Episode 182 - CIOB Guide to Products Critical to Safe Construction

This week we will be talking about the newly published Guide to Products Critical to Safe Construction by the Chartered Institute of Building. This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

Websites:

• https://www.ciobacademy.org/product/guide-to-products-critical-to-safe-construction/
• https://www.architecture.com/knowledge-and-resources/knowledge-landing-page/what-can-architects-learn-about-new-guidance-around-products-critical-to-safe-construction

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Transcript

Episode 182:

Hello and Welcome to the Part3 with me podcast. 

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I am your host Maria Skoutari and this week we will be talking about the newly published Guide to Products Critical to Safe Construction by the Chartered Institute of Building. Todays’ episode meets PC3 of the Part 3 Criteria.

Back in episode 91 I spoke about the Guide to Managing Safety Critical Elements in Building Construction, which was published jointly by the Chartered Institute of Building and RIBA. This new guide augments and supports the Safety Critical Elements guide.

While the earlier guide looks more on product safety in relation to the construction process, this new guide focuses more on sourcing information and critical product safety data and guidance to evidence compliance. The guide is primarily intended for designers and contractors involved in specifying and selecting products that are critical to safe construction, but it can also be used by clients, project managers, installers, and those responsible for procurement, installation and oversight and who may also have responsibilities as designers or contractors. 

So when it comes to products the guide refers to the regulations the UK generally follows includes the European Construction Products Regulation or CPR Regulation EU No. 305/2011. The UK mark, also known as UKCA mark, can also be used. To use this marking, businesses must ensure they are using a UK approved body for testing and certification for products supplied to the GB market. Whilst the products outlined within those regulations have a number of characteristics, the guide focuses on two key ones - structural safety and fire safety. 

So how does the guide assist with demonstrating compliance under the Building Safety Act:

The guide pursues this by encouraging designers and specifying contractors to take direct responsibility for product safety, rather than relying on others. It also assists them by outlining the key risks to be identified during the design and constructions phases. These include:

• Identification of elements that are critical to safe construction
• Listing the relevant systems and products forming those elements
• Evaluation of the risks
• Assessment of supporting compliance and certifications
• Communications with the supply chain
• Verification of the installed system
• Maintenance of records and any sign-offs  

The methods for demonstrating product compliance tends to vary, as mentioned these tend to be assessed against Building Regulations, European Construction Products Regulations or depending on the specific project needs. Therefore, product compliance would generally follow a few key principles, including:

• Third-Party product certification, for products critical to safe construction this could include a UKAS accredited third-party product certification for example,
• Test Report,
• Technical Assessment - which would look at Design Compliance, Product Certification and Installation Assurance,
• Declaration of performance or Declaration of Conformity,
• Calculations by qualified, competent professionals,
• Data published by trade associations,
• Manufacturers published information.

The aim of these principles are to provide a comprehensive range of evidence supporting compliance to the highest possible level. Where this is not carried out the Principal Designer of Principal Contractor is at risk of failing to maintain the expected level of building safety for the project. 

Principal Designers, Principal Contractors, as well as Designers and Product Suppliers, all have a vital role to play when it comes to product selection:

The PD and PC of course have a duty to control the design and building work respectively and to plan, manage, monitor and coordinate matters related to the design and building work respectively. 

Now, the product supplier has duties to provide accurate and honest declarations on the perfjoamcne of the product and to ensure that the manufacturers product meets the stated performance declaration. It should be noted here that a CE or UK CA mark does not show compliance with the Building Regulations but with the relevant codes. In general, the product supplier will be responsible for the performance of the product, including the Declaration of Performance and other documentation directly related to the product and the designer for assessing the compliance with the Building Regulations.

Now let’s look closer at how the guide assists with product selection by starting with a key definition:

‘A product is critical to safe construction when its failure, omission, or incorrect installation carries a risk of causing serious injury or fatality.’

For example, for fire safety this can include the use of glass within a fire door leaf whereas the glass on its own right is a ‘product’ but it will not provide a safety-critical function unless combined with other products or components to form a fully assembled door. 

The use of products forming systems, if applied correctly, makes a major difference to safety within buildings. There are many factors which should be taken into consideration at the specification and the installation stages. 

As mentioned, the UK follows the European Construction Products Regulation (CPR) for most products, demanding compliance with standards around mechanical resistance, fire safety, and more. Since Brexit, the UKCA mark complements CE marks for the British market, although marking alone isn’t enough!

Under the Building Safety Act 2022, all safety-critical decisions including products specifications, should be recorded within the “Golden Thread” of information and maintained throughout the building’s life.

Alongside statutory regulations, industry codes like the Code for Construction Product Information (CCPI) push for transparent, up-to-date, and unambiguous product data. That’s key for architects, who must base decisions on truthful performance claims.

So what is the process from design to installation of a product:

First, you need to identify which products are critical to safe construction for your project. The guide recommends making a database or a list—don’t just rely on memory or “what we did last time.” Each project and its risks are unique. Focus on understanding the role of each product, system, or element within the building. If you’re working as part of a design team make sure to ask questions. Does this product, in this context, really affect safety?

To assist with this identification process, the guide introduces the HAZID process, which standards for Hazard Identification. The HAZID process is a structured workshop involving a multidisciplinary team to systematically identify and assess potential hazards associated with a building or system. The early stage assessment informs design decisions, highlights areas requiring risk mitigation, and directly supports the identification of products critical to safe construction. The outputs of this process then feed into the design risk register, construction planning and regulatory compliance, ensuring risks are addressed before construction begins. 

While the full HAZID process is typically used on only larger projects, the same principles apply on smaller jobs. A recorded discussion may be sufficient to capture these decisions and demonstrate that the risks associated with products critical to safe construction have been properly considered. 

Then the next step following the identification process is the procurement process. Which assists in ensuring the correct products are used by asking the correct questions of the manufacturer and/or supplier before any agreements to purchase are made. Questions should include the level of supporting compliance documentation available and aspects of final installation. Examples could include, is the product covered by a valid CE and/or UKCA make? Is the respective Declaration of Conformity and/or Declaration of Performance available publicly?, etc.

The design intended and responsibilities should also be clarified with the manufacturer and confirmation obtained that the product is able to satisfy this requirement in the intended end-use application. 

Refer to frameworks like the 2025 “Competence Framework for Procurement in the Built Environment,” and supporters’ pledges like the CCPI Demand-Side Pledge for those specifying and procuring products. This ensures everyone involved has the skills and knowledge to make safe choices.

Then the following step before installation of the product is assessing the requirements with the supply chain and engaging with suppliers in promoting compliance. This ensures products critical to safe construction are correctly managed. The process in engaging the supply chain should begin with formal notification, typically through specifications, purchase orders, or design instructions, explicitly stating that the product is part of a safety-critical system. 

At this point, suppliers should be asked to provide appropriate evidence, including CE or UKCA marking, CCPI declarations, relevant third party certification, and declarations of performance aligned to the intended use. 

Early engagement with suppliers is recommended to determine product suitability and to draw on their technical expertise in identifying limitations, alternatives, or risks of misuse. Evidence of such discussions should be included within the Golden Thread in the form of emails, minutes and so on. Where relevant, suppliers or manufacturers should also provide installation guidance and confirm competency requirements for installers. It should be made clear that incorrect installation could undermine the product’s compliance and overall safety performance. 

If products are proposed for substitution, care should be taken and the responsibility for the design should be confirmed as well as compliance evidence verified, which should form part of a change management process. 

Now if the building is higher risk, changes to products on such buildings must be assessed to determine whether they are major or notifiable, in line with the Building Safety Regulator’s requirements. Any changes which could impact Building Regulations compliance must be clearly justified, documented and notified or approved before implementation. If a product is registered with the CCPI process it could help support the change management process. 

So once this process with identifying the product, evaluating the risks, assessing compliance, procurement and the supply chain, installation can then take place. A product’s compliance is only as good as its installation. Faulty installation can undo all the careful work upstream—invalidating all the great documentation. Correct installation of the product is as important as the product’s compliance. 

Where possible, certified installers can be used specific to the product or system. For example, someone approved for fire door installation should not install other fire-rated systems unless appropriately trained.

At the end of construction, an as-built inspection would be beneficial to be carried out, ideally by an independent, competent body, and record everything. Photographs, test results, and signed checklists can make a world of difference if something goes wrong later.

Once the works have then been completed, comprehensive records for the products critical to safety construction should be produced and maintained throughout the building’s lifecycle in order to provide traceability of the products used. 

This would include documentation of product selection, specification, and compliance with relevant standards, along with manufacturer and supply chain details. This is particularly important for Higher Risk Buildings and the Golden Thread. Any changes should be fully recorded, in accordance with the change management process and justified with updates to drawings and specifications. 

Once construction completes, ongoing safety depends on maintenance records, inspection schedules, and clear instructions for future building managers. This information should be securely stored, digitally accessible, and kept up to date. 

And lastly, the guidance refers to Whole Life Cycle:

Sometimes the “cheapest” product has a short service life, needs frequent replacement, or hard-to-source spare parts. Short-term savings can create massive future headaches or even safety risks. Therefore it is essential to consider the product’s whole life cycle rather than making decisions based on initial cost.

Regulation 7 of the Building Regulations 2010 demands consideration of durability, exposure, and intended use. Therefore each product’s expected service life, maintenance needs, and what might happen if it fails should be assessed ensuring that safety and functionality are not compromised.

To sum up what I discussed today:

• The new guide from CIOB builds on prior resources by emphasising the need for robust evidence—such as certifications, test reports, and technical assessments—to demonstrate compliance with UK Building Regulations and the Building Safety Act, particularly for products critical to structural safety and fire safety.
• It outlines clear duties and responsibilities for principal designers, principal contractors, and product suppliers during the specification, procurement, installation, and record-keeping stages. Each must ensure compliance, maintain accurate documentation, and avoid relying solely on marks like CE or UKCA as proof of building regulations compliance.
• Adopting formal processes (like HAZID) and maintaining a “Golden Thread” of information is essential for identifying, evaluating, and managing risks related to safety-critical products throughout the building’s life cycle, including change management for higher risk buildings.
• Engaging early and effectively with suppliers—and requiring comprehensive documentation and clear installation guidance—helps ensure that safety-critical products are properly specified, installed, and verified, with traceability and accountability supported by formal records and third-party certifications.
• A key principle is to prioritise whole-life performance over upfront cost. Maintenance records, inspection schedules, and ready access to up-to-date documentation ensure ongoing safety and regulatory compliance long after initial installation.