Engineers Ireland Letter to the Department of Environment, Community and Local Government

Engineers Ireland Letter to the Department of Environment, Community and Local Government

01 September 2015 at 16:08

Engineers Ireland Letter re the Decision to Amend S.I. No. 9 2014 - Building Control (Amendment) Regulations 2014 


Radio Interview: Listen to Cormac Bradley, chartered engineer discuss the issue on Newstalk on August 31st, 2015.

Cormac Bradley, a chartered engineer with RPS, represented Engineers Ireland on the working group which was formed to develop the S.I. No. 9 2014 - Building Control (Amendment) Regulations 2014, the associated Code of Practice and the complementary Ancillary Certificates with the Department of Environment, Community and Local Government.

Letter from Engineers Ireland

Date: 28th August 2015

Re: Decision to Amend S.I. No. 9 2014 - Building Control (Amendment) Regulations 2014

Dear Minister,

I write on behalf of Engineers Ireland in regards to your recent decision to amend the Building Control (Amendment) Regulations 2014 (S.I. No. 9 of 2014).

Engineers Ireland remains strongly supportive and committed to the Departments’ goals of protecting consumers through the raising of standards, competence and professionalism in the construction sector. The statutory inspection regime required by S.I. No. 9 ensured the competence of all personnel involved in design, inspection and construction of building work. It is the view of Engineers Ireland that the amendment as outlined may seriously compromise the very significant advances made to date and do not appear to align with the Departments’ goals to protect the consumer.

It is also the view of Engineers Ireland that the newly proposed regulations will lead to the creation of a two - tier housing market, which will not support consistent implementation of standards throughout the industry. Investment in design, inspection and certification during construction leads to better quality and compliance with building standards.

Therefore the overall fee associated with statutory certification should be looked upon in the context of the overall life cycle costs of a building and not just the “one off” costs of construction. There is no empirical data supporting the assertion that consumers are being quoted excessive fees.

In relation to the proposed sample preliminary inspection plan (PIP) it is important to highlight that every construction project presents its own unique set of risks; and therefore any inspection plan must assess risk on a case by case basis. The PIP should not be a check list, but rather a risk assessment based on professional judgement.

Statutory certification places a significant level of professional responsibility and indemnity on the appointed professional; therefore the role should only be performed by those who have undergone a rigorous screening process of their academic and professional development. Whatever structure, a proposed educational course takes; it must be subject to a QQI assessment (or equivalent) and be equal to the academic and professional standard of a Chartered Engineer, Chartered Surveyor or Registered Architect.

We would support the broadening of the pool of professionals allowed to take on the role of Assigned Certifier and Design Certifier, provided other industry professionals are capable of demonstrating their competence equivalency with the academic and professional standards of a Chartered Engineer through a rigorous and accredited assessment

Engineers Ireland is not opposed to the development of a new Register for Architectural Technicians/Technologists. However, if such a register is put in place, Engineers Ireland expects that a parallel statutory register be set up for Engineers, and restricted functions be defined in legislation for Engineers holding the professional titles of Associate Engineer and Engineering Technician.

In light of the above, and while we remain strongly opposed to this decision, we urgently request a meeting to discuss a Ministerial commitment to a full review of this decision in September 2016 at the latest.

Yours sincerely,



Caroline Spillane
Director General
Engineers Ireland
22 Clyde Road
Dublin 4

Minister Alan Kelly, TD
Minister Paudie Coffey, TD