4 minute read time.
Join us to discuss the Marketing Integrity Group’s recently published proposed Code for Construction Product Information document ‘Better Data, Safer Building’ and how it relates to the digitisation of manufacturers product data.

 

Introduction


The Code for Construction Product Information (CCPI) is currently under consultation and will have a huge effect on how construction products are marketed in the UK. It has implications for manufacturers and specifiers alike, including marketers, PRs, technical and salespeople working in the construction product sector. This is an opportunity to hear about it and have your questions and concerns aired.


The construction industry is changing as a result of the tragedy at Grenfell. Subsequent government interventions include the Steering Group on Competencies which led the Construction Products Association to set up a Marketing Integrity Group. This group’s stated aim is to address the particular issue of shortcomings in product information identified by Dame Judith Hackitt in Chapter 7 of her report ‘Building A Safer Future’, in relation to marketing.*


Integrity is in our view one of four key elements to avoiding tragedies like Grenfell, alongside information, competence and regulation. On 4th December we wrote about the Marketing Integrity Groups’ work in our article Avoiding Failure: Product Data Post Grenfell and discussed these four essential elements further.


We are delighted that the CPA has now published its Code for Construction Product Information (CCPI) and launched an industry consultation, called ‘Better Data, Safer Building’.

  • You can read the report on the CPA’s microsite here.

  • You can also download pdfs of the questions for providers and users of construction products.


Please note this is a consultation and the document shared is just a first test summary. It is important that manufacturers look at it and ask themselves whether it it’s feasible, what it would involve implementing in their organisation, what the implications are and most importantly, what is missing to make it work. But please read it and take it seriously. If we are going to avoid mistakes in specification, getting information right is crucial.


The consultation opened on 1st February 2021 and runs until 31st March. The IET’s Plain Language Guide Editorial Board is working on a response from a digitisation perspective, and we’d like to hear your views as a manufacturer or user of construction product information to help in our response.

 

An Opportunity to Discuss the Code


Over the course of the last six months, we have built up quite a community of interest and a useful methodology for discussing topics relating to product data in the construction sector, particularly as it relates to manufacturers. To support the MIG’s efforts to deliver a solution, we want to use this community to participate in the consultation.


The consultation document includes the following guidance:

“Whilst we wish to understand Industry’s support for the Code generally, we are particularly seeking feedback on:



  • How easy or difficult each area of the Code will be for your organisation to implement*

  • How long it would take to implement in your organisation*

  • Anything that you see as missing or any specific area of concern or ambiguity

* Whilst these questions are clearly aimed at ‘Manufacturers’, we are also keen for input from Users of ‘Product Information’ as to what this would mean for them, in embracing use of Code-compliant ‘Product Information’.”





We shall be holding an open call on 26th February at 11am to discuss the code and gather evidence and ideas from our community about these and related questions.




The call will follow our normal format with a brief presentation of the topic, followed by an open discussion that all attending can participate in.


Whilst the major part of the call will be this guided discussion, we have also invited Adam Turk, Chair of the Marketing Integrity Group, who is also a CEO of a manufacturer with many years in the industry, to introduce the code and the consultation for us. We shall also be joined by Catherine Fyfe of Polypipe who is deputy chair of the Marketing Integrity Group who will also be available to answer your questions.

Sign up to join the call


Please sign up to join us on the call here, and read the consultation report which introduces the code before you join us. We look forward to hearing your views. You can read an overview of our previous articles and discussions here.


As always, the Zoom Call will be recorded and made available afterwards on this blog.




____________


*Other initiatives related to product information include but are not limited to:

  • The BEIS are looking at information requirements through their Golden Thread Initiative




  • Former Community Member
    Former Community Member
    ",sans-serif">Construction Product Information
    ",sans-serif">Comments on Consultation Document
    ",sans-serif">General Comments
     
    1. ",sans-serif">Manufacturer, Manufacturer's, Construction Product and Product Information should be declared as reserved words. They will then not require quotation marks.
    2. ",sans-serif">In some places where it has been used, "stakeholder(s)" is an inappropriate word, as it is ambiguous or confusing. Use a more specific term appropriate to each usage case.

    ",sans-serif">Foreword from the Marketing Integrity Group Chair

    ",sans-serif">"The Code for Construction Project Information (CCPI) sets a level playing field..."

    ",sans-serif">Code for Construction Product Information

    ",sans-serif">Eleven Robust Ways of Working

    ",sans-serif">Construction Product: Core Information
    ",sans-serif">Item 6: "Make available on your website and in hard copy the descriptive and technical* characteristics of the Construction Product"
    ",sans-serif">*     ["physical" could be just dimensions and weight]
    ",sans-serif">Item 7: "Ensure Product Information is consistent with Manufacturer's supplied products" should be incorporated into Item 2: "Have in place a formal version control process for all Product Information".

    ",sans-serif">Construction Product: Support and Competence
    ",sans-serif">Item 10: "Ensure technical helpline contact details (telephone and/or email) are clearly visible on your website and in hard copy brochures and literature".

    ",sans-serif">Definitions

    ",sans-serif">Product Information (PI)
    ",sans-serif">"Product Information is defined as any information about a Construction Product made available to internal stakeholders* and/or external [potential] users, which includes, but is not limited to, in print, in writing, online, electronically, verbally, by practical demonstration, in an instructional video, or in an advertisement.             
    ",sans-serif">*[Here, the term "stakeholders" is appropriate]
    ",sans-serif">Construction Product
    ",sans-serif">"A Construction Product is defined as a substance (whether in its natural state, refined and/or processed, and supplied in bulk or packaged), or a product (whether a single manufactured item or an assembly of such items procured from various sources) placed on the market and declared by its Manufacturer for an intended use..."

    ",sans-serif">Manufacturers
    ",sans-serif">"The Manufacturer is defined as any natural or legal person who:
    1. ",sans-serif">Is responsible for designing and manufacturing (or having manufactured) a Construction Product and places it on the market under their own name or trademark, or
    2. ",sans-serif">Takes a Construction Product produced as in a) by an Original Equipment Manufacturer [OEM]* and places it on the market under their own name or trademark, or
    ",sans-serif">*     [This is often referred to as "badge engineering" and normally involves enclosing the basic product in a casing and providing it with a User Interface (UI) matching the Manufacturer's regular style and livery]
    1. ",sans-serif">Assembles, packs, processes, or labels ready-made Construction Products as in a) and/or b) and places them on the market under their own name or trademark, or
    2. ",sans-serif">Changes the intended use of a Construction Product as in a), b), or c) in such a way that different essential or other legal requirements will become applicable, or
    3. ",sans-serif">Substantially modifies or re-builds a Construction Product (thus creating a new Construction Product), with a view to placing it on the market or putting it into service."

    ",sans-serif">Accessing Product Information

    ",sans-serif">"In order for [potential] users of Construction Products..."

    ",sans-serif">Information Creation Clauses 1-3

    ",sans-serif">Clause One
    ",sans-serif">Minimum Requirements
    • ",sans-serif">Named individual responsible for Product Information - PI Team Leader
    • ",sans-serif">Sign-off by technically competent person - Chief Engineer
    • ",sans-serif">Process for updating all appropriate channels - PI Data Administrator/Coordinator
    • ",sans-serif">Audit trail - [Several construction software packages incorporate this function]
    ",sans-serif">Clause Two
    ",sans-serif">Minimum Requirements
    • ",sans-serif">Be clear about how
      • ",sans-serif">potential users can check that Product Information is for the latest version, or
      • ",sans-serif">Facility Maintenance (FM) staff or interested others can obtain Product Information for the installed/approved version
    ",sans-serif">Considerations
    • ",sans-serif">"Using unique identifier to also highlight type of Product Information"
    ",sans-serif">[The intent of this statement requires clarification]
    • ",sans-serif">"Ability to confirm this Product Information is up to date"
    ",sans-serif">[See comment on Minimum Requirements: The QR code on any product should be version-specific and link to the clearly dated information for that version]
    ",sans-serif">Clause Three
    ",sans-serif">Minimum Requirements
    • ",sans-serif">Only use industry terminology and abbreviations where a competent [potential] user would be expected to understand them, or define locally at the first occurrence.

    ",sans-serif">Reproduction of Product Information by third parties
    ",sans-serif">"However, where Product Information is to be generated and/or modified by a third party who is part of the Manufacturer's downstream supply chain, e.g. a Merchant or Distributor, the responsible department of that third party and its output must be integrated into the Manufacturer's PI version control process. Only on this basis and irrespective of whether any fees are being paid, may the Manufacturer's CCPI credentials be used downstream by the third party to confirm that the Product Information detailed on the Manufacturer's behalf is in accordance with the Code for Construction Product Information.

    ",sans-serif">"Finally, consideration has been given to the information produced by Trade Associations (TA) and Industry Bodies (IB)..."
    ",sans-serif">Product Information should ALWAYS contain* references to applicable Government, TA & IB regulations and advisory notices.
    ",sans-serif">*     Albeit in "fine print"

    ",sans-serif">Core Information Clauses 4-7

    ",sans-serif">Clause Four
    ",sans-serif">Now, post-Brexit, rather than adding a "fine print" annotation to text in just the Classification subsection, the whole content of this clause must be reviewed and revised, to clarify the different procedures and certifications required for Construction Products which are to be sold within UK and those which the Manufacturer intends to [continue to] sell to the EU and its associated territories.

    ",sans-serif">Clause Five
    ",sans-serif">The bulleted list should be under a heading Performance Data
    ",sans-serif">The second bullet point should read:
    • ",sans-serif">"Each test outside of Certification, Classification or Industry Standard tests shall have been performed by, and each [specified] technical assessment shall have been made by an accredited independent testing authority. Details of the testing protocols and/or assessment criteria shall be made available on request."
    ",sans-serif">The third bullet point should read:
    • ",sans-serif">"Stated performance data must be clear as to whether it is based on testing of the completed product or inferred from the results of laboratory testing on certain of its components."

    ",sans-serif">Clause Six
    ",sans-serif">Minimum requirements
    ",sans-serif">See comments above on Construction Product. The Product Information should be presented as:
    • ",sans-serif">A header section containing information common to both substances and products
      • ",sans-serif">Manufacturer and Product Name
      • ",sans-serif">Product Type
      • ",sans-serif">Code/Model/Reference
    • ",sans-serif">A detail section containing information relevant to the product category:
      • ",sans-serif">Manufactured Product
        • ",sans-serif">Description
        • ",sans-serif">Application/Use
        • ",sans-serif">Material (including finish and colour...)
        • ",sans-serif">Weight
        • ",sans-serif">Size/dimensions (product & installation spatial, services and FM access requirements)
      • ",sans-serif">Substance
        • ",sans-serif">Description
        • ",sans-serif">Packaging
        • ",sans-serif">Pack size(s)
        • ",sans-serif">Unit of measure
        • ",sans-serif">Chemical properties/COSSH statement
        • ",sans-serif">Shelf life/pot life

    ",sans-serif">Clause Seven
    ",sans-serif">Considerations
    ",sans-serif">A reference to ISO 9000 would appear to be appropriate here.
    ",sans-serif">Footnote
    ",sans-serif">Para 1 - "Where Certification...": Delete this paragraph, as it is confusing.
    ",sans-serif">Para 2 - "Certificate and certification...": Delete this paragraph because it is unnecessary, so confusing
    ",sans-serif">Para 3 - "Classification...": Delete this paragraph, as it is not clear and adds to the confusion. Instead, use "category" to group similar items together
    ",sans-serif">Para 4 - "Test reports should not be summarized other than where allowed by the related standard. Full reports, presented as specified or recommended in the standard, must be accessible via a web page hyperlink or URL in hard copy."
    ",sans-serif">Para 5 - "When organizing...":     [ETIM should be defined here]
    ",sans-serif"> Development of common digital and print formats for Product Information must be the top priority.

    ",sans-serif">Associated Information Clauses 8-9
    ",sans-serif">Clause Eight
    ",sans-serif">[No comment]
    ",sans-serif">Clause Nine
    ",sans-serif">"A legally binding promise (called a guarantee or warranty) which is the Manufacturer* of a Construction Product's offer of a specific remedy or range of remedies to the Purchaser* of that product, if it does not meet its specification and/or is defective. It aims to provide assurance that the product is able to perform to the requirements of its intended use subject to correct installation and operation."
    ",sans-serif">*     In the case of a project, building or part thereof, at the time of Handover (Preliminary or Final, according to the terms of the Construction Contract) the Manufacturer will normally be the [General] Contractor and the Purchaser will be the Client (or Owner, if a building was erected "on spec" and intended for immediate sale).
    ",sans-serif">        In the case of a project or building component (cement, equipment...), through Construction and the Contractor's Warranty Period** the Manufacturer will be the manufacturer of the component and the Purchaser will be the [General] Contractor or the respective Sub-Contractor.
    ",sans-serif"> **  Usually 1 year from the Preliminary Handover Inspection on completion of Construction, which will produce a "punch list" of defects requiring rectification. The [General] Contractor (who may also be required to operate the building systems - aka "shakedown") is liable to rectify faults on the punch list and any which may arise during this period.
    ",sans-serif">All guarantees/warranties will normally commence at the time of [Preliminary] Handover, but their length will vary according to the nature of the subject item:
    • ",sans-serif">Warranties for manufactured components are usually one year
    • ",sans-serif">Those for major equipment items such as elevators, escalators and NVAC plant are normally longer, and often subject to maintenance being performed by the item manufacturer's service personnel
    • ",sans-serif">Those for complete buildings or projects may range from, say, 5 years to decades
    ",sans-serif">It is also worth noting that guarantees/warranties given under the terms of the UK Sale of Goods Acts make the seller, not the original manufacturer, of the concerned good responsible in the first instance, unless specifically noted otherwise at the time of purchase.

    ",sans-serif">Footnote
    ",sans-serif">Durability Statement: "The period throughout which the Construction Product will deliver its intended performance in line with appropriate product standards, assuming that any periodic maintenance required according to the manufacturer's recommendations has been carried out."
    ",sans-serif">Expected Service Life: "The potential lifespan of the Construction Product until becomes Beyond Economic Repair (BER) "

    ",sans-serif">Support and Competence Clauses 10-11
    ",sans-serif">Clause Ten
    ",sans-serif">[No comment]
    ",sans-serif">Clause Eleven
    ",sans-serif">[No comment]
    ",sans-serif">In today's online world, a "robust training programme" will be expected to rely heavily on audio-visual materials (aka video clips), which will also form the core of promotional material for sales.

    ",sans-serif">Glossary
    ",sans-serif">ETIM, LEXiCON
    ",sans-serif">Development of common digital and print formats for Product Information must be the top priority.
    ",sans-serif">Technical Assessment
    ",sans-serif">This definition needs to be revised and expanded with plain language explanation.
    ",sans-serif">**Insurance Backed Guarantees/Warranties (IBG)
    ",sans-serif">For consistency of footnote formatting, "Insured*" should be "Insured***"

    ",sans-serif">How the Code will work
    ",sans-serif">Renewal and ongoing assessment
    ",sans-serif">"The licence is renewable annually, with reassessment also annual for the first three years and every [3] years thereafter."
    ",sans-serif">Fees
    ",sans-serif">"Fees will be according to the size of the organization"
    ",sans-serif">Complaints
    ",sans-serif">"In the case of persistent and unresolved matters, it is likely that the CCPI licence will be suspended and a notice placed on the website to this effect..."