Colt, Compliance and Competence

Posted by Conor Logan on 20/11/19 10:00

Grenfell TowerFollowing the tragic events at Grenfell Tower, the subsequent Hackitt Review into Building Regulations and the ongoing Public Inquiry, Colt is proud to establish their viewpoint on Compliance and Competence.

The word compliance appears in the Hackitt Review Final Report 46 times and competence appears 152 times - these are clearly important terms for the fire safety industry, yet ata recent conference on competence from the Construction Industry Council (CIC) working groups representing specific sections of the construction industry struggled to provide a clear single interpretation of what competence really means.

At Colt we strive to deliver our projects in an ethical, compliant and competent way, but what does this really mean and how do we demonstrate that we deliver on this commitment?

Ethical is captured by terms such as legal, honest, decent and truthful but also described by integrity, respect, rigour and leadership.

Colt demonstrates leadership not by market position but from a duty of care. We endeavour to lead by commitment to educating our customers and our supply chain, by developing standards and guidance through partners such as CEN, BSi and trade associations such as CIC and the Smoke Control Association but also engaging with regulators such as MHCLG and other government departments, Building Control bodies, fire brigades and others.

What does Compliance mean to Colt?

Compliance to Colt means an adherence to standards and regulations, but this has to be tempered through practical knowledge and application not a blinkered, unthinking adherence, as not all standards and regulations fit all buildings and applications. Adherence needs to be considered, practicable and justifiable. There will always be occasional instances where non-conformance and deviation needs to be considered and this will be assessed and proposed on a case by case basis. Where non-conformance is unavoidable, Colt will takes steps to ensure the client is clearly aware of the decision taken and the reasons for it, and of any subsequent compromises and potential consequences.

What does Competence mean to Colt?

It could be argued that competence could be demonstrated by signing up to quality management systems such as ISO 9001 and at Colt we have numerous qualifications, which we are more than happy to offer for review, but competence is really so much more.

Following Grenfell, the Smoke Control Association launched a 3rd party certification scheme, under the governance of International Fire Consultants Certification (IFCC). Colt was the first to gain certification which verified our ability to follow a design, install, commission and maintain smoke control systems, smoke curtains and fire curtains.

We are also developing a summary of all operational staff, whether directly employed or sub-contracted so that each individual involved in a project in any technical or related capacity, has a ‘competence passport’ to summarize their skills, knowledge and experience.

We welcome scrutiny, we are proud of our processes and believe that the way we deliver our life safety installations is the best in our industry and we continue to learn and strive to be better.
However, competence, as indicated above, is a hard concept to define and is not simply a matter of collecting certificates through audit trails. At Colt we conclude competence to be an amalgamation of knowledge, skills, training, experience and limitations - knowing the how, what, where, when and why we do what we do - but also knowing where to stop and draw the line, the red line that we cannot justify crossing.

Knowledge and skills encompass employing the right people for the right jobs. For example, our technical team is drawn from graduate engineers as a minimum, Masters degrees are preferable, but even these are employed at a trainee level, with a clear plan to mentor, develop and train them to understand the limitations in their skills. Where knowledge is lacking, training is provided to fill the gap. Experience is provided in a controlled, supervised environment where a mentor can explain the importance of the information being provided and support professional development over a period of time.

We recognise that many people think they are competent beyond their present expertise and this is where limitations must be respected - all of our processes are developed so that critical functions are subject to a peer review process. For example, all technical reports are reviewed by a senior engineer, all drawings for construction are reviewed by the technical team for content and by the operations team for scope.

So competence is not just about knowing what is the right way to do the job, it is equally about knowing what is the wrong way to do it and about knowing where a person’s knowledge, skills and experience stops. We encourage our staff to question what they see, to stop when they are unsure and call out when they see something that is wrong.

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Topics: Smoke Control