On 22^nd July, the British Standards Institute (BSI) released a public consultation on ‘BS 40104 Retrofit assessment for domestic dwellings – Code of practice’, otherwise known as the Retrofit Assessor Standard. This consultation has now closed for public comment and Elmhurst has submitted a response.

Elmhurst Response Summary

Section 4: Assessment Process:

4.2 Stage 2: On-site assessment – Clarification is needed regarding the necessity of calibrated equipment where applicable, as this could lead to additional costs for Retrofit Assessors.

Section 5: Context Assessment:

5.1.1: Process, overview – A pragmatic solution would be that the desktop ‘context’ assessment does not need to be carried out by the Retrofit Assessor. Further clarification is also needed on the expected level/amount of information required.

5.1.4: Ground conditions and topography – it is unrealistic to expect the Retrofit Assessor to identify some of the issues listed, such as subsidence, ground heave and water infiltration of the site.

Section 6: On-Site Assessment

6.1.1: Condition Rating – too much emphasis is placed on the Retrofit Assessor to decide whether a defect must be repaired. This responsibility should sit with the Retrofit Coordinator.

6.2.1: Ventilation assessment (Process) – Elmhurst notes thar airflow rates must be recorded. Should a Vane Anemometer be required, we recommend that it be used in line with proper measuring practices and that the user be adequately trained and ideally certified through a competency scheme.

6.3: Occupancy assessment – There is currently no provision for a basic occupancy assessment. With no standardised calculation method, the industry risks variation and disparity between software provider outputs if the data is used to alter the energy rating of the property.

6.3.2 – Occupancy assessment (Output) – In the context of PAS 2035, data collection relating to occupant comfort, satisfaction, wellbeing and usability are determined by the Retrofit Coordinator. Only one party should gather this information.

6.4.1.2: Energy performance assessment (Suitable methodologies) – Further guidance is needed to ensure that default values are only amended when industry-approved evidence is available. Clarity is also needed on whether a qualified or competent person is required.

Section 7: Reporting and lodgement

There is concern over the requirement for ‘section drawings’ as, at present, the retrofit assessment is a non-invasive survey. In the majority of instances, this would prevent any such section drawings from being provided.

Annex A: Condition (Informative)

It should be made clear that the list provided here is not exhaustive. There may be additional information that is not referenced.

Elmhurst Thoughts:

As a standalone document, BS 40104 is a good standard and offers clear guidance on how to complete a thorough Retrofit Assessment for a property in readiness for whole house retrofit.

Elmhurst accepts that existing assessors would need a significant amount of additional competency training and skill development to cover many of the enhanced requirements in this standard. This is generally well received, as assessments should be completed by competent persons. However, there is concern that some areas noted in the standard would be very difficult to train across the entire retrofit work forces. This may result in the dilution of resource and create consumer confusion.

When considering the standard in relation to PAS 2035, Elmhurst has serious concerns about its adoption and the potential impact on large-scale projects and widespread implementation. The standard could significantly hinder the progress of PAS 2035 and lead to substantial cost increases in delivering retrofit projects, potentially harming the industry. If the intention is to replace the Retrofit Assessor/Assessment element of PAS 2035 with the Retrofit Assessor Standard, then the impact of this must be carefully considered.

The consultation has now closed for public comment and we now await a response. Elmhurst will continue to keep members informed of any updates relating to the Retrofit Assessor Standard.

Further Resources:

To view the Retrofit Assessor Standard consultation page, please click the following link: https://standardsdevelopment.bsigroup.com/projects/2022-00570#/section

To view our initial breakdown of the Retrofit Assessor Standard Consultation, please click the following link: https://www.elmhurstenergy.co.uk/blog/2024/07/29/the-retrofit-assessor-standard-a-step-in-the-right-direction-but-does-it-go-too-far/