BSA 2022: is ‘as-built’ information the only thing that matters?
‘he who asserts must prove’ _ Abisogun OBE [July 1994]
Happy New Year to you all – it’s 2023 and the year that everything will change for the ‘high-rise’ residential asset owner, principally through their select appointment(s) and the documented actions of any Accountable Person(s). Suffice to say, the rules of ‘compliant / regulatory’ asset management have changed, for good and in the public interest.
But why am I seeking to talk about ‘as-built’ information and what is the relevance of this, in the context of the ‘new’ Building Safety Act? A humble surveyor of almost 30years, I’m asking the question not only as a diligent practitioner, fluent in the assembly, content and negotiation of any Final Account [which in many cases, will include or refer to ‘as-built’ information], but more as an asset owner, given my NED Role at Richmond Housing Partnership. However, given that Building Safety is a risk that I live with [as an NED] on a daily basis, I’m now being provocative in asking, both, of my peers and the wider industry, ‘what information’ constitutes the ‘as-built’ and how accurate is it?
Over the years, I have been led to believe [and rightly so] that the reality of what has actually been built is often reflected in the ‘as-built’ information; but is that entirely true and why is ‘as-built’ information so much more important in a post-Grenfell world? What is the role of the contractor’s 'marked up drawings' and the design team’s interpretation and acceptance of it? Is this ‘traditional’ albeit standard procedure, still fit for purpose in the era of #digitalconstruction and the Digital Twin?
Credit: RICS | WBEF
Let's begin by attempting to define ‘as-built’ ……
“A set of drawings that are marked-up by the contractor building a facility or fabricating a piece of equipment that show how the item or facility was actually built versus the way it was originally designed. At the completion of a project, the as-built drawings describe what was actually built.” _ Credit: US Department of Energy
Conversely, in the UK [according to Designing Buildings, the Construction Wiki]; The RIBA Plan of Work 2013 defines 'as constructed' information as: Information produced at the end of a project to represent what has been constructed. This will comprise a mixture of ‘as-built’ information from specialist subcontractors and the ‘final construction issue’ from design team members. Clients may also wish to undertake ‘as-built’ surveys using new surveying technologies to bring a further degree of accuracy to this information.’
In fact, according to the Design Framework for Building Services 5th Edition (BG 6/2018), written by David Churcher, John Sands & Martin Ronceray, and published by BSRIA in June 2018 suggests that record drawings (in relation to buildings services) are:
Credit: RICS | WBEF
During my career, naturally I have come across hundreds of thousands of drawings and I am always drawn to the title block first, normally in the bottom right hand corner of said drawing. As a PQS, the title block, at least for me, was and remains the most important element of that drawing. However, as a digital-constructor, I am now challenging my own thinking, that of my peers, my Clients, mentees, and the wider eco-system of built environment stakeholders and actors / Suppliers ……..
My question to you all, “is the ‘as-built’ information – as provided – accurate enough to reflect what has been designed, built and paid for AND sufficient to manage the asset(s), post-construction or following any refurbishment project?”
Credit: RICS | WBEF - Webinar on YouTube
In the presence of the recently enacted Building Safety Act [which received Royal Assent on 28.04.22], this is a very significant and pertinent question, allow me to briefly explain.
The core requirement of any asset owner is the implementation of relevant [and appropriately, albeit proportionate] management procedures being in place, to ‘create, hold and maintain the golden thread of information management; in an accessible and digital format’. That is the legal requirement for ‘in -scope’ buildings which comes into force this year, for existing buildings. At the time of writing an in-scope building is defined as, eighteen (18) meters or seven (7) storeys in height, with at least two (2) residential units within its structure. Again, picking up on one key point, i.e. ‘the golden thread’, which in and of itself is an evolving definition; “what is the role of ‘as-built’ information and how can asset owners be sure that what they have paid for [and received] is ‘actually’ a like-for-like representation of what has actually been built”?
Progressive ‘levels of detail’ [LOD] through effective information management, assembled, audited, verified and managed in a collaborative CDE will be key and critical to future success. And according to David Churcher, John Sands & Martin Ronceray via the Construction Wiki, the project’s ‘as-built’ data should in turn lead to a complete set of:
“Drawings showing the building and services installations as installed at the date of practical completion. The main features of the record drawings should be as follows:
· The drawings should be to a scale not less than that of the installation drawings.
· The drawings should show locations of all the mechanical, electrical and public health systems and components installed including ducts, pipes, cables, busbars, plant items, pumps, fans, valves, dampers, control devices, strainers, terminals, electrical switchgear and components, security and fire sensors and control equipment.
· The drawings should be labelled with appropriate pipe, duct and cable sizes, pressures and flow rates.
· The drawings should have marked on them positions of access points for operating and maintenance
· The drawings should not be dimensioned unless the inclusion of a dimension is considered necessary for location.
As the RICS Digital Champion, a disruptive PQS, previously frustrated Construction Manager, turned Digital Twin ambassador and now Strategic Advisor in all things digital construction, I am convinced that if we were to chronologically check every as-built drawing and compare it to the ‘physical’ building itself – there will be material difference(s) between the two. I also accept that ‘differences’ will always occur due to the inherent nature of the construction process, but when ‘any difference’ has the potential to unearth and facilitate a tragedy, akin to that of Grenfell Tower, the only question that I would ask of any responsible asset owner, is “how was that risk not identified, contained and ultimately extinguished?"
Credit: HSE via GOV.UK
From October 2023, it is also my informed understanding that the Building Safety Regulator could well be asking the same [or similar] questions of both public and private sector housing professionals [i.e. the Accountable Person(s)]; so preparedness for this inevitability should be high on the ‘organisational risk register’ for any, morally adept asset owner generally, but specifically all those that own and manage any existing ‘in-scope’ building(s), at the time of writing [1st January 2023].
The role of ‘as-built’ information has always been mission critical and in much of my own dispute resolution work, I am always reminded that ‘he who asserts must prove’ [also deployed in my thesis of 1994]. However, it is now upto to the ‘Accountable Person(s)’ / asset owner(s) to prove, beyond any reasonable doubt, that their residential building(s) are safe to occupy. To that end, the real and only question that remains is, “is/are your ‘in-scope’ building(s) catering to the needs of your residents and does your ‘as-built’ information suitably corroborate and confirm this?.......”
Credit: RICS | Tech Partners
As an NED of a progressive and reputable, London-based housing organisation, with circa 10,000 units under management, our talented Senior Exec team, fellow Board Members and myself are all acutely aware of our legal, multi-faceted obligation(s) to our Customers and Residents. Each and everyone of our Customers at RHP - whilst they reside within any of our homes - and who remains king [and queen!] now has more powers to wield to ensure that we are doing our best to maintain their safety and well-being. Collectively, we remain fully accountable to each and everyone one of them. The consequence of any failure across the public and private sector [by an Accountable Person / Duty Holder], to step-up and own this intrinsic responsibility regarding the day-to-day ‘regulated delivery’ of our core business, could result in another Grenfell Tower disaster. The competence of persons employed and/or engaged in the delivery of the construction and/or asset management process – over the whole and economic life of any built asset – is now required to be vigorously documented, held on record and maintained [ideally] in an immutable, digital format.
Credit: HSE via BSR website
So please, let us start the ‘urgent and tangible’ conversation now in January 2023 and undertake the ever important groundwork in preparedness for the thousands of Building Safety Cases [including the Resident Engagement Strategies] that are now ‘legally’ required to be submitted. Personally, I am excited by the UK Govt sponsored ‘generational reform’ imposed upon the built-environment professional, instigated by the presence of this new Act. I am also keen to support the sector to prepare for ‘future enforcement’ by the HSE-Building Safety Regulator, prior to, during and beyond the registration period which officially begins in April 2023.
With purpose, trust and function [i.e. the Gemini Principles] as my core tenets of thought / amidst the legacy of my work at the University of Cambridge - Centre for Digital Built Britain; my unapologetic, over-arching ambition is to inspire the housing sector into submission and improve wide-scale adoption of the digital twin solut
An urgent reminder to the sector – 12months left to prepare [posted October 2022]