Housing, Communities and Local Government Committee

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1 Housing, Communities and Local Government Committee

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4 Ban on combustible materials: Briefing on the number of buildings in England with combustible materials on the external walls Dear Sir/Madam, I am writing on behalf of ROCKWOOL Ltd to raise a matter of public safety regarding high-rise and high-risk buildings. We have long-standing expertise in fire safety as a leading manufacturer of non-combustible stone wool insulation, and we have provided in-depth technical and regulatory information to MHCLG, the Independent Review of Buildings Regulations, Parliament and the built environment sector, to support ongoing work around fire regulations and public safety. ROCKWOOL supports MHCLG s proposal to ban combustible materials on the façades of high-rise residential buildings but believes the scope of the ban should be extended to all high-rise buildings, including existing buildings, and all high-risk buildings such as hospitals, schools, and care homes, in order to protect public safety in the event of a fire. As Dame Judith Hackitt highlighted in her recent report, there is a lack of a golden thread of information through projects in the UK, from design, completion and operation. We do not currently have a clear picture of which hospitals, schools, care homes and other high-risk buildings across the country incorporate combustible cladding or insulation. ROCKWOOL has carried out analysis that shows that there are at least 1,600 high-rise and high-risk building projects across the country with combustible façade systems that have not yet been identified under the Building Safety Programme. Hundreds more buildings are planned and underway that will also be left out under the current scope of the ban, including schools, hospitals and care homes. We believe this data will go some way to providing clarity on how many buildings across the UK currently have combustible cladding. We expect the Government to formally publish their proposals for a ban in the coming months, and we would like to request a meeting to meet at your earliest convenience to discuss this matter. Kind regards, Darryl Matthews Managing Director, ROCKWOOL UK

5 Briefing on the number of buildings in England with combustible materials on the external walls Overview On Monday 1 st October, the Government announced proposals to ban combustible materials on the façade of: High-rise residential buildings (18m and above) new-build and refurbishment work High-rise residential schools (18m and above) new-build and refurbishment work High-rise hospitals (18m and above) new-build and refurbishment work High-rise student accommodation (18m and above) new-build and refurbishment work High-rise care homes (18m and above) new-build and refurbishment work However, the ban does not include: Any existing buildings, as built or refurbished Residential schools that are lower than 18m in height Non-residential schools, regardless of height Hospitals that are lower than 18m in height Care homes that are lower than 18m in height Offices, regardless of height (despite high office to residential conversion rates) We believe the scope of the ban should be extended to all high-rise buildings, including existing buildings, and all high-risk buildings such as hospitals, schools, and care homes regardless of height. This is a position that has been endorsed by various other industry experts and representative bodies such as the Local Government Association who continue to strongly urge the Government to ban the use of any combustible materials including cladding panels, insulation and other materials on the external walls of high-rise and high-risk buildings. Across the UK Current Situation Given the current lack of held data on the number of projects across the UK with combustible cladding systems, ROCKWOOL has recently carried out research using the construction industry insight tool Glenigan, combining future and historical construction output figures to estimate the number of construction projects in the UK that use, or plan to use, external rainscreen cladding systems (the type of system on Grenfell Tower). Data from Glenigan is available at a project, rather than individual building level, and projects often incorporate multiple buildings. The numbers given below therefore represent the minimum number of buildings affected. As Dame Judith Hackitt highlighted in her recent report, there is a lack of a golden thread of information through projects in the UK, from design, completion and operation. In the absence of this, we hope our findings will go some way toward providing clarity on how many buildings across the UK currently have combustible cladding and insulation. We welcome any additional information you may have on the precise proportion of buildings incorporating combustible materials, and we recommend that a comprehensive audit should be undertaken by MHCLG. Headline Analysis According to our analysis, there are 1,065 high-rise and high-risk projects currently planned or underway in England which will use rainscreen cladding systems. The Government s proposed ban would apply to less than half of those. The rest, around 543 projects across England, could still use combustible materials.

6 Additionally, our analysis of data from shows that there are around 2,372 existing high-rise or high risk projects which use rainscreen cladding systems. We estimate that before the Grenfell Tower fire, at least 90% of these projects incorporated combustible insulation, and a large majority incorporated combustible cladding as well. Of those, the Government systematically identified 457 high-rise buildings with ACM cladding. That means at least 1,678 at-risk projects, including hundreds of school and hospital buildings, are likely to have combustible materials and have not been identified by the Building Safety Programme. Detailed Breakdown of Buildings The following numbers give a more detailed breakdown of the numbers of different projects using rainscreen cladding systems that have been completed in the UK since 2013: 964 university and school buildings 428 hospital, nursing homes and sheltered housing projects 162 hotels The vast majority of these projects, as noted above, will incorporate combustible materials. To note, our data analysis tool only has access to data going back to 2013, so the number of projects will be much greater than outlined here. In addition, none of these existing buildings will be covered by the Government s ban, which will not be retrospective. Further, we have analysed publically available information listed and identified around 70 existing high-rise or high-risk buildings that use combustible materials on the external walls, to provide further detail behind the problem identified above. These are planned buildings that would not be covered by the Government s proposed ban and existing buildings that were not identified in the Government s ACM screening programme last summer. We would be happy to share the full list of buildings we have identified with you. Our recommendations ROCKWOOL believes that combustible materials (Euroclass B or below) in cladding systems should be banned for all high-rise and high-risk buildings. We believe that a ban is a straightforward, practical, enforceable and effective way to improve public safety in the event of a fire. Specifically, we recommend that the ban should: Apply to all high-rise buildings (12m and over with one escape route, and 18m and over with multiple escape routes), not just high-rise residential buildings Apply to all high-risk buildings (such as hospitals and care homes, schools, hotels and sports arenas, where there may be challenges in exiting the premises), regardless of their height

7 Dr Jonathan Evans Mr Clive Betts MP Chair, Housing, Communities and Local Government Committee House of Commons London SW1A 0AA Dear Mr Betts, 5 th December 2018 The details of the much anticipated combustible materials ban emerged on 29 th November. The scope of the ban is much as expected, but there has been widespread criticism of several aspects and general confusion. My feelings can perhaps best be expressed through the following summary: a. MHCLG has astonishingly reverted to the structure and wording of the old Approved Document B that featured regularly during your Committee meetings. b. The ban is effected by adding a new Clause that defines building types that are subject to the new overriding Building Regulations clause 7(2) that requires non-combustible materials. c. We therefore have: a. Approved Document B Guidance that is even more complicated than before. b. The combustible ban doesn t have exceptions; buildings subject to the ban are the exceptions to what we had before. Hotels and offices are not covered why? d. The contentious words filler and etc that MHCLG used to claim that cladding was always supposed to be limited combustibility, remain. Dr Barbara Lane s Grenfell public inquiry expert witness report emphatically supports industry opinion that this contrary to the Approved Guidance. e. Diagram 40, which allows combustible Class 0 and Class B cladding materials above 18m remains unaltered and in effect. Nothing has been done to directly address or highlight the dangers and limitations of national Class 0 certification in relation to combustible composite materials. f. Aside from a vague cautionary note in 12.6 there is still nothing that clearly precludes the use of highly dangerous Class 0 polyethylene cored ACM from a high rise hotel or commercial building. g. The wording of the new regulation 7(2) and the specific list of exceptions is a vast improvement on the previous ambiguities and proof of the improvement that could be achieved with a broader ban. It s remarkable that an opportunity to remove the contentious Guidance wording and clauses that are seen as having contributed to Grenfell, has been missed. It stands as another failure to learn - do we have to wait for a disaster in a city-centre hotel before such buildings are included too? On the day of the announcement, the Chairman of the National Fire Chiefs Council, Mr Roy Wilsher (who has been a constant member of the Building Safety Programme Independent Expert Panel from the outset), stated I am disappointed this ban does not go further and apply to buildings of any height and that 18m is a historical height which does not reflect modern firefighting equipment and practices. Height and scope do not appear set in stone, so there is work to do to achieve an effective ban. By reducing the height and widening the scope of the ban, Section 12 collapses into simple wording that will save lives. Widening the scope to commercial buildings would drive innovation (Kingspan have just released a much-welcomed A1 insulation product), increase non-combustible production volumes and reduce cost increases which currently are burdened largely by house-buyers. I feel it s also insensitive that Grenfell survivors or those being re-housed during remedial works could be temporarily staying in buildings which aren t covered by the combustible ban. Yours sincerely, Jonathan Evans