The CPA’s new proposed Code for Construction Product Information (CCPI) addresses the credibility challenge facing our industry following Grenfell. Catherine Fyfe, Marketing Director at Polypipe and Deputy Chair of the CPA’s Marketing Integrity Group, explains how the Code was formed, its significance in rebuilding trust and why builders’ merchants need to take note.
In the aftermath of the Grenfell disaster, Dame Judith Hackitt was commissioned to carry out an independent review of Building Regulations and fire safety. Her final report – Building A Safer Future – included important recommendations for greater clarity in construction product information. The report also made clear that action was needed to ensure events like Grenfell never happened again.
In taking action to address the findings of the report, the Construction Products Association (CPA) established the Marketing Integrity Group (MIG) in 2018. I was appointed deputy chair of the group to help drive much needed change, ensuring clear, accurate, up-to-date, and unambiguous construction product information is provided by manufacturers and accessible by its users. For merchants, however, the Code impacts in two ways: as manufacturers and users of product information. More on this further down, but firstly, how did the Code come about?
Creating the Code
Our first action was to understand what the industry thought about construction product information. We conducted a Call for Evidence survey in 2019, receiving over 500 responses and almost 200 pages of free text information. It was obvious from the detail submitted that users of product information wanted to see a change, and more structure was necessary. The MIG, made up of industry and product manufacturer representatives from across the construction supply chain, set about creating a new Code of Conduct.
This voluntary Code would ensure construction product manufacturers provide reliable, accurate information – across the entirety of the construction product’s life cycle – so users of product information have all the facts when making decisions about specifying, installing, maintaining and disposing their products.
The Code for Construction Product Information (CCPI), which applies to all construction products, is built around five ‘acid tests’, stemmed from the Call for Evidence survey where most respondents told us that to be trustworthy, product information must be Clear, Accurate, Up-to-date, Accessible and Unambiguous.
The Code has 11 clauses and is broken down into four main sections:
Ensure sign off procedures are in place with accountable technical competent person, that version control is used so the latest information is always available and ending the practice of misleading and/or ambiguous wording or images.
- Core information
Where performance or compliance information is given, it must be supported by evidence.
- Associated information
Ensure information regarding the handling, installation, operation, maintenance, and disposal of construction products is available for the variety of stakeholders of products. This section also covers guarantees and warranties, to ensure manufacturers are transparent about what is covered, excluded, and required to comply with any terms and conditions.
- Support and competence
Ensuring access to the people providing support and advice and ensuring they have sufficient training and knowledge for their role.
Management and Auditing
For this Code of Conduct to be supported, adhered to, and trusted, we also recognised that compliance needs to be independently assessed and verified. We don’t want manufacturers ‘marking their own homework’, but equally, we need to recognise the effort behind compliance.
To create that independence the CPA, with the support of the Considerate Constructors Scheme (CCS), have established Construction Product Information Limited (CPIL) – an independent, not for profit organisation that will be responsible for administering and managing the forthcoming Code, and auditing registrants. While the audit and assessment frameworks are still being developed, the approach will contain an online assessment with human verification. CPIL will have an independent Board as its governance structure with Amanda Long, CEO of CCS also taking on the CEO role for CPIL. All successful assessments will be given a numbered licence, as part of a logo mark, to demonstrate compliance with the CCPI. This licence mark can be used across the manufacturer’s product information to demonstrate their compliance to users. The licence will be valid for one year and subject to ongoing assessment.
What does this mean for builders’ merchants?
The CCPI is intended to create a level playing field within the construction product manufacturing community, ensuring the information they provide, in whatever format that might be, is clear, accurate, up-to-date, accessible and unambiguous. But who is deemed as a manufacturer and why should builders’ merchants take note?
The CCPI’s definition of a manufacturer describes any natural or legal person who places a construction product on the market under their own name or trademark. This extends further to any natural or legal person who changes the intended use of a construction product in such a way that it creates a new construction product and puts that on the market. Therefore, any merchant in the construction industry who is selling ‘bought-in’, ‘own-label’ products, or is creating a system from multiple products, becomes a ‘manufacturer’. At this point, the CCPI applies to you.
If a builders’ merchant does not sell own brand products and only reproduces product information as part of the construction product manufacturer’s downstream supply chain, then as it currently stands, you do not have to adhere to all the clauses in the code. However, if a merchant wanted to use the code-compliant licence mark of the supplying manufacturer, there must exist a formal process which ensures the manufacturer checks, verifies and signs off the product information prior to its use and whereby the merchant agrees to manage appropriate version control processes. This would be part of the manufacturer’s processes and they would have to demonstrate adherence within their CCPI audit.
Have your say
It is important that as part of the CCPI consultation, merchants have their say. Integral to the supply chain of construction products, many merchants will fall under the ‘Manufacturer’ umbrella. So we want to hear from you, particularly around the debates that have arisen on the reproduction of performance certifications with own brands and the generalising of product information so as to not favour one manufacturer’s product over another. For those that don’t fall in the ‘Manufacturer’ category, there is also the opportunity to have your say as a ‘User’ of construction product information. We’re particularly interested in merchant views on the role of a CCPI supporter.
Ideally, we’d like the Code to go live in June 2021, with the first companies being CCPI approved by the end of the year. But before we reach that point, we need the industry’s views – and that includes builders’ merchants.
The Code is a significant development for our industry and one that will mark change for the long-term. Now is your chance to be part of that development. The consultation closes on the 31st March. So visit www.buildingsafely.co.uk/consultation and tell us what you think.