provide examples of limitations or inappropriate applications.
'Some manufacturers have been providing the industry with inadequate information (classification/ certification) and the correct guidance on how a product or material should be used etc. to meet that classification/ certification,’ says Patrick Crocock, specifications lead at AHMM. ‘We need to ensure that information isn’t generalised to say “yes, you can use this” but when you read the small print you find it can only be used in certain situations, buildups and interfaces with specific materials.’
Along with a list of descriptive and physical characteristics of the product, manufacturers must have a documented process to ensure that any subsequent changes are reflected in revised information.
Looking beyond design and supply, Clauses 8 and 9 deal with product information pertinent to handling, installation, operation, maintenance and disposal, and the disclosure of warranty and guarantee information.
Minimum requirements around installation must include, among other things, information on safe installation and access, interface with other products, installation guidance to achieve tested performance and the specific competence level required for installation.
When making any claims of guarantees and/or warranties, the manufacturer’s website must state what is covered, excluded and required to comply with its terms. Details should be transparent and in a format recognised by the relevant sector of industry.
The final two clauses cover the need for appropriate signposting to contact information on websites and for a robust training programme for new and existing personnel, to ensure the competence of anyone conveying product information.
Data dilemma
The future success of the CCPI hinges on industry support and supplier adoption and, according to the findings of a recent consultation on a draft version of the Code, this is strong. A total 97% of trade associations and 86% of product providers quizzed said they thought it was important to comply. However, several concerns were highlighted, particularly over a proposal for peer-based policing and the need for more clarity around training, competence and compliance requirements.
The ability to standardise and harmonise manufacturers’ product data, the properties and certification etc, so that everybody works to the same format and structure is the holy grail
CPI Ltd now plans to run an independent verification process with product evidence assessed and reviewed by a team of independent self-employed verifiers. These will award a verification marque, licensed for each product set for up to two years.
Teething problems with the Code’s implementation, including how easy it is for organisations of different sizes, structures and with different product ranges to conform, will be revealed through a pilot programme being run by CPI.
The ability to bring smaller manufacturers along for the ride is a particular concern, says AHMM’s Crocock: ‘I don’t think it's going to be wholly inclusive, because some smaller manufacturers may not be able to sign up to this because of limitations in their IT infrastructure or there may be cost implications of ‘meeting criteria’ for getting this in place.’
Factor in other business impacts and commitments, such as Covid and the requirement to have post-Brexit UKCA and UKNI product marking in place before 2023, and some could fall through the cracks.
Amanda Long, chief executive of CPI, says there are ‘plans to update the approach, if necessary, to ensure small manufacturers can access and conform with the Code’.
Access to trustworthy information is a positive move, but the CCPI makes no mention of information standardisation, including the use of common data formats, or digitisation, considered by many as vital to ensure a consistent approach by the industry and in line with the needs of the golden thread.
Crocock comments: ‘The ability to standardise and harmonise manufacturers’ product data, properties and certification etc, so that everybody works to the same format and structure, is the holy grail.’
Owen adds: ‘We need to get to a point where everyone can see that products have been tested to the same standard, that performance results for similar products include the same information, not slightly different information, and that we see all aspects of performance, not just some.’
The consultation revealed a push to add more digital requirements, but the CPA’s MIG felt that was pitching the bar too high for some organisations. Through a pragmatic approach, it is intended to review and update the code’s requirements in line with manufacturers’ capabilities over the coming years.
‘We want to take it one step at a time: step one – make sure you can trust information; step two – put it in a standardised format; step three – improve accessibility to make comparison easier,’ explains Turk. ‘The industry is going through evolution, not revolution, we’re taking a very fragmented, unregulated sector and trying to get it to do things properly,’ he concludes.