It was only after I finished delivering a CPD seminar on changes to the Building Regulations for RIBA Northern Region yesterday that I realised the new Approved Document K is a year old. That set me wondering: how has the new AD K doing? Is it everything we hoped for, or is it still awkward in places?
Looking at the macro level, the revision of AD K, coupled with the euthanasia of AD N and the excisions to AD M, was meant to remove clashes between different requirements and bring together much of the guidance into one place. How did that go?
Parts of it have done very well: there really was no justification for having AD N and AD M both giving guidance on manifestation of glazing, and no sensible reason why there should be guidance on the layout and configuration of stairs in two different documents. Bringing all of those together in one place has been a Good Thing. But – always a but – the longer I look at it the more annoying it is to see that requirements for stairs and ramps on access routes as still there in AD M, even though those requirements are, save one point, identical to those given in AD K. With a bolder approach DCLG could have got all the guidance on stairs into one place.
Turning to the Approved Document itself, one of the big changes was the move to ‘plain english’, and a one column layout better suited to reading on screen. That gets a thumbs up. Much as I might like the passive voice – mainly I think for its (?erroneous) sense of neutrality – it can become an obstacle to understanding. Personally, I find it difficult to judge if the new-style AD K is easier to understand, as I have spent so long reading and working with the old-style approved documents. I think, for guidance, it does work better, certainly where there are definite rules. A ‘do this’ is better to work with than an ‘ensure that’. Reading through, there are points when I catch what seems to be an unreformed sentence (the maximum dimensions for … are shown in Diagram 5.2), but on the whole the new style of language works.
One part of the revision which does seem problematic is the division of guidance by building type. For example, when looking at handrails, the guidance addresses:
- All buildings
- Buildings other than dwellings and common access areas in buildings that contain flats and do not have passenger lifts
- Buildings other than dwellings
That is quite a set of distinctions to work round. It also, on occasion, leaves some gaps. What happens in common access areas in buildings that contain flats and do have a passenger lift? Should they follow all the guidance for buildings other than dwellings, or do we just go with the all buildings guidance?
There are five categories overall, not each of which is mentioned in each set of divisions, which leaves me wondering what building type a particular piece of guidance applies to, or how it applies. If I wanted to give DCLG anything as a corporate Christmas present it would be Occam’s Razor: entia non sunt multiplicanda praeter necessitatem (entities must not be multiplied beyond necessity). The Department simply loves making lots of different classifications of building types.
Finally, there is the guidance itself. The promise was ‘There are no new technical requirements’. That is true, but there have been changes within the requirements. A minor change has been the reduction in soffit height which requires guarding from 2.1 m in AD M, to 2.0 m in AD K 2013. That isn’t a substantial change. However, as someone pointed out at the CPD seminar, the widths of stairs have changed. AD K 1998 did not specify a minimum width for stairs, it merely require stairs wider than 1800 mm to be divided with handrails: the limits on widths of stairs were in AD B; 1000 mm for institutional buildings, 1100 mm in an assembly building and 800 mm in other non-dwellings. AD K 2013 requires a minimum width of 1200 mm between walls, strings or up stands and 1000 mm between handrails. That is an extra 200 mm in many cases, which, to my mind constitutes a significant change.
So how is Approved Document K 2013 doing? Overall, it gets a pass, and in places reaches merit standard, but still falls some way short of a distinction.