Written evidence submitted by the National Federation of Roofing Contractors (NFRC) (RDC0092)
This submission to the Public Accounts Committee’s inquiry into the Remediation of Dangerous Cladding has been completed by the National Federation of Roofing Contractors (NFRC) on behalf of two of our Member businesses directly involved in cladding remediation. The opinions expressed in this document are attributable to NFRC Members and do not necessarily reflect NFRC’s position. NFRC is the UK’s largest roofing and cladding trade organisation, with over 1,200 Member businesses at every stage of the supply chain. The following consultation was not an exhaustive investigation of all NFRC Members involved in envelope cladding but instead interviews with two prominent businesses involved at different stages of the supply chain.
The Member businesses have chosen to remain anonymous due to the nature of their claims and the industry's relatively small size. NFRC has confirmed their history of work in the field and their authority to speak on the subjects before the inquiry.
There is a recognised divergence between the two testimonies, arising from their distinct positions in the supply chain. The most prominent difference concerns the current licensing and accreditation processes intended to ensure workmanship quality. One party cites multiple instances of substandard work necessitating redoing, advocating for more stringent statutory competency requirements. The other contends that existing oversight is duplicative, restricts contractor entry, and inflates costs. Regardless of these differing views, it is evident that clearer delineation of responsibilities at each stage is urgently required to address the faulty buildings that still house thousands across the UK.
Through a steering group chaired by NFRC’s Head of Technical and Training Bob Richardson, the industry has developed a competency framework for upskilling rain-screen operatives. Five short-duration courses have been written, and CITB has begun a commission to use the framework to fund training for 60 operatives and 24 supervisors. This is an essential start to building the training infrastructure as a way to demonstrate competence for those working on higher-risk buildings as required under the Building Safety Act. NFRC has been encouraged by MHCLG’s engagement with the competency framework and urges them to continue to expand such education infrastructure into the future.
NFRC would be much obliged to provide additional help to this inquiry and undertake further investigation amongst out membership if desired.
First Testimony
The first testimony comes from the head of QHSE at a major business specialising in the external envelopes of buildings, including high-rise re-cladding projects, industrial roofing/cladding, and new-build façade installations. The interviewee has a broad construction background and began work in cladding remediation after many years in general construction. Their testimony focuses on practical lessons learned and first-hand observations from projects aiming to replace non-compliant or unsafe cladding as part of the government’s cladding remediation push post-Grenfell. It highlights persistent issues such as poor workmanship, regulatory bottlenecks, and lack of clarity around responsibilities.
1. Progress and Timelines on Identification and Remediation
High Degree of Unknowns
Unlike new-build projects, re-cladding works often encounter unforeseen conditions after work begins. Exploratory surveys may miss hidden defects or previously undisclosed variations.
Designs may need frequent alteration when previously unknown issues emerge on different elevations—causing new rounds of approvals and delays.
Regulatory Process for Re-Cladding
The Building Safety Regulator (BSR) process under the new legislation is currently unified for both new builds and re-cladding. This does not fully account for the unpredictability and iterative nature of refurbishment projects.
Every major design change or discovery triggers a new re-submittal and extended waiting period, which is critically slowing down the process of making buildings safe, putting residents at risk.
Recommendation: Split Off and Fast-Track Re-Cladding
Propose that the BSR implement a dedicated track for refurbishment projects, distinct from the process for new builds.
Specifically, “significant changes” (i.e., unexpected design alterations) should have a faster approval route, preventing works from stalling, often for months at a time.
2. Protection of Taxpayers’ Money
Undercutting and Insolvency
Cases of suspect bidding, where a contractor undercuts all competitors (by up to £1 million) and subsequently goes bust mid-project, are not uncommon.
This leaves incomplete or poorly executed remediation and no clear avenue for the affected residents to secure additional funding to correct the work.
Mismanagement of Funds
Where government grants or private funds are allocated, unscrupulous operators may draw down money and fail to complete the job to a safe standard.
Residents end up with no workable route to further financing when substandard works are discovered—compounding distress.
Recommendation
Introduce more rigorous checks on competency, solvency, and track record before awarding re-cladding projects funded by government or public money.
Potentially ring-fence a “contingency or rescue fund” to salvage incomplete works when the original contractor fails or the job proves more extensive than initial estimates.
Competency of the Building Safety Regulator (BSR) Staff
Some new BSR inspectors have reportedly come from other HSE departments without prior facade or fire-safety backgrounds.
There is a strong learning curve and an industry-wide shortage of deeply experienced façade and cladding experts to fill new BSR posts.
Competency Among Contractors
Historically, some trades were well regulated (e.g., bricklayers, joiners) with standardized training. Facade and cladding, by contrast, evolved rapidly in response to global demand, often lacking a clear, uniform skill pathway.
The National Federation of Roofing Contractors (NFRC) is working on improving training and NVQ (qualification) standards, but the process is ongoing.
Impact on Project Quality
Projects are frequently undertaken by contractors with insufficient specialized knowledge.
The interviewee cites repeated instances of having to remediate or correct half-completed or substandard re-cladding work by previous teams.
Recommendation
Continue enhancing statutory competency requirements and training for all parties involved in re-cladding (from site operatives to project managers, inspectors, and design professionals).
Consider a registration or licensing scheme for cladding-remediation contractors (akin to asbestos-removal licensing) to assure genuine specialist capability.
Fee for Intervention (FFI) Concerns
Interviewee indicates that inspectors often rely on Fee for Intervention (FFI) notices to address even minor issues, which can create distrust and a perception that raising revenue trumps balanced risk mitigation.
At times, the guidance used by inspectors does not have the clarity of statutory regulation, yet it is treated punitively.
Potential Overreach & Practical Realities
Example: A requirement to strip cladding “from the top down” to avoid theoretical fire spread is sometimes mandated, even if bottom-up removal would be equally safe or safer in certain contexts.
In the interviewee’s experience, some guidance seems disconnected from real-world scenarios—e.g., prescribing nightly installation of temporary fire barriers with little evidence it meaningfully reduces risk in every situation.
Recommendation
Encourage science-based, evidence-driven risk assessments and guidance for partial/facade removal rather than blanket mandates.
Shift from revenue-driven enforcement (via FFI) to an educational, consultative approach focusing on genuine life safety outcomes.
Fire Risks Extend Beyond External Cladding
The interviewee notes that internal building products—non-fire-rated insulation, door sets, inadequate fire stopping—are equally critical to occupant safety.
A building can be rendered non-compliant from the inside-out, even if external cladding is perfectly replaced.
Recommending a Holistic Approach
Fire risk must be seen in totality, not merely as an external facade issue.
Each building should undergo a comprehensive safety assessment, covering smoke migration routes, internal compartmentalization, and façade compliance.
Prioritization of Funds
The interviewee acknowledges that simply injecting money will not expedite works unless it is channelled effectively.
If the supply chain lacks sufficient skilled contractors and the BSR backlog remains, extra funding alone will not ensure faster remediation.
Potential Uses for Additional Funding
Fast-Track the Re-Cladding Process
Distinguish re-cladding approvals from new-build approvals under the BSR.
Implement “significant change” fast-tracking so that unavoidable mid-project design amendments do not result in excessive wait times.
Enhance Competency, Licensing, and Oversight
Support ongoing NFRC efforts to strengthen façade and cladding NVQs (or equivalent qualifications).
Explore a registration/licensing scheme specifically for cladding-remediation contractors, ensuring proven expertise, robust insurance, and a track record of compliance.
Proportionate and Evidence-Based Enforcement
Align enforcement with actual risk rather than purely theoretical scenarios or revenue-focused approaches.
Increase funding and capacity for real-world fire testing on partially stripped façades, temporary barriers, and scaffolded projects to refine guidance.
Protect Residents Through Greater Financial Safeguards
Establish or bolster a contingency fund for projects left incomplete due to contractors going insolvent, ensuring residents are not trapped in unsafe conditions or financially penalized.
Tighten due diligence to mitigate potential fraud, undercutting, or repeated cycles of partial, substandard remediation.
Address Internal Fire Safety Defects Alongside Cladding
Avoid a narrow focus on cladding alone. Promote holistic building assessments for all fire safety elements—doors, compartmentation, and internal fire stopping.
Second Testimony
The following second testimony comes from the managing director of a contracting business that has been involved in cladding remediation for around three years. The contractor has direct experience with government-funded projects intended to replace or remediate dangerous cladding. The testimony reflects their observations about procurement, project timelines, costs, insurance, accreditation requirements, and systemic barriers encountered in delivering cladding remediation.
Two-Year Lag from Tender to On-Site Work
Unlike standard construction projects, cladding remediation projects are experiencing significant delays between tender acceptance and starting on-site.
Example: A tender priced in 2022 did not enter the construction phase until 2024, illustrating the large gap.
Reasons for Delay
Impact on Completion Timelines
Unclear Pipeline
Despite government announcements of large funds and the scale of dangerous cladding still unremediated, contractors have reportedly noticed a significant slowdown in inquiries and actual contract awards recently.
It is difficult for contractors to prepare: if a job emerges, they may discover unanticipated accreditation or insurance criteria, which can take months to fulfil, thus causing additional delays.
Contractor Preparedness
Without a central, publicly available register or pipeline of upcoming cladding projects, contractors cannot effectively plan resource allocation, manage insurance coverage, or apply for specific accreditations in advance.
This unpredictability discourages new entrants from investing in the required specializations—exacerbating the shortage of qualified contractors working in the space.
2. Protection of Taxpayers’ Money
Government Department vs. Surveyor vs. Contractor
Typically, a government department or grant administrator appoints a building surveyor who prepares employer’s requirements and coordinates the tender process.
Contractors often do not liaise directly with the government; they work under the surveyor’s or employer’s agent’s direction, leading to indirect communication.
This multi-layered approach can create miscommunication about variations or scope changes.
Mid-Project Variation Disputes
In one cited instance, a necessary building adjustment was overlooked in the initial schedule of works. The contractor carried out the variation, only to face later scrutiny and potential financial clawbacks of over £30,000, even after final certification.
Such retrospective disputes indicate a breakdown in oversight consistency and a potential waste of public funds if contractors avoid future projects due to heightened financial risk and uncertainty.
Lack of Unified Requirements
Different design teams or building surveyors may impose different accreditation and insurance requirements, creating confusion and variability in procurement processes.
This often leads to rework and additional consultations, further delaying the remediation timeline.
2.2 Cost Inflation, Insurance, and Accreditation Pressures
Professional Indemnity (PI) Insurance Cost
For contractors, designers, and surveyors involved in fire safety or cladding remediation, professional indemnity insurance premiums have doubled or tripled—and in some cases, even more.
These inflated premiums then feed into higher contract prices because only a limited pool of companies can afford such coverage.
Excessive Design & Consultancy Fees
Typical design fees on a £500k project might be around £10k–£15k, but for cladding remediation these fees can jump to about £60k or a flat 10% of contract value.
Price spikes reflect both the limited number of qualified professionals and the perceived higher risk but this is limiting competition and reducing the value gained from the public money being spent.
Monopolies
Because cladding remediation requires high insurance cover and specialist accreditations, limited firms are available. This small pool can drive up prices without normal competitive tension.
The restriction of providers effectively grants them a monopoly, which is in turn leading to uniform elevated pricing.
3. The Government’s Approach to Risk Around Building Safety
Barrier to Entry vs. On-Site Checks and Balances
The contractor emphasized that building control, the client’s surveyor, and independent clerks of works are already in place to ensure adherence to safety standards during design and construction phases.
However, additional front-loaded requirements—stringent tendering hurdles, excessive insurance demands, specialised accreditation—raise barriers to entry to a degree which negates the need for later safety enforcement.
Excessive Complexity in Accreditation
Contractors face multiple overlapping accreditation bodies, many verifying the same or similar items. Examples include FIRAS, SafeContractor, CHAS, etc.
Gaining each accreditation can take up to 6–9 months, is expensive, and often duplicates the function of existing health and safety or quality checks.
Potential for Subcontracting Loopholes
When only a limited number of larger contractors are winning cladding remediation work, they can become so overwhelmed that they may subcontract projects to smaller firms that did not initially qualify. This can add layers of cost and reduce transparency.
This approach effectively nullifies stringent front-end hurdles, since on-site checks should already safeguard quality.
4. Plans for Deploying the £1bn for Cladding Remediation Effectively and Efficiently
Establish a Centralized Project Register
If possible, create a publicly accessible database listing:
Contractors can then plan and invest in relevant accreditation or insurance coverage, reducing last-minute bottlenecks.
Standardize Accreditation Requirements
Develop a unified, government-endorsed framework for minimum accreditation and insurance thresholds—recognising equivalences among different schemes (e.g., FIRAS, SafeContractor, CHAS).
Similar to the Safety Schemes in Procurement (SSIP) model, accept one recognised accreditation in lieu of multiple duplicative ones.
Limit Additional Intermediary Fees
Encourage thorough building control checks and the use of a client’s representative (e.g., a clerk of works) rather than multiple overlapping design consultancies or high-level fee structures.
Set reasonable caps on certain professional fees in government-funded remediation to safeguard public investment.
Balance Risk Management with Market Competition
Maintain robust on-site inspection from building control and independent clerks of works, but reduce front-end barriers that block qualified yet smaller or newer contractors.
Adopt an approach that focuses on actual work quality, rather than purely historical record or large corporate capacity, to encourage a wider pool of capable contractors.
Long-Term Collaborative Frameworks
Create multi-year frameworks where contractors can join if they meet core criteria.
This consistency helps with cost forecasting and ensures a broad range of accredited contractors is available to handle the workload, preventing artificial monopolies.