Competence and Culture

Competence is the quiet failure point in the building safety regime. Your safety case rests on findings produced by other people, and if you cannot show they were competent to produce them, the findings are doing less work than you think.

Statutory basis
Requirement
The safety case report must address the competence of those involved in risk assessment In force
Guidance
Preparing a safety case report, last updated 6 December 2024
Wales
Fire risk assessments must be made by a competent person, ss.30 and 82 Not yet commenced
Common failure
Training attendance records offered as competence evidence

Attendance is not competence

The most common competence evidence we see is a training matrix: names down one side, courses across the top, dates in the cells. It answers the question “who attended what?” It does not answer the question the regime actually asks, which is whether this person can do this work, make these decisions, and recognise this risk.

GOV.UK guidance requires the safety case report to address the competence of those involved in risk assessment. A course certificate does not address it. It evidences exposure to content, on a date, with no assessment of whether anything was retained or can be applied.

Assess against the work, not the job title

Competence is specific. A fire risk assessor competent in a purpose-built block of flats is not automatically competent in a building with a complex external wall system, a residual large panel system structure, or a stay-put strategy under review.

A defensible competence position assesses three things together:

  1. The work the person actually performs, at the level of the specific task rather than the role.
  2. The decisions they are expected to make unaided, and the ones they must escalate.
  3. The risk carried by those decisions if they get them wrong.

Where those three are documented, a training record becomes meaningful, because it is evidence in support of an assessment rather than a substitute for one.

Culture is what happens when nobody is watching

Culture is difficult to evidence and easy to assert, so most safety case reports assert it. A more useful approach is to describe the mechanisms that would reveal a poor culture, and then show what they have revealed.

  • Does bad news travel upward? Show an example where it did, and what changed as a result.
  • What happens to an overdue action? If the answer is “it stays overdue”, that is your culture, whatever the policy says.
  • Are residents’ concerns treated as intelligence or as complaints? The complaints system is a required mechanism, but what you do with the pattern in it is the cultural signal.
  • Can a contractor stop work? And has one ever done so?

Why this matters commercially

The regulator is moving to an intelligence-led model that looks first at organisations responsible for multiple higher-risk buildings. That shifts the question from “is this building’s paperwork adequate?” to “is this organisation capable of managing buildings safely?”

Competence and culture are how that second question gets answered.

Last reviewed 17 September 2026.