PAS2035 Concerns regarding reduction of the inherent technical risk scores (Part 1)

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The hope of Trustmark was that the problems with CWI would go away with the introduction of PAS2030/35 as a result of the Each Home counts review. One of the key strap lines being 'no insulation without ventilation; Trutmark would fulfil the  'quality mark' of government endorsed quality and home owners  can relax - there will be strict oversight for once.
The retrofit co-ordinator role was seen as key to bring about a whole house assessment and make impartial recommendations in the best interest of the home owner and it was assumed to be an independent role similar to a building control inspector.

Unfortunately, independence is seldom enforced and is not an absolute requirement. CIGA are gearing up to provide their own in-house retrofit co-ordinator to their members. Not only that but said retrofit co-ordinator can 'reduce the inherent technical risk score' of Cavity wall insulation under PAS2035 simply because Trustmark recognise CIGA as an 'industry quality assurance scheme'.

What this means is, such is the faith that Trustmark have in CIGA , they are happy to let them  bypass large important parts of the PAS related to occupancy, ventilation and damp simply because they are a trustmark scheme provider.  Essentially downgrading the risk of CWI to be the same as installing new LED lightbulbs!

It's likely IAA(CIGA2) will be offering Retrofit co-ordinator for free to its members and such a retrofit coordinator will be under huge pressure from CIGA2's board to take up the opportunity to apply the point reduction of the risk score.

The offering



There were some safeguards regarding conflicts of interest  written into the PAS and so we should  expect CIGA2's retrofit co-ordinator to provide written information to a home owner explaining the potential conflicts of interest, especially when the installer is owned by a CIGA2 director, or a CIGA2 director has shares in an installer. How these conflicts of interest are resolved is not so clear.



What's in a point? -  a worked example
Imagine I am an installer wishing to install CWI into a single dwelling. I will approach a home owner via an internal assessor to review the property and fill in the paperwork. I can then pass the paperwork to CIGA to do the retrofit co-ordinator work.
For the above project we need to do a risk assessment which includes a score for 'inherent technical risk'. PAS has fixed scores for these measures with  CWI (and solid wall insulation) risk scoring 2. As can be seen from table  B.2 . Putting the technical risk onto  Table B.1 this places the project at risk grade B - and the PAS2035 standards for Path B must now be followed.




The important parts of path B include appraisal of occupancy, any vulnerable occupants and a full assessment and if appropriate proposed upgrade to the ventilation system.


This is especially important for CWI and EWI where many of the problems with condensation and health can be attributed to the worsening of clean air/venitlation as clearly described in Kate de Selincourt's article  



Addressing this is all good stuff. However here is where things start to go wrong.

Reduction of Inherent Technical Risk 

Trustmark states that a  reduction of the inherent technical risk scores is permitted "Where the intended Retrofit Installer operates under an ‘industry quality assurance scheme’."

The only two current Recognised Schemes:
  • CIGA Guarantee* under the quality assurance framework of The IAA *
  • SWIGA Guarantee* 
* All three share directorship.

Worked example (revised with 1 point deducted)

Working though the example above again but this time with 1 point deducted for CWI, the easiest route is to simply install CWI alone as the project is now magically Risk grade A - the same risk as installing LED light bulbs.

As a CWI installer under Risk Grade A  I'm over the moon because I only have to document that there is an extractor fan in the bathroom - I do not have to show that it works or is in any way sufficient . It's like 2009 all over again.

This risk reduction is at the discretion of the Retrofit co-ordinator who should be working in the home owners' best interest but by offering retrofit coordinator services for free, CIGA is also squeezing out truly independent retrofit co-ordinators from the industry who may be much better placed to act in the occupier's best interest and choose not apply the risk reduction due to the well documented risks associated with CWI and especially in relation to ventilation.

Are ofgem and Trustmark asleep at the wheel?




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