Written evidence submitted by the National Federation of Roofing Contractors (NFRC), Liquid Roofing and Waterproofing Association (LRWA), and Single Ply Roofing Association (SPRA) [BSB 132]


To whom it may concern


We write on behalf of the above industry trade associations representing the vast majority of individuals and organisations with business interest in the flat roofing sector of the construction industry. The scope of membership of our collective trade associations represent product manufacturers as well as installing contractors; and guidance from our respective organisations is extensively used by the building design sector and constructors in the specification and delivery of flat roofing systems in the United Kingdom and further afield.


Below we provide a response to the Draft Building Safety Bill (CP 264) presented to Parliament by the Secretary of State for Housing, Communities and Local Government in July 2020.


Our collective associations broadly support the Bill in its content and fully its aim in improving standards and clarity on all matters pertaining to building safety. However, we have some concerns relating, at this stage, specifically to Schedule 8 ‘Construction product regulations and within, Clause 7 ‘Safety-critical products.


In the main these concerns relate to labelling or listing construction products as ‘safe’ or ‘unsafe’ and the lack of consideration of the safety performance of the ‘system’ as a whole made up of individual products. An example from the flat roofing sector is given below only to illustrate the point of concern but the point could clearly relate to other construction sectors where compliance with Building Regulations is based on a systems test approach.

Approved Document B requires that all flat roof systems require a European classification (e.g. BROOF (t4), CROOF (t4), etc) in accordance with BS EN 13501-5 in relation to external fire performance. This classification is determined by a systems-based test.

The flat roofing ‘system’ is made up of a number of different products, critical to overall performance, not just fire. The products within the system can include waterproofing membranes, insulation boards as well as air and vapour control membranes: depending on the means of attachment or ballasting for security against wind uplift, other products will be required.

The concern with Clause 8 is that some products may be labelled as ‘unsafe’ generally, but in the context of the above test are safe when used as part of a flat roofing system and can demonstrate compliance with Approved Document B and thereby the Building Regulations. This could clearly lead to the unintended consequence of some products being labelled as ‘unsafe’ but are actually safe when used as part of a system-based test. It is our understanding that it is not the intention of the proposed legislation to exclude such products from being used in a systems approach as outlined in the flat roofing example above, provided that system can demonstrate compliance.

A ‘safe’ or ‘unsafe’ descriptor for a construction product may cause industry confusion as in certain cases it is the system that is tested and classified for compliance as demonstrated in the flat roofing example above. Understandably, on the grounds of safety, in giving assurance to residents and other building occupiers, building stakeholders including specifiers/designers may not wish to have products listed as ‘unsafe’, used for their own or any project.

The proposed legislation as it progresses, and the detail evolves, will hopefully allow further discussion concerning Schedule 8, making it clear that taking a system approach in many cases to achieve compliance with Approved Document and therefore Building Regulations, is critical.

Our associations are willing to assist government in this critical process as it directly affects flat roofing but as outlined earlier, but we believe this approach could also be beneficial in developing clarity in other construction sectors with similar concerns.

As previously indicated, the flat roofing industry from our collective associations standpoint, welcomes this Bill and sees it as a means to improving standards and clarity on all matters pertaining to building safety. Furthermore, we hope further legislation in this area will also assist in bringing clarity at all levels in construction, enabling clear understanding regarding what is a safely constructed building. This will also hopefully address conflicting interpretation of safety and compliance often experienced at site level.

We appreciate the opportunity to raise these concerns and look forward to any further engagement and meaningful discussion in relation to the proposed legislation.


September 2020