Make Your Voice Heard on Approved Document Q

If you’re just getting to grips with the upcoming changes to Part L and Part F of the Building Regs – and wondering what Part O even means – you probably won’t want to think about any more legislative changes which might impact on your business.

However, I want to sound the alarm that the consultation on PAS24: 2022 has just closed, and a new updated security standard is definitely on the way. I hope as many people as possible had the chance to make their thoughts known, because, as we all know, once the consultation on a new standard is over, it’s too late to complain about the implications.

The significance of the updated PAS24: 2022 is that it will be referenced in the new Approved Document Q, which we could expect to see implemented as early as Summer next year. And, while we have all got used to Approved Document Q requiring PAS24: 2012 in new builds and change of use installations, the expectation seems to be that, from 2023, ADQ will require PAS24 2022 accreditation for the replacement market as well.

Within the consultation document are higher specifications for hardware and additional requirements for doors such as security chains and spy holes. And what looks like a reinforcement of the requirement for doorsets, coupled side panels and accessible windows to include at least one pane of Class P1A laminated glass.

I’ve read the proposed standard several times and, like others who have responded to the consultation, I’ve asked for clarification on whether the requirement is for laminated glass in ALL vulnerable windows or just for windows next to doors.

If it is all accessible windows, then there is currently not enough capacity in the glass market to meet that scale of demand for laminated glass and there will need to be huge investments made in production to avoid massive bottlenecks.

Even if it is only windows adjacent to doors, then consideration will still need to be given to the negative impact a switch to laminated glass would have on the thermal performance of those products. We’re already seeing a situation where the thermal efficiency of windows which meet the requirements of the new Part L is being compromised by the addition of trickle vents in line with Part F; and we could potentially face another situation where two parts of the Building Regs are seemingly in conflict with each other.

I’ve said many times that there is too much emphasis in the Building Regs on energy ratings and ventilation and not enough on security. I’m sure Mr and Mrs Jones would prioritise security over efficiency – particularly when they learn that even a top A rated window will have to have a slot cut in it to allow air to flow through!

Some fabricators will obviously welcome the extension of PAS24 testing into the replacement market as they will see it as levelling the playing field. They have been supplying PAS24 complaint windows and doors into the replacement market for several years but have seen themselves being undercut on price by others who are selling an advertised security locking product which doesn’t actually comply to any industry standard. There needs to be a broader understanding of the fact that security is not just about the locking hardware that is fitted but about the overall performance of the window or doorset.

Certainly, for those whose offerings aren’t PAS24 accredited, there is likely to be a race to upgrade their products, get their windows and doors tested and accredited, and hopefully start the process of educating the wider market.

At Mila, we are very confident that our security hardware options will provide our customers with everything they need to comply with higher specifications. Our security range includes 1* cylinders and accompanying 2* handles, 3* cylinders, and TS008 compliant anti-fishing letterplates, so fabricators who buy from us can relax knowing that they are in safe hands.

But, as I see it, the challenge for the market is not in complying with new hardware specifications, but rather in a potentially industry-wide switch to the Class P1A laminate glass.

Until we get the results of the PAS24: 2022 consultation and have chance to review the proposed new ADQ, it’s impossible to get a clear view. However, I would urge everyone who feels disappointed or frustrated by the apparent contradictions between Part L and Part F to engage with the regulatory process as soon as the option becomes available. We need to make sure that the voice of the industry is heard loud and clear this time around when it comes to security.

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