Grenfell Tower: why the ACM panels were in compliance with the building regulations.

The Government testing program

The Grenfell Tower calamity highlighted the possible danger of employing combustible cladding on high rise buildings. Of the two main cladding components, the aluminium polyethylene (PE) composite rainscreen outer cladding panels, and the polyisocyanurate (PIR) insulation boards, it was the ACM panels that have generally been thought – probably rightly in my view, as I have argued previously –  to have been the primary cause of the disastrous rapid spread of the fire over the external surface of the building.

The Government acted with commendable speed and efficiency by requiring Local Authorities and Housing Associations to identify by end of day 19 June any ACM panels in use on their high rise buildings, and to send in samples for testing.

In its letter to the Chief Executives, the Department for Communities and Local Government (DCLG) claimed that to be compliant with ‘Building Regulations guidance’, the core of the panels should be composed of a material of ‘limited combustibility’, as defined in Approved Document B2 at Table A7, or be Euro Class A2 or better:

I outlined the Approved Document guidance for cladding systems in an earlier post. In brief, in AD B2 at 12.5, two routes to compliance are offered:

i) through adherence to the requirements of sub-sections 12.6-9 or;

ii) through large-scale system testing to BS 8414.

The DCLG, in its letter, was in effect assuming that the second route had not been taken, so that it was the requirements of 12.6 to 12.9 that were to be satisfied. In summary, 12.6 specifies that:

external surfaces over 18m should be national Class 0 or Euro Class B or better;

while 12.7 requires that for buildings over 18m:

insulation products, filler material etc should be of ‘limited combustibility’ as defined in the Table A7 mentioned in the DCLG’s letter. A material or product must either be 99% or more inorganic, or pass a 750° C furnace test (BS 476 part 11 or part 4), or have an incombustible core, or be Euro Class A2 or better.

I concluded in an earlier post that of the two main components of the Grenfell Tower system, only the Celotex RS5000 insulation boards were in breach of the Approved Document guidance, since it was only these that were covered by 12.7. The Reynobond PE cladding panels, not being an insulation product, and having a Class B rating, were in compliance with the relevant section, which is 12.6.

It is easy to see the difficulty for the government of admitting that the polyethylene cored cladding panels were compliant with the Approved Document guidance. It had been their responsibility to ensure that the regulations were fit for purpose and did not permit dangerous products to be used. These panels were certainly dangerous, in the use to which they were put. If a way could be found to assert that the regulations did not in fact permit the panels to be used, then this could potentially allow them to escape culpability in this regard.

Moreover, it was no doubt felt to be imperative to get any similar panels off the nations high rise buildings as soon as possible. It would probably be easier to force immediate action if the panels could be deemed to be non-compliant with the official guidance, than if it were admitted that they had been designed and installed in accord with it.

It is not particularly surprising, therefore, that the DCLG is currently pretending (if I may be so bold) that combustible ACM panels are in breach of the Approved Document guidance. In this post, I critically analyse the ways in which the Department has attempted to justify their position.

Continue reading Grenfell Tower: why the ACM panels were in compliance with the building regulations.

Grenfell Tower and the EU: a North-Booker red herring (3/3)

(continued from Part 2)

As a recap, I will try to summarise the position put forward by North and Booker in a number of articles and blog posts:

  1. During 1999-2000 the MPs of the EFRA Committee wanted to replace the existing fire standard EN 13501-1 with one based on a more realistic large-scale test (now BS 8414);
  2. They were unable to do so because as EU members we were obliged to adopt the European standard EN 13501-1;
  3. EN 13501-1 is based on the small-scale surface test EN 13823;
  4. This surface test is quite inadequate to test products with good surface ratings but combustible cores;
  5. If we had been able to make BS 8414 mandatory, then the Grenfell Tower fire would never have happened, since the system employed there would have failed the test;
  6. The EU was laggardly in developing a large-scale test which could then have been made compulsory;
  7. Because of point 2 and point 6, the EU bears a measure of responsibility for the fire.

I pointed out in my last post that in 1999-2000 the cladding regulations were based on four British standards BS 476 parts 7, 6, 11 and 4, and not on any European standard. Nevertheless the European standard was introduced in 2002 and its adoption was indeed compulsory. So the prospect of its adoption could conceivably still have influenced decision-making at an earlier date.

I also showed that the EFRA Committee recommended two routes to compliance:

a) through use of non-combustible materials, or

b) through a large-scale system test.

I then observed that in 2005 Scotland adopted a regulatory approach almost identical to that recommended by the Committee.

Since England and Wales are in the EU as much as Scotland is, it follows that we were also free to adopt this approach.

According to North, EN 13501-1 is based on a surface test only. The question then arises as to how Scotland has implemented their approach, with one route to compliance being through the use of non-combustible materials, if the only test available is a surface test?

The answer, very simply, is that North is mistaken and that EN 13501-1 is a classification standard which ranks construction products according to their performance in two or more of four tests, of which two are surface tests, and two combustibility tests. We are therefore free to raise our regulatory requirements at any time, simply by specifying a higher Euro Class.

I will begin by showing that this has been North’s understanding of EN 13501-1, and then explain the real situation.

Continue reading Grenfell Tower and the EU: a North-Booker red herring (3/3)

Grenfell Tower and the EU: a North-Booker red herring (2/3)

(continued from part 1)

Booker and North’s main argument, as I understand it, is that:

  1. The 1999 EFRA Committee recommended that the BS 8414 large-scale system test should have been made mandatory for cladding systems.
  2. Our membership of the EU prevented this being done.
  3. If it had been done, the Grenfell Tower fire would not have happened.

In this post, I demonstrate that the EFRA Committee did not in fact recommend making the BS 8414 test mandatory. Instead they proposed two alternative routes to compliance:

a) through the use of non-combustible materials;

b) through the BS 8414 test.

I also show that Scotland did adopt a regulatory system of this type in 2005. Since Scotland is in the EU as much as England and Wales are, this in itself rather proves that membership of the EU presented no obstacle to the Westminster government adopting a similar system.

Continue reading Grenfell Tower and the EU: a North-Booker red herring (2/3)

Grenfell Tower and the EU: a North-Booker red herring (1/3)

Christopher Booker has argued (1 July 2017, also here)  that our EU membership has been a contributory factor to the Grenfell Tower disaster. He claims that a Commons committee, set up to investigate the fire risks of cladding on multi-storey blocks, had wanted to replace the European standard EN 13501-1 with the British standard BS 8414, but had been unable to, because of the former standard’s mandatory status in the EU:

Again, as his conclusion, he argues that:

if only full compliance with the BS 8414 standard could have been made mandatory  … that fearful conflagration would never have happened.

This is putting a great deal of responsibility for the Grenfell disaster on our EU membership, an assignment of blame which I believe is entirely misplaced.

Continue reading Grenfell Tower and the EU: a North-Booker red herring (1/3)

Grenfell Tower: was the cladding legal or not (part 3)?

In my previous two posts (part 1, part 2) I have outlined the two routes offered by the Building Regulations 2010 Approved Document B (Vol. 2) at B4 (‘External Fire Spread’) to meet the statutory requirement that:

The external walls of the building shall adequately resist the spread of fire over the walls…

The first route, also sometimes called Option 1, or the ‘linear option’, is to satisfy the requirements of paragraphs 12.6 to 12.9. With regard to the fire properties of materials used in cladding systems for buildings over 18m in height, the requirements are in brief:

a) 12.6. External surfaces should be UK Class 0 OR European Class B or better. The relevant UK tests are BS 476-7 and BS 476-6. The European tests are EN ISO 11925-2 and EN 13823. All four tests are surface tests.

b) 12.7 Insulation products should be of ‘limited combustibility’. They should pass EITHER the BS 476-11 750º C furnace test OR the EN ISO 1182 750º C furnace test OR the EN ISO 1716 calorific test. These are combustibility tests.

The second route, also sometimes called Option 2, is for the entire cladding system to pass a large-scale test to BS 8414.

I will now describe the fire properties of the main two components used in the cladding system at Grenfell Tower, and discuss whether they could satisfy the Approved Document B4 requirements, through either of these two routes.

Continue reading Grenfell Tower: was the cladding legal or not (part 3)?

Grenfell Tower: was the cladding legal or not (part 2)?

In my last post, I pointed out the statutory requirement, contained in Article B4(1) of Schedule 1 of The Building Regulations 2010, that:

The external walls of the building shall adequately resist the spread of fire over the walls…

I then began to examine the guidance given by the government in Approved Document, Volume 2, at the corresponding part B4, as to how this statutory requirement can be met. Two alternative routes to compliance are given in Section 12.5:

In my last post also, I examined the provisions of paragraphs 12.6 to 12.9 and in particular of 12.6 and 12.7 which concern the fire properties of the materials used in construction. I explained that, for buildings over 18m high:

a) The requirement of 12.6 can be satisfied if the materials are UK Class 0. This classification can be achieved through satisfactory performance in two UK fire tests, BS 476 part 7 ‘Surface Spread of Flame’; and part 6 ‘Fire Propagation’. In both of these it is the surface of the board or panel that is subjected to assault by fire.

b) The requirements of 12.7 appear to apply to insulation products only.  The materials must either survive trial by a furnace at 750° C, or have a calorific value of less than 3 MJ/kg. I argue that no material with a substantial component of a polymer like the PIR of the Celotex boards, or the PE of the Reynobond panels, could possibly pass these tests.

In this post I describe the BS 8414 fire test, which is offered as an alternative route to compliance at paragraph 12.5. In following posts I plan to:

Continue reading Grenfell Tower: was the cladding legal or not (part 2)?

Grenfell Tower: was the cladding legal or not (Part 1)?


Philip Hammond, the Chancellor, claimed on the Andrew Marr Show on 18 June 2017 that the cladding that was used on Grenfell tower is banned in the UK:

Was he right?

I will argue here that, from a practical point of view, this flammable cladding cannot legally be used in the UK on buildings over 18m in height. It is not that there is an explicit ban on the material. It is more that there is no way that it could ever meet the requirements of the Building Regulations, at least as interpreted by the standard industry guidance. From a practical point of view, it is not a marginal question. Aluminium composite panels with a polyethylene core are highly combustible and should never be used on high buildings. If, as has been reported, these panels are in place on other tower blocks, they should be removed immediately, or the residents evacuated.

Continue reading Grenfell Tower: was the cladding legal or not (Part 1)?

Psalm 89 in Brian Simmons’ Passion ‘Translation’ (part 1): making interpretive decisions for the reader

Psalm 89.27 (28 in the Hebrew bible) reads:

אַף־אָ֭נִי בְּכֹ֣ור אֶתְּנֵ֑הוּ עֶ֝לְיֹ֗ון לְמַלְכֵי־אָֽרֶץ׃

Here are a few translations into English:

Also I will make him my firstborn, higher than the kings of the earth. [KJV]
I also will make him [my] first-born, The highest of the kings of the earth. ASV
And I will make him the first-born, the highest of the kings of the earth. RSV
“I also shall make him My firstborn, The highest of the kings of the earth. NASB
And I will appoint him to be my firstborn, the most exalted of the kings of the earth. NIV
Also I will make him my firstborn, The highest of the kings of the earth. NKJV
I will make him the firstborn, the highest of the kings of the earth. NRSV
And I will make him the firstborn, the highest of the kings of the earth. ESV

The differences between the translations are fairly minor. The NIV has ‘appoint’ rather than ‘make’. Several have ‘my first-born’ rather than ‘the first-born’, but all of these except the NIV mark ‘my’ with italics or square brackets to show that it is not in the original text. The KJV has ‘higher than’ the kings of the earth, rather than the ‘highest of’ the kings of the earth.

In Brian Simmons’ book ‘The Psalms: Poetry on Fire’, however, this verse has been changed into something very different:

I am setting him apart, favoring him as my firstborn son. I will make him like unto me, the most high king in all the earth!

According to Simmons, God seems to describe Himself as ‘the most high king in all the earth’, and say that He will make someone (‘him’) like Himself, particularly in this aspect of being the highest king in the earth. But who is this someone, in the original, and in Simmons’ version?

Continue reading Psalm 89 in Brian Simmons’ Passion ‘Translation’ (part 1): making interpretive decisions for the reader

Psalm 78.41 in the Passion ‘Translation’: did Israel wound ‘the Holy One’ as Brian Simmons pretends?

Psalm 78.41 reads:

וַיָּשׁ֣וּבוּ וַיְנַסּ֣וּ אֵ֑ל וּקְדֹ֖ושׁ יִשְׂרָאֵ֣ל הִתְווּ׃

The NASB, as an example of a normal translation, reads:

Again and again they tempted God,

And pained the Holy One of Israel.

The NKJV reads:

Yes, again and again they tempted God, 

And limited the Holy One of Israel.

with a very different meaning for הִתְווּ (hīṯwû) in the second part of the verse. We will see that there is a genuine difficulty in ascertaining the meaning of the word.

The ASV reads:

And they turned again and tempted God, 

And provoked the Holy One of Israel.

Here, the translators have rendered וַיָּשׁ֣וּבוּ (wayyāšûḇû) with ‘and they turned again’ rather than with ‘again and again’. The verb שׁוּב (šûḇ) in its Qal form as here, can mean ‘turn back’, ‘return’, but it can also mean ‘do repeatedly’, so either way of translating is within the lexical range of the word.

psalm 78.41 in the ‘passion translation’

In the ‘Passion Translation’, however, Brian Simmons has this verse as:

Again and again they limited God, preventing him from blessing them. Continually they turned back from him and wounded the Holy One!

We seem to have a new and previously unknown messianic prophecy, conjured out of thin air, so to say. Israel wounded the Holy One, according to Simmons. Is there any justification for translating the verse in this way?

Continue reading Psalm 78.41 in the Passion ‘Translation’: did Israel wound ‘the Holy One’ as Brian Simmons pretends?

Psalm 44.4 in Brian Simmons’ Passion ‘translation’: ‘command deliverances for Jacob’ or ‘decree majesties for Israel’?!

In my last three posts I have looked at three cases in the Psalms where Brian Simmons, in his so-called ‘Passion Translation’, has erased all mention of Jacob. In Psalm 47.4, it is no longer Jacob whom God loves but, apparently, ‘us’, likely the Christian reader. In Psalm 147.19, Simmons has the psalmist apparently speaking of another people of God, apart from Israel. And in Psalm 14.7, he appears to replace the salvation of Israel with the rescue of the poor! Shame on him for changing the holy scripture. I do pray for him that he would realise the great harm that he is doing and repent. I happen to believe that he is sincere and means well, but has been deceived into thinking that God Himself has called him to translate the holy bible. He seems to be partially aware of his lack of scholarly capability as a bible translator, since he apparently said in response to criticism of his work on amazon.com that:

I do not claim to be a “scholar” of the original languages.

It appears that he deleted this comment ten days later, but that it was then retrieved and posted on Holly Pivec’s blog. It carries exactly the same date and time of posting:

as the record of a deleted comment that is still visible on Amazon:

Praise the Lord, who leads us into all truth, and guards His holy people from heresy.   I have nothing against Brian Simmons personally. My reason for pointing out the gross errors and distortions in his so-called translations is that sincere Christians, including young people in particular, are reading them believing them to be the true word of God, translated as accurately as possible from the Greek, Hebrew and Aramaic manuscripts, when in fact they are nothing of the kind. The faith and Christian life of these believers is thus being put in peril through the actions of this very foolish man.

Continue reading Psalm 44.4 in Brian Simmons’ Passion ‘translation’: ‘command deliverances for Jacob’ or ‘decree majesties for Israel’?!