Questions
Respondent Details
Question 1 Respondent details
Name Steve Cooper
Position (if applicable) Director
Organisation (if applicable) Tenos Limited
Address (including postcode) 4th Floor MacLaren House,
Talbot Road,
Manchester
M32 0FP
Telephone number 0161 872 6798
Please state whether you are On behalf of the organisation
responding on behalf of yourself or
the organisation stated above
Question 2 Select one
Please indicate whether you are applying to this consultation
as:
• Builder / Developer
• Designer / Engineer /Surveyor x
• Local Authority
• Building Control Approved Inspector
• Architect
• Manufacturer
• Insurer
• Construction professional
• Fire and Rescue Authority representative
• Property Manager / Housing Association / Landlord
• Landlord representative organisation
• Building Occupier/ Resident
• Tenant representative organisation
• Other interested party (please specify)
Question 3 Yes/No/Don’t Know
a. Do you agree that combustible No.
materials in cladding systems should be
banned?
b. Should the ban be implemented No - we do not agree that combustible
through changes to the law? materials in cladding systems should be
banned outright.
c. If no, how else could the ban be N/A - we do not agree that combustible
achieved? materials in cladding systems should be
banned outright. Combustible external
walls and cladding systems tested to
BS 8414 and meeting appropriate
performance criteria such as BR 135
can be safe provided that the system is
specified competently and installed and
maintained correctly.
Question 4 Yes/No/Don’t Know
Do you agree that the ban should apply:
a. to buildings 18m or over in height? No (see comments under Q4.e)
b. throughout the entire height of the No (see comments under Q4.e)
wall, i.e. both below and above 18m?
c. to high-rise residential buildings only? No (see comments under Q4.e)
d. to all high-rise, non-residential No (see comments under Q4.e)
buildings e.g. offices and other
buildings, as well as residential
buildings?
e. Please provide any further ‘No’ is entered in each case above as
information in relation to your answers we do not agree that combustible
above. materials in cladding systems should be
banned outright.
However, the increase in performance
criteria recommended by standard
guidance for buildings 18m or over in
height is appropriate, and design
solutions should be developed in this
context. Additionally, an increase in the
performance criteria recommended by
standard guidance for buildings where
evacuation may be delayed (e.g. those
operating a phased evacuation protocol,
such as hospitals), irrespective of
height, may be appropriate.
Where restrictions on combustible
materials in the external wall
construction of tall buildings are
recommended or imposed, it would
typically be appropriate to apply these to
the entire height. However, in some
cases, applying controls to only those
parts above 18m may be reasonable.
Question 5 Yes/No/Don’t Know
a. Do you agree that the European Yes, the European classification system
classification system should be used is appropriate for this use. (Note that
and do you consider that Class A2 or Class A2 materials are of limited
better is the correct classification for combustibility, not non-combustible, and
materials to be used in wall would not represent a ‘ban on
construction? combustible materials’ if that is the
Government’s desired outcome.)
In our opinion, Class A2 is the correct
classification for the ‘baseline’ design
guidance for external walls in relevant
buildings but, as above, other materials
and systems tested to BS 8414 and
meeting appropriate performance
criteria such as BR 135 can be safe
provided that the system is specified
competently and installed and
maintained correctly.
b. If no, what class should be allowed in See above.
wall construction and why?
Question 6 Yes/No/Don’t Know
a. Do you agree that a ban should cover We don’t agree that combustible
the entire wall construction? materials should be banned, but any
limitations should apply to the entire
wall construction.
b. If no, what aspects of the wall should N/A
it cover?
c. Should a ban also cover window No, there should be exceptions for small
spandrels, balconies, brise soleil, and elements provided that adequate
similar building elements? justification is given.
c. Please provide any further Any exceptions to limitations should
information in relation to your answers only be permitted if adequately justified
above. by a qualified fire engineer.
Question 7 Yes/No/Don’t Know
a. Do you agree that a limited number of Yes.
wall system components should, by
exception, be exempted from the
proposed ban?
b. If yes, what components should be Sealants, gaskets, etc. (as per current
included on an exemption list and what standard guidance) which do not form a
conditions should be imposed on their continuous and contiguous path for fire
use? spread over the external walls.
Membranes or other components
representing limited fire load in the
context of the overall external wall
construction, and which are
encapsulated by materials of limited
combustibility (e.g. a breather
membrane sited between sheathing
board and mineral wool insulation).
c. Would you recommend an alternative See Q3.c
way of achieving the policy aims stated
above?
Question 8 Yes/No/Don’t Know
Do you agree that:
a. a risk-based approach is appropriate Yes.
for existing buildings?
b. the ban should apply to alterations to No - we do not agree that combustible
existing buildings, including over- materials in cladding systems should be
cladding? banned outright. However, current
guidance may be an appropriate
benchmark for alterations or remedial
works, particularly in respect of over-
cladding.
c. the ban should extend to projects that We do not agree that combustible
have been notified before the ban takes materials in cladding systems should be
effect but work has not begun on site? banned outright.
d. the ban should not affect projects Yes.
where building work has already
begun?
e. Please provide any further A risk-based approach is appropriate for
information in relation to your answers all buildings, providing that those
above. involved in the design, specification,
installation, maintenance and approval
are sufficiently competent.
Question 9 Free text answer
a. Which wall elements are likely to be Sheathing boards, breather
affected by the proposed change – i.e. membranes, certain plastic foam
where they would pass as part of a insulation products, brick slips
cladding system in a BS8414 test but incorporating a plastic foam substrate,
would not meet the proposed Class A2 and certain combustible cladding
or better requirement (e.g. sheathing panels (as evidenced by the BS 8414
boards or vapour barriers)? commissioned by MHCLG in 2017).
b. We understand that since the Grenfell In our experience, the majority of
tower fire, a high proportion of relevant external wall constructions in tall
building work is already using elements buildings still typically contain at least
which meet Class A2 or better. How one of the elements listed above
frequently are elements which do not comprised of combustible materials;
meet the proposed requirement, as and have either been subjected to a
identified in question 3, currently being BS 8414 test and classification to
used on buildings in scope? BR 135; or subject to a specific
engineering assessment by a suitably
qualified fire engineer.
There is no evidence in the public
domain to indicate that buildings clad
with such systems have exhibited rapid
or extensive external fire spread.
c. What the impact of removing access [Question unclear]
to the BS8414 for those buildings
affected by the ban test is likely to be?
d. What types of buildings 18m or over Unknown
are likely to be affected by this change
(e.g. hotels, residential, student
accommodation)? What proportion of
each type would likely be affected by the
proposed change?
e. How much extra cost would typically Unknown
be involved in meeting the proposed
new requirements over and against a
building which meets the current
requirements? (Please provide any
further details.)
f. Please provide any further comments Buildings that are affected are likely to
on the likely impact of this change for become uneconomic, with a resultant
construction (e.g. supply chains) reduction in construction projects. This
will have a severe impact on the entire
construction industry, including
associated manufacturing.
About this consultation
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Annex A
Personal data
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