Building control: private versus public responsibilities

dr. F.M. Meijer and dr.ir. H. Visscher1

ABSTRACT

In the Western world building regulations should guarantee that newly built buildings are safe and
healthy for the users and visitors. In most countries additional demands are made concerning comfort,
accessibility, energy efficiency and sustainability. The building regulations consists in general of
technical requirements on the one hand and a set of procedural regulations on the other hand. The
latter determines the building permit procedures and the extent and intensity of building control. In
Europe traditionally governmental bodies play a central role in formulating and enforcing the
regulations. The past decennia however we have seen some changes in this respect. In a growing
number of European countries private parties within the building sector (e.g. contractors, architects and
engineers) have been taken over some of the traditional activities of the local building control
authorities. The reasons for this development differ. For instance in the Netherlands alternatives for
local authority building control are sought because doubts have arisen about the effectiveness and
efficiency of the control. In some other countries however the changes are motivated by more positive
reasons. This paper focuses on the public versus private responsibilities for inspection and control of
the building regulations. The paper is based on the results of a research project in which the system of
building control of eight European countries (Belgium, Denmark, England, France, Germany, the
Netherlands, Norway and Sweden) were compared. The material has been updated and extended with
an investigation of the Australian building control system. Central question is what are the
preconditions and ingredients for an effective and efficient building control system?

1. INTRODUCTION

There is a growing number of international oriented research in the field of technical building
regulations and building control procedures. Studies of Mathurin (1988) and the Institute of Building
Control (1997), provide basic insight in the different systems in the European countries. Sheridan
(2001) analyzes technical building regulations in some European countries with a broad range of
regulations and incentives that promote housing quality. Bowen (1997) provides basic definitions to
understand systems of technical requirements, with a focus on performance-based building codes (like
the Dutch Building Decree). The Taskgroup Performance Based Regulatory Systems of the CIB
(international Council for Research and Innovation in Building and Construction) is developing a
performance systems model for the technical requirements systems (Beller et al. 2001, Meacham
2001, Bergeron et al. 2001, Bukowksi et al. 2001, Meacham et al. 2002).

Within this field the OTB Research Institute for Housing, Urban and Mobility Studies has focused in
a range of national and international projects on the different systems of technical building control.
Some of these studies supported the Dutch government in the search of alternative instruments (e.g.
the development of an Assessment Guideline with requirements for the certification of private
companies for inspecting construction work). Other research projects analyse the organization of
building control in various European countries (Meijer and Visscher 1998).Recently we have finished
an international project into building regulations in eight European countries: the Netherlands, England,
France, Germany, Sweden, Norway, Belgium and Denmark. The research project is published in two
volumes. The first volume compares the systems of building control (Meijer et al. 2002). Part two
addresses the technical requirements in the eight countries (Sheridan et al. 2003). Slowly but surely
these international oriented comparative studies lead to a framework, in which the building regulatory
systems can be analyzed in a coherent way. Important aspects here are:

1
F. Meijer & H. Visscher are senior researchers at the OTB Research Institute for Housing, Urban and
Mobility Studies, Delft University of Technology, The Netherlands.

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 • Establishment of regulations (e.g. influence of building industry).
• Scope and interdependence with other regulations (e.g. planning and zoning aspects).
• Administrative/building permit procedures.
• Inspection and enforcement of the regulations.
• Formulation of technical requirements (e.g. descriptive/functional/performance based,
approved and alternative solutions).
• Qualification/accreditation/registration of building practitioners (designers, builders, inspectors).

This paper focuses mainly on a part of the regulatory system, namely the inspection and
enforcement aspects of the building regulatory systems. Traditionally the role of public authorities is
large but in a growing number of countries, private parties within the building industry are playing a
more important role. The focus on this subject is inspired by the fact that public versus private
inspection is a topical subject in the Netherlands. The paper is largely based on the European
comparison mentioned before and is supplemented with the system in Australia. We start with an
overview of building regulations in Europe. Section 2 sketches the outlines and the characteristics of
the permit procedures. In section 3 the building control systems are described. Subsequently section 4
discusses the choice for public and private systems. In section 5 conclusions are drawn.

2. BUILDING REGULATIONS IN EUROPE

In Europe every country has developed building and planning regulations to assure basic qualities
of buildings. Regarding the scope and contents of the regulations parallel developments can be
recognized. Safety and health are traditional subjects of public regulations. In later years requirements
were added concerning the use of building materials, water and energy in buildings. We can also see
parallel developments in the way the building regulations are set and pursued. Permit procedures and
the role of parties and firms involved are changing. In the western world this development is reinforced
by the strong tendency towards deregulation and minimizing the influence and role of the state. All in
all this has lead to a growing importance of private building control.

2.1 Scope of the regulations

In most countries the regulations concerning building permit procedures, technical requirements
and planning aspects are determined at a national level. Belgium and Germany are the exceptions to
this rule. In Belgium the three independent regions (Brussels, Walloon and Flandres) are responsible
for the regulations. This leads to some variety. On the other hand, the national Civil Code (which
directly influences the responsibilities in the building sector) leads to more congruity. In Germany the
various states play a decisive role in establishing their own Building Codes. They are based however
on the same nationally accepted Model Building Code, so in practice the regulations tend towards
harmonization.

England & Wales make a distinction between the building permit and the planning permission
(Office of the Deputy Prime Minister various years). Another local authority department than building
control takes care of the planning permission. One has to have planning permission in order to apply
for a building permit. The advantage of this model is that the length of procedure time for a specific
building permit can be minimized. Long time-consuming exemption procedures of planning
requirements can be avoided. In the Netherlands a phased permit procedure has been introduced in
early 2003. In the first phase the location aspects will be emphasized.

The formulation of the requirements is changing. Within the European Union changes and
convergence is established through the EC-Directive on Building Products and the gradual acceptation
of Euro Codes in the member states. In general the technical demands are more and more phrased in
performance requirements. In most countries the Acts and Codes that regulate the building permit
procedures also contain references to the technical requirements. Most European countries have a

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national set of rules that regulates the subjects mentioned in the EC Directive (mechanical resistance
and stability, safety in case of fire, hygiene, health and the environment, safety in use, protection
against noise, energy economy and heat retention and access and facilities for disabled people).
Belgium is the exception on this rule and in some cases there are not even regional regulations on a
subject (for instance on hygiene, health and the environment).

2.2 Construction categories

A building permit is needed to start construction work in all studied countries. The countries have
however developed various procedures for different construction works and activities. All countries
have defined a category of construction works that the building regulations do not apply to. In general
this involves constructions with specific functions, like army barracks or other government buildings. In
general the exemptions are small alterations and renovation works or extensions, annexes, garden
sheds, etc. or construction works for forestry, agriculture and horticulture. Temporary constructions are
also often exempt. In general, the permit free construction works are described in broad outlines. In
comparison with other countries the Belgian and German lists of exemptions are, because of their
detailed description, very sizeable. Sweden and France beat the lot on the other side of the spectrum:
their exemptions are defined in quite general terms.

Besides exemptions most countries recognize a category of construction works that must be
announced to the local building control. The applicant has to give notice of the intended construction
work, but there is no or no complete preventive control to check the construction. In almost all cases
the building notice applies to minor construction works where location-dependent demands do not play
a role. England, France, Denmark, Norway and Sweden have introduced the building notice procedure
for these construction works. In England the applicant may choose if he/she wants to apply for a
building notice or a full plan/permit procedure. Belgium and the Netherlands have made a distinction
between simple (or light) and regular permit procedures. Germany also does not have a building notice
procedure, but the German regulations distinguish a category of construction works that are eligible for
self-control and a more simple permit procedure.

2.3 Pre-consultation and submission demands

Norway and Sweden are the only countries in which the consultation phase is specified in the
building regulations. It is a fixed and obligatory part of the permit procedure. All parties that carry
certain responsibilities in the planned construction project (applicant, architect, contractor, etc) must be
present (or represented) at the consultation meeting. In the meeting, the local authorities have the task
to clarify the specific regulations that are in force for the location of the planned construction work. A
further purpose of the meeting is to establish the control method during the design and execution
phase of the project.

All countries studied have a set of conditions regarding the submission of a building permit. Some
countries (e.g. the Netherlands) have determined these conditions at a national level (in the Housing
Act). In other countries the national law gives a framework and the conditions can be elaborated at a
local level. The nature of the documents that have to be submitted depends on the way the control
procedure is organized. The regulations in France, Belgium and Germany state that applications for a
permit (for certain building works) must be prepared and submitted by a recognized architect. By
making such demands the chances grow that the application for a permit is adequately prepared. A
preventive check during the procedure still has to be carried out, but a well-prepared application can
lighten the task of the controller considerably.

3. CHECKS AND INSPECTION: PRIVATE VERSUS PUBLIC RESPONSIBILITY

The accent lies on the technical control of the building plans and the site inspections. The aesthetic
and planning control are left out of consideration. A distinction can be made between the responsibility
for granting the permit and execution of the plan checks and site inspections. In all European countries
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studied local or regional authorities are in charge of the building permit procedure, i.e. they formally
grant the permits. Only in England and Wales does an alternative exist in which private organizations
may grant a building permit which only covers the technical aspects (and not the planning aspects). In
Australia the situation is somewhat different. In Australia private building certifiers may issue building
permits and occupancy permits. Individuals who are employed by local government agencies may also
carry out designed certification and inspectorial functions. In both cases stringent demands are made
on qualifications and experience (ABCB 2003). In this respect the situation is quite distinct form those
in many European countries.

The main issue in this section is the responsibility for plan checks and site inspections. Both private
and public organizations can be responsible for the check of the design application and the site
inspection of building activities. When private parties are responsible for these tasks local authority
building control in most cases stays in charge to supervise the control of these private organizations.

3.1 The Netherlands and Denmark

Denmark and the Netherlands are the only countries in which local authority building control is the
only existing form of building control. In the Netherlands there are developments towards a more
important role of private organizations by the check on the technical requirements. This search for an
alternative is driven by the fact that the traditional approach in which all municipalities (big and small)
operate their own department of building control, does not function well because of the lack of non-
uniform control procedures and limited capacities A draft assessment guideline (AGL) indicating the
requirements for processing a certificate for testing building permit applications in compliance with the
requirements of the Building Decree has been completed in the summer of 2002. The system is not yet
implemented in practice. The idea is that companies can be certified for the checks on the integral
Building Decree, but certification for one ore more parts of the Building Decree is also possible. The
following scopes have been specified: General subjects, (no specific calculations required) and co-
ordination; (A), Structural safety (B); Fire safety.(C); Building physics (D), Installations.(E) and
Environment (F). The quality of the certified test procedure is assured by a series of requirements.
There are some general requirements to the certificate holder (a company) that controls its
independence and there are requirements on the qualifications of the responsible controllers. These
are specified for every scope and make demands on general (technical) education and additional
specific courses. All specialists have to follow professional developments and courses if these are
required by the change in regulations and building techniques. The AGL further contains requirements
for the quality system of the certified organizations. They have to work out their system in a quality
book. Most important are the checking procedures, which must be described in detail. The AGL
contains requirements for a series of about twenty specific checking procedures. There is a general
checking procedure for subjects which can be checked on drawing (presence of functions and
dimensions). Other procedures relate to specific calculations (structure, building physics). Another
important feature of the AGL is a format for a detailed test report for every individual building plan in
which all the requirements of the Building Decree are listed. An experimental project with the certified
Building Decree Test, which will presumably start early next year, will have to prove if this concept
works in the building practice.

3.2 Germany

In Germany local building control contracts out many checking and inspection activities to
specialized and recognized engineering firms. In general this is the structural check and the site
inspection. These engineering firms are responsible for their control. The engineers involved are
specialized, recognized, have to comply with heavy demands to qualify and are liable for the quality
they deliver. The check engineer (Prüfingenieure) is an independent, freelance, fully qualified,
consulting engineer having knowledge of statics and structural problems. Other requirements include -
design experience of more than 10 years, knowledge of materials, economical and ecological
problems, building management and building legislation, more than one year’s experience as a site
engineer and be within the age range of 35 - 60 years. When mistakes occur in building parts or

4
functions of the building that are inspected which should have been detected, the engineers are legally
liable for damages. Germany has also introduced the concept of self-control for small buildings:
residential buildings with a maximum height of one storey and a maximum floor area of 200m2.

3.3 Belgium and France

In Belgium and France private companies play an important role in the provision of adequate
quality safeguards as the foundation for insurances because of strong liability regulations. Whether,
and to what extent, checking takes place depends mainly on financial considerations. In France the
applicant for certain construction types (e.g. constructions with a high ‘fire-risk’ like big buildings) is
legally obliged to hire a private engineering or control firm. This system is basically the same as
described by Germany. The main difference is that the national law and not the local authority decide
in what cases this control firm has to be brought in. The technical inspector is subject to the same
presumption of liability as the architect and contractor, must be completely independent of any design,
construction or advisory activity relating to the structure and approved by the Council of State. The role
and function of the technical inspection body are now defined under the Spinetta Law. For 50 years the
profession of technical inspection, especially the issuing of decennial insurance policies, developed
without legal obligation. The Spinetta Law, together with supplementary regulations, gave the profession
official status and defined its new legal framework. In particular the following has been specified:
• The role of the technical inspection body: intervening on behalf of the owner, with a view to
contributing to the prevention of technical hazards, i.e. the risks of errors made by all professionals
involved in a project.
• The main subjects of control that should be covered: structural stability and peoples’ general
safety being the main concerns.
• The conditions of practice of the technical inspection profession.

In France and Belgium extensive checks and site-inspections by private organizations

commissioned by the contractor are in some cases necessary because of the strict liability system and
the sometimes obligatory insurance system. Because of the important role of private organizations,
local building control authorities in France hardly execute any preventive inspections anymore. This
means that there is a category of construction works (where there is no control by private
organizations) that are not controlled at all.

3.4 England & Wales

Before 1997 building control was carried out either by local authorities, or since 1985, by NHBC
Building Control Services Ltd., the first organisation to be appointed as an Approved Inspector. Since
January 1997, more Approved Inspectors, both corporate and individual, have been appointed, but
only NHBC Building Control Services Ltd. has the necessary insurance to undertake building control of
new-build houses and flats. A mutually agreed set of Performance Standards for both public and
private sector Building Control Bodies (BCBs) was published in 1999. There are four stages to
qualification as an Approved Inspector:
• Application: an application form and a detailed ‘knowledge base’ must be completed. The
knowledge base, which is similar to an open exam, addresses six key areas of knowledge:
Building Regulations and statutory control; Law; Construction technology and materials; Fire
studies; Foundation and structural engineering; Building service and environmental
engineering. It uses the formulation “Please demonstrate, using particular examples from your
experience, how you feel you are equipped with a comprehensive knowledge of / an
understanding of / an appreciation of…” depending on the topic. Applicants must also submit
an operational business plan.
• Pre-qualification verification: the registrar checks the knowledge base responses for gaps in
experience or qualification that may disqualify the applicant or cause delays at later stages.

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 • Admissions panel: the papers are assessed by experts nominated by members of the
Construction Industry Council and qualified Approved Inspectors. They decide whether the
candidate merits a professional interview.
• Professional interview: three assessors assisted by the Construction Industry Council
Approved Inspectors Register Iinterview the candidate.

Successful completion of the four stages results in an invitation to register as an Approved

Inspector. Approval is valid for five years. New Approved Inspectors are issued with the CICAIR Code
of Conduct and Disciplinary Procedures. The Approved Inspector checks if the design and execution
meets the technical demands and is authorized to submit a building permit. The applicant may choose
between local authority building control or an Approved Inspector. An Approved Inspector does not
have the same competences as a local building control authority. When conflicts arise about whether
the regulations are being met (especially during the construction phase), the Approved Inspector has to
call in whether local building control authority to take action. The system of building control may
change again in the next few years. In addition to self-certification schemes for the installation of
specified equipment and for replacement windows, which were introduced in 2002, the government is
considering the development of self-certification of buildings by enterprises or individuals deemed to be
‘competent’ by accrediting bodies.

3.5 Norway and Sweden

In Norway and Sweden the applicant is always responsible for the execution of the plan checks
and site inspections. Local building control authority checks the control plan in which the applicant
indicates how all the necessary inspections – during design and on-site – are provided for to ensure
that the construction meets the demands of the building regulations. The local authority decides when
they are satisfied with a self-control system carried out by the firms involved (designers, construction
specialists and contractors) and when they insist on an independent inspection by a specialized
inspection body. The qualification system for architects, building companies knows various classes and
levels. The basis for the class levels are complexity of the construction work and risk for damage on
health, environment and safety damage. There can, however, be a mix of classes within one project, if
a fire solution requires special attention, that part of the project can be put in a certain class, while the
rest may be categorized in another class. On the basis of this, the construction work is divided in some
hundred categories. Besides the three ‘complexity/risk’ levels, three roles are distinguished:
responsible for design, responsible on site and responsible for the complete co-ordination. Most
companies apply for approval for the complete set of ‘risk and role levels’.

The qualification and experience demands are limited to the professional staff. The administrative
staff and the workers are not included. There are four levels of education, from technical school to
university degrees. The demands depend on the class. The building regulation contains a table for the
demands for education and length of experience for each function in each class. The demands on
experience depend also on the class, and varies from two to eight years. Co-ordination responsibility
requires longer experience than ordinary performing responsibility in design or construction, and there
is also a demand for ‘relevant’ experience. Contrary to the demands for education and length of
experience, which are related to the professional leadership of the company, the so-called (quality)
system requirements (or demands) are related to the company as such. There are four formal
demands:
Organisation plan (or rather two organisation plans, one showing how the company is organised, and
one showing how the company organises its projects).
• A system for identification of official demands (often just shown in the control plans).
• A system for the handling of documents.
• A system for handling of deviations.

In addition, there is a general demand for knowledge of the building regulations. As a part of the
permit application the building and construction companies have to show qualifications in order to be
given responsibility. The national qualification body provides the proof or certificate for this
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qualification. This certificate has recently been given a duration of three years (formerly two years). If
the company does not have a national certificate, in can nevertheless apply for a local issue, but it
must renew its application in each new case. The demands are initially the same as for the national
certificate, but the municipality also has a possibility to issue responsibility to persons. On the national
level, certificate is only issued to companies. Until now, it is estimated that about 1/3 of all the
Norwegian building and construction companies (= 30 to 35.000) have obtained certificate from the
National qualification body, and it is also estimated that this figure (which still is increasing) will stop at
about 50 %. This is about the double of what was estimated in 1997.

3.6 Australia

In Australia a nationwide uniform system of competency standards for building surveyors has
recently been approved by all States and Territories (ABCB 2003). This Framework seeks national
harmonisation of educational qualifications, experience and work scope for professionals who are
involved in building certification. In essence the framework adopts 2 levels of building certifiers, namely
• Building Certifier, Level 1 (who has an unrestricted work scope) and who must hold a tertiary
level degree and have a minimum of 3 years relevant and practical experience; and
• Building Certifier, Level 2 who is able to certify the design and construction of buildings up to 3
storeys and with a maximum floor area of 2,000 m2. These professionals must hold an
advanced diploma and have at least 2 years relevant and practical experience.

Individuals who are employed by local government authorities may carry out designated
certification and inspectorial functions in respect of structures (including residential buildings) that are
no more than 2 storeys in rise, with a maximum floor area of 500 m2. Such personnel would require to
hold at minimum a diploma in building surveying and have at least one year relevant experience. The
Framework was developed in consultation with industry, State and Territory Governments and other
relevant stakeholders, and was in its final form adopted by the Australian Building Codes Board. The
National Accreditation Framework requires practitioners to have attained competencies in both
education and practical experience. Graduates of an accredited course or program are deemed to
have attained the educational competencies of the Framework without further assessment. Attainment
of the practical competence requires a period of practical experience within industry under the
guidance of experienced professional Building Certifiers practicing at the relevant level. A further
guideline document is developed which details how the experience competencies should be assessed.
The rationale for developing these guidelines is that across the building and construction industry,
changes are occurring at an unprecedented rate. The role of building certification profession has
changed quite significantly over recent years and now embodies work in building regulatory
consultancy, building approval or enforcement (both in private practice and Local Government) and
construction or asset management. The rapid change in the role of building certifiers has been
influenced by industry changes such as the introduction of private certification, adoption of the
performance based Building Code of Australia, and through rationalization of Local Government in
most States and Territories. These factors have increased industry and community expectations for
building certification profession to be multi-skilled in various facets of the construction industry. To this
end, courses for professional building certifiers need to give rise to attributes that will enable this level
of multi-skilling to occur.

An integral part of the framework is the recently nationally endorsed competency standards and
higher education benchmark for building surveyors. The competency standards are the building blocks
used by TAFE–Institutes (Technical and Further Education) to develop courses. These have been
specifically designed to match the core functions of level 2 of the framework. The Benchmarks similarly
align with the functions described at level 1 and universities will structure their undergraduate courses
accordingly. These two sets of standards mean that irrespective of where a student gains their building
surveying qualification, they will graduate with the same skills, knowledge and understanding in the
identified core areas, Moreover much care has been taken to ensure that there is a seamless transition
between the two sets of education standards, People with a TAFE qualification in building surveying
may progress through to the University degree.

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3. DISCUSSION

The general point of departure of our research is the wish to establish a more effective and more
efficient building control system in the Netherlands. In this paper the emphasis particularly lies on the
system of plan checks and site inspections. At this moment local authority building control in the
Netherlands can hardly be made responsible for the quality of the inspections. The execution of the
control activities as to frequency and profundity varies between (and also within) local authorities and is
not always in proportion to what is actually needed. The size and quality of local authority building
control differs widely in the Netherlands. Small municipalities in particular have problems keeping the
knowledge and skills up to date. Applicants have to prove in advance by means of substantial plan
documentation that the regulations are going to be fulfilled. This leads to a relatively heavy
administrative burden for the applicants. The need to improve the quality of the plan checking and site
inspections (skills, competences, behaviour) is clear. The solution lies not only in the introduction of
private inspection to replace local authority building control. Apart from the fact that this will lead to
undesirable and unforeseeable effects, local authority building control still has basic qualities and skills
based on many years of experiences. The aim should be to develop a system in which private and
public building control (eventually) work side by side. A framework has to be established that
guarantees the competences of both public as private inspectors. The introduction of private control
could be used as a catalyst for improvement of building control all along the line. The demands on both
inspectors (private or public) should be identical and both public and private inspector should be
accredited for the same skills, capabilities and experiences. We have found examples of this in various
countries: Germany (for structural parts), Norway, England and Australia. The example of Australia is
tempting: especially because of the transparency of the system and interdependence between
educational standards and the demands on the building practitioners.

Until now we have analyzed formal documents which describe the way the private building control
is organised. Although the experiences in the countries with private building control sound positive, we
haven not found or studied research which compares in depth public versus private building control.
The next research activities should be focussed on examining the effectiveness and efficiency of
private and public building control in practice. In Netherlands an experimental project will start in the
immediate future with the certified Building Decree Test. As mentioned the basic principle is to certify
private firms and parties for parts of the Building Decree (e.g. structural safety, fire safety, building
physics, etcetera). The rationale for this classification lies in the way the Building Decree is structured
and the Dutch building industry is organised (with specialist experts). A complementary approach could
be to research the possibility of a certification scheme based on construction works (e.g. dwellings,
commercial buildings). Another important research topic will be the development of a framework which
guarantees the competence of both public as private building control. The experiences in other
countries ca be used here as a frame of reference.

4. CONCLUSIONS.

This paper focuses on private versus public system for plan checking and site-inspections. The
question how the quality, skills and competence of inspectors can be guaranteed is of course of great
importance, but there are more preconditions and ingredients for an effective and efficient building
control system. The technical requirements should be clear and nationally wide uniform. The most
obvious solution is that an organization (with representatives from governmental organizations and the
building industry) defines the regulations at a national level. The performance approach as used
among others in the Netherlands provides a good basis. In the future determination methods are
uniform in Europe if the Euro Codes are implemented in all the countries. All countries can set their
own limit values that can vary because of regional reasons (like climate and geophysical factors). It is
important that the systems are the same and that a set of approved documents (with acceptable
solutions) and alternative solutions is kept up to date. The procedures should be transparent, effective
and efficient. It must be possible that an applicant can get information about the feasibility of the
planned construction work as early as possible. This could be realized in various ways, for instance by

8
making a distinction between a permit for location dependent aspects (e.g. planning permit) and a
permit for location independent aspects (e.g. building permit) of construction works. Other ingredients
that can contribute to this goal are the introduction of an obligatory pre consultation meeting, a phased
procedure and fixed permit handling times.

Almost every European country used to have a ‘traditional’ control system, in which local authority
building control played a key role. This system has undergone major changes and the role of private
organizations within the permit procedure has grown considerably. Due to liability reasons this has
been the case in Belgium and France for a long time. In Germany the responsibility of the check
engineer to enlarge the security that buildings are built according to the rules also goes back a long
time: to the early 1920s. In the other countries however the developments are from a more recent date.
In England Approved Inspectors have been able to take over the role of local authority building control
since the mid 1980s. At the moment the English are considering enlarging the role of private
organizations further by introducing a form of self-certification for architects. This could mean that
inspection and control could be integrated in the design and draft phase of building projects. The same
idea is behind recent propositions in the Netherlands to certify architects, building advisory
organizations, construction companies, etc. to check whether the plan meets the technical
requirements of the Building Decree. In Norway and Sweden the decision has been made to move
away completely from the traditional role of local authority building control. The applicant is responsible
to take care of the necessary inspections. Local authority building control checks the control plan. In
Denmark local authority building control can contract out inspections to private organizations, but they
stay responsible for the inspection. To our knowledge there are no developments in Denmark
comparable with those described for the other countries. In Australia a nationwide uniform system of
competency standards for building surveyors has recently (2003) been approved by all States and
Territories. Both private and public building surveyors fall inside the scope of the framework.

With the exception of Belgium and France (where financial and liability reasons play an important
role) the main motives for other countries to adapt their system is to enlarge the quality of the building
control and to diminish the administrative burden for applicants. The systems in Belgium and France
are not an inspiring example. Apart from the fact that these systems there are the result of historical
factors, the disadvantages seem great. Main disadvantage is that this option creates a dependency of
the building regulatory system on the insurance market. In France we see furthermore that, because of
the important role of private organizations (including insurance companies), local building control
authorities hardly execute any preventive inspections anymore. This means that there is a category of
construction works (where there is no control by private organizations) that are not controlled at all.
The experiences in the other countries support our conclusion that the Netherlands should develop a
system in which private and public building control work side by side. A certification/accreditation
framework both for public and private inspectors in which educational standards and the demands on
the building practitioners are linked, offers the optimum chance for effective and efficient actual control
and inspection.

6. REFERENCES.

ABCB (Australian Building Code Board) ABCB, media release 2003, National competency standards
for building surveyors (website www.aib.org.au)

Beller, D., P. Everall, G. Foliente and B. Meacham, 2001, Qualitative versus quantitative aspects of
performance-based regulations, CIB World Building Congress, Wellington, Australia.

Bergeron, D., B. Bowen, B. Tubbs and T. Rackliffe, 2001, Acceptable solutions, CIB World Building
Congress, Wellington, Australia.

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Bowen, R.P. 1997. Final Report of CIB Task Group 11, Performance-based Building Codes.
International Council for Building Research and Documentation.

Institute of Building Control 1997. Review of European Building Regulations and Technical Provisions.
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