The consultation on the Code for Construction Product Information has closed – so what do we do now?
Author: Ian Exall CIMCIG
The last few months have been pretty busy trying to unpick the draft code for construction product information means (CCPI) and what I think about it. The resumed Grenfell enquiry has continued to show that the construction industry has a lot of work to do to put its house in order. Moving the CCPI from draft to launch will be a key part of that in my view.
For me, it was very important to engage with the CCPI consultation process. To do my bit to help create something that will help our industry to create buildings and environments that are not only safe but do what we want them to do. The code gives a framework not just for safe buildings but buildings that work.
Yes, I think that the CCPI is needed - unfortunately.
Yes, I think that the draft CCPI provides a good framework for the publication of reliable product information so that product users design and / or build correctly. We must remember that the Hackitt Review, quite rightly, highlighted that the failings that led to the Grenfell disaster were widespread across the construction process and not limited to one single product, process or decision. The CCPI is not the silver bullet that will stop this happening again but it will be part of the overall solution.
No, its not perfect but that’s why there is a consultation. The consultation was our second chance to engage with the process and provide feedback. I have seen some material that is very negative about the code and the process. Constructive criticism is healthy. Simply being negative is as much use as a chocolate tea pot!
Criticism has also been levelled at the CPA being the wrong body of people to create something like the CCPI. I disagree with this as I think it is right that the industry is given the opportunity to put its own house in order. From what I have seen this has involved interested parties from outside of the industry which is right.
So what do we do now?
My view is that we shouldn’t wait for the code to be launched.
I have spent quite a lot of time thinking about how the code affects my business and other product manufacturers. Whilst there are several aspects that need further definition or clarification as to what they mean or require (what does a documented sign-off process look like? and how should version control be implemented? For example), I think that there are many elements of the code that we can work on in anticipation of the code being launched. Not just so that compliance can be achieved but because they are best practice and the right thing to do for a responsible, professional business.
Whilst we await the outcome of the consultation and then the actual launch of the code I think it is the perfect time to do a full product audit.
As it happens, in the day job, I need to overhaul the company’s product information. I have used the CCPI criteria to develop a matrix for product literature using the code’s requirements (clauses 4 to 9) as a checklist. Handy! There are quite a lot of elements that are not relevant to our products but, conversely, there are quite a lot of aspects that haven’t been in the literature in the past but will going forward.
The next step is to engage with the various people in the business to pull all of the required content together thus identify the gaps. A lot of work, but not difficult. The tricky bit is mapping the process so that its recorded and signed off correctly. I also need to put some thought into the creation of a version control system. Fortunately the code doesn’t seem to prescribe what this should be as my business is that small that we don’t have the luxury of software or other such tools to map this. So we will have to use something like excel or Word to form a process tracker and log.
We have only just started down this journey but its already started to flag up some interesting questions. I would say that the process of ensuring that you have gathered all of the required information will give you the opportunity to question whether products are actually viable within the range (from a commercial perspective).
I can see many websites being overhauled both in terms of their functionality but, more likely, in respect of their content. The CCPI puts the product website as being the portal to all information about the product. I would suggest that very few websites today really live up to this requirement already.
The part of the CCPI that is causing me the most consternation is that of competency. The Hackitt review has made a big issue of competency across all disciplines in the building procurement process. We have seen this demonstrated within the Grenfell enquiry. Its really important. But the draft CCPI doesn’t give much guidance. We also know that there is a separate work group (Working Group 12 – Construction Products Competence) but we still haven’t seen its output.
I think a lot of companies will have some challenges with competency. Clause 11 of the draft CCPI gives me enough to start thinking about in this respect:
“Have in place a robust training programme (for new and existing personnel) to ensure that anyone conveying ‘Product Information’ is competent to the level of knowledge required for their role.”
- Manufacturers must define a knowledge and competence matrix for all roles that are involved with Product Information’, including all customer-facing roles.
- Show evidence of a maintained training and qualifications register
- Demonstrate understanding from all personnel of where, due to competency, they cannot provide ‘Product Information’
- How you test competence following training given.
- How you assess new starters’ competence levels.
- Consider how you extend this out to your distribution network, who are responsible for communicating your Product Information.
There are some very interesting challenges within this (apart from the obvious creation of an appropriate training programme with minimum competency standards and testing regimes). For me, it has to start with a review of who does what. An appraisal of job descriptions against what your colleagues actually do would be a good thing but I would start with mapping the “commercial” processes (technical support, internal and external sales and marketing) that exist and / or are required. This should be easy if the business has a clear sales and marketing strategy with the appropriate organisation structure in place to deliver it. Game of dominoes anyone???
Setting the bar for each role will be a challenge in itself but assessing members of staff who have been in the job for a while may not be easy either. I suspect that there a huge number or people in customer facing roles that have not been through any formal, recorded or assessed training but do a good job. Looks like some sort of CPD programme may evolve in some companies.
The consultation on the CCPI may well be over but now the work really starts. Use the time well!
Ian Exall is a CIMCIG Committee member and Commercial Director of insulation converter A I M Limited, part of the Performance Technology Group of companies.