Jonny Millard, managing director of UK Fire Door Training, explains how better, standardised approaches to evidencing competence could help improve compliance and ultimately create a safer built environment
If you asked most people working in the built environment whether they’re competent at their job, the answer would almost always be yes.
The people I encounter every day in the fire industry are, by and large, very knowledgeable, experienced professionals who care about what they’re doing.
They’ve spent years developing expertise; they take their responsibilities seriously, and they’re genuinely committed to doing their job well.
But being competent and being able to prove it are two very different things. And right now, the industry has no consistent, reliable way of doing the latter.
I’ve lost count of the number of conversations I’ve had with experienced, capable professionals who are clearly good at what they do, but who would struggle to explain how they evidence their competence beyond a collection of certificates and years in the job.
Recent research we carried out reflects exactly that challenge. While most respondents believed they had the skills, knowledge, experience and behaviours (SKEB) needed to describe themselves as competent, almost six in ten admitted they didn’t know how to evidence it.
Competence without proof
Competence is now a legal requirement, and the industry is still coming to terms with the changes introduced by the Building Safety Act 2022.
We have the regulatory frameworks now, and all the progress we’ve made so far is, of course, very welcome.
But very little thought has been given to how those on the ground evidence their competence in a way that meets these new expectations.
The Industry Competence Committee’s (ICC) Annual Report 2025–26 acknowledges this, saying that adoption remains inconsistent across organisations and the wider supply chain.
It’s encouraging that we’re making progress in defining competence, but it’s clear we’re still missing a consistent, industry-wide approach to evidencing it.
The evidence challenge
The fire door industry gives us a useful example of the wider challenge facing the built environment.
Industry inspection data suggests that around three-quarters of fire doors in UK buildings fail inspection. That can be down to many reasons, from poor maintenance and third-party alterations to changes made during the life of a building.
But what people often fail to consider is that many of these issues ultimately lead back to questions of competence. Who carried out the work? Were they working to the correct standard? Were the right checks completed? And, crucially, where is the evidence?
Too often, there is no reliable record to answer those questions.
That concern isn’t unique to my own experience. Our research found that 87% of respondents had seen people carrying out fire door work they believed those individuals were not competent to perform on more than one occasion.
The same challenge exists across almost every safety-critical discipline in the built environment. Without a consistent way to evidence competence, organisations are left relying on assumptions, rather than proof, about the people carrying out critical work.
The behaviours problem
Historically within the built environment, competence has often been assumed from experience. If you’d been working in the same role for 15 years, the assumption was that you knew what you were doing.
But the Grenfell Inquiry showed us that experience alone is not enough. Many individuals involved in the building’s safety had long careers, but critical risks and warning signs were missed, and procedures were not always followed.
Behaviours are one of the four pillars of competence that the industry is least equipped to evidence. How do you demonstrate that someone challenged unsafe work, recognised the limits of their own competence or followed the specification when commercial pressures made cutting corners tempting?
It’s perhaps no surprise then that competence or SKEB is rarely discussed in many workplaces. If we don’t routinely talk about competence, it’s difficult to see how we can consistently evidence it.
The organisational gap
The individual competence problem is well understood, even if the evidence infrastructure isn’t there yet.
However, the part that’s discussed far less is the organisational competence problem.
I think if we were being honest, most businesses in this sector don’t have clear visibility of who is competent to carry out which safety-critical roles or whether they could evidence that competence if they were asked to.
For years, competence has been tracked through informal knowledge, professional trust and personal relationships.
That might have worked when the regulatory framework allowed it but the Building Safety Act has changed everything.
Organisations now have responsibilities as well as individuals, and they’re increasingly expected to demonstrate that competence has been assessed, maintained and managed rather than simply assumed.
That shift requires a very different approach to the way we think about competence.
What needs to change
There’s a pattern emerging in the built environment that concerns me more than the skills gap itself.
The frameworks, guidance and standards are here, and they’re continuing to evolve. But adoption remains slow. That’s not me being cynical – it’s what the ICC’s own reporting tells us.
The reasons are understandable. The frameworks can be difficult to navigate, guidance is spread across multiple bodies and documents, and most professionals are busy delivering projects rather than reading competence frameworks in their spare time.
There’s also a perception that enforcement is still some way off. But the Building Safety Regulator is already active, and organisations are increasingly being asked to demonstrate how competence has been assessed and maintained.
The conversation about competence has focused heavily on developing it, and that work needs to continue. But developing competence and evidencing it are two different challenges, and we’ve spent far more time on the first than the second.
What we’re missing is an evidence infrastructure. We need a practical, consistent way for individuals to demonstrate competence throughout their careers, not just at the point they gain a qualification. We need organisations to understand who is competent to carry out safety-critical work, where the gaps are, and how they can evidence the decisions they make.
Most importantly, we need to stop treating evidence as an admin burden that happens after the work is done and start treating it as an essential part of competence itself.
Because in today’s regulatory environment, competence that can’t be demonstrated is becoming increasingly difficult to defend.
The uncomfortable truth
The UK has an evidence gap, and it runs deeper than most people in the industry have been willing to acknowledge.
In a regulatory environment where what you can prove matters as much as what you can do, that gap is a fundamental risk to the individuals, organisations and residents who depend on the built environment being managed safely.
We have the frameworks, legal obligations and in most cases, the competent people. The one thing we have failed to build is the proof.
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