Supply chain competence needs evidence, not paper
By SubTrada ·
Most main contractors can show a folder of certificates for every specialist on site. Far fewer can show that the people who installed the work were competent to do it, that what went in matched what was approved, and that the record will still stand up when someone asks in ten years. That gap is where supply chain competence actually gets tested, and the latest industry survey says most of us have not closed it.
What BESA found
The Building Engineering Services Association published its third annual survey on the industry's response to the Building Safety Act on 19 October. BESA contacted more than 6,000 firms and over 250 companies took part.
The headline is positive. 64% of respondents said they could demonstrate their dutyholder requirements "very well". Underneath that, the numbers get less comfortable:
One in three said one of their biggest challenges was demonstrating competence in practice, as opposed to holding a qualification.
40% said competence issues were identified frequently or occasionally.
Around one in three reported challenges in demonstrating assurance across the supply chain they appoint.
Only 30% felt confident they could evidence competence and compliance on projects more than ten years old. Some respondents called historic compliance a "ticking time bomb".
74% had seen no significant change in client behaviour since the Act came in, and Construction Management reports that 26% said clients were more willing to compromise on safety compliance when under pressure.
21% of micro and small firms had made no significant changes, against 5% of medium and large organisations.
For a main contractor the message is plain. The weak point is the evidence trail for the packages you let, and the smallest firms in your chain are the least likely to produce it unprompted.
Why the evidence matters when a job changes hands
Four days earlier, Northumbria Healthcare NHS Foundation Trust confirmed the scale of remedial work at the part-built £35m Berwick Community Hospital. The original contractor, Merit, went into administration and Robertson Construction was appointed as replacement contractor in January. After inspection, the trust says M&E systems, pipework, internal walls and fittings are being removed from 19 October, and the façade and the steel frame system supporting the cladding will be removed and replaced from late November. The main structural steelwork stays. The trust now expects the majority of work to be complete by summer 2028, and Construction News reports it has started legal action against Merit's administrators over alleged defects.
I won't speculate on what went wrong at Berwick. The lesson is narrower. When a project changes hands, or a client's adviser starts asking questions, the only things that count are the records. If nobody can show which drawing revision was installed, who signed off the product, and what the installer's competence looked like on the day, the safe answer is to open it up. That cost lands on the client first.
Competence is a package question, not a company one
Most PQQs still test the company: turnover, accreditations, insurances, policies. That gets a firm on a list. It says very little about whether the gang turning up next month can install the fire-stopping system you specified.
Competence under the Building Safety Act is about the people doing the work and the work they produce. So the evidence has to sit at package level:
the named supervisor and operatives, with the cards and product training relevant to the system being installed
the approved product data, samples and method statements for that package
the drawing revision they priced and the revision they installed from
inspection and test records, with photos tied to locations
every instruction that changed the scope, numbered and priced
None of this is new. The Act simply puts real weight on producing it.
A checklist for each package
Run this before you let the order, not after the first problem:
Pre-qualification. Tier the PQQ to the risk. A specialist working on a higher-risk building or on fire safety critical elements should face a deeper check than a fencing contractor. Record which tier they passed and when.
Insurance and accreditation dates. Track expiry dates live, not as a PDF from the tender stage. An expired PI or third-party accreditation halfway through a job is a competence gap on paper and a commercial gap in practice.
Named people. Ask for the named supervisor and key operatives at tender, and make substitutions subject to approval.
Tender from controlled drawings. Issue the tender from the current register, so the return is priced against a known revision. Log every RFI answer against the package.
Technical submittals before installation. No product goes in until the submittal or sample is approved, and the approval is linked to the location it applies to.
Photographic evidence at hold points. Photos taken on site and filed against the element, not stored on someone's phone.
Numbered instructions. Any change to specification or scope goes through an approved instruction with a number, so the as-built record reconciles to the contract.
Close-out pack. At practical completion a stranger should be able to follow the package file, whether that is a replacement contractor or a lawyer in 2036.
Worked example: a fire-stopping package
Take a mid-rise residential job with a fire-stopping package let to a specialist. This is an illustration, not a real project.
At pre-qualification the specialist passes the top PQQ tier, with third-party certification for the systems they install. Their insurance and certification expiry dates sit on the directory record and flag before they lapse. At tender they price from revision C of the compartmentation drawings, issued from the drawing register. Two RFIs about service penetrations through a particular wall type are answered in writing and attached to the package.
Before work starts, the product data and installation details for each penetration type go through technical submittal and are approved by the design team. On site, each completed penetration is photographed, tagged to its location and inspected at the hold point. When the M&E designer moves a riser and revision D is issued, the build team see the new revision on site, the specialist gets an instruction with a number, and the change is priced and certified through the valuation.
If that specialist goes bust in month nine, the replacement inherits a file that shows what was installed, where, to which revision and by whom. That is the difference between surveying the work and stripping it out.
Developers and clients need to be on the same page
BESA's 74% figure on client behaviour should bother developers as much as contractors. Clients carry their own dutyholder obligations, and a client who pushes the programme hard while having no sight of the evidence trail is taking a risk they may not see until handover or sale.
The fix is visibility, not more meetings. A client should be able to see design progress against the information release schedule, package status, outstanding submittals and issued instructions without waiting for the monthly report. When the client can see the evidence building up, the conversation about a compliance shortcut under pressure gets much shorter.
This is where a shared platform earns its keep. In SubTrada, the PQQ tier, live insurance expiry, controlled tender issue, QR-linked technical submittals, numbered instructions and the IRS tracker sit on one record per package, and the client profile can see progress without asking for it.
FAQ
What counts as evidence of supply chain competence under the Building Safety Act?
Evidence that the people doing the work had the skills, knowledge, experience and behaviours for that task, and that the work matches the approved design. In practice that means named operatives with relevant training, approved submittals, installation records with photos, and a drawing and instruction trail that reconciles to the as-built.
Is a PQQ enough to show competence?
No. A PQQ shows a company is suitable to bid. Competence has to be shown at package and task level, during the works, through the records you keep as the job is built.
How long should main contractors keep package evidence?
At least as long as your liability runs, which on higher-risk buildings is a long time. Store it in a structured system, not project email.
What should developers ask their main contractor for?
Ask for live visibility of package status, submittal approvals and numbered instructions, rather than a summary at handover. If the evidence only appears at the end, it was probably assembled at the end.
My view is simple. Pick the next three packages you are about to let, run the checklist above against them, and see which items you could not evidence today. Fix those before the order goes out, because once the work is covered up the only thing left to rely on is the file.