Quality Assurance for Domestic and Non-Domestic Buildings
The role of the auditor
Technical non-compliance sizing
Common audit non-compliances
BER Audit Selection
BER Appeal Process
Revocation of a BER
BER Assessor Independence - Guidance note
The quality of service delivery by BER Assessors is central to the reputation and effectiveness of the BER scheme, both for the purposes of fulfilling legal obligations on building owners and of stimulating action to improve the energy performance of buildings. That quality of service has two key dimensions: competence and conduct.
As the Issuing Authority responsible for the BER scheme, and as part of an overall suite of provisions governing the registration and performance of BER Assessors, SEAI has put in place a quality assurance system for BER Assessors, and a related disciplinary procedure. Through this system and procedure, SEAI will maintain a strong focus on monitoring the technical performance and professional conduct of BER Assessors, and taking appropriate corrective action. This policy is designed to serve the interests of clients for BER services and of all reputable BER Assessors.
The Quality Assurance System and Disciplinary Procedure outlines the key elements and processes of the Quality Assurance System and of the Disciplinary Procedure for BER Assessors. It applies equally to BER Assessors operating in either the domestic or non-domestic buildings sector. Disciplinary sanction can arise from audits or complaints. Audits can be selected on either a random or targeted basis at SEAI’s discretion.
Auditing is a key tool through which quality control of BER assessments is implemented. The aim of the BER Audit Programme is to identify technical, procedural or system faults in a timely manner so that:
- Any errors identified can be corrected or other appropriate action taken in relation to published assessments;
- Such faults are avoided in future through feedback directly to the BER Assessor concerned and to other BER Assessors as appropriate through the relevant communication channels; and
- Such faults are avoided in future through disciplinary action as appropriate.
Audits are carried out on both the BER Assessor and BER assessments to ensure compliance with both the relevant BER technical methodology and the Code of Practice for BER Assessors.
Selection of BER Assessors/ assessments for audit is on both a targeted and a random basis with due consideration of anomalies / risks in ratings. Selection of a BER Assessor for audit should not be interpreted as connoting any prior presumption by SEAI of there being error/ non-compliance with the relevant BER technical methodology, the Code of Practice or the 2006 Regulations on the part of the BER Assessor concerned.
BER QA auditors carry out audits on behalf of SEAI to review compliance with the relevant methodology and the BER Assessors Code of Practice. In verification that an audit request is issued on behalf of SEAI, please refer to NAS and NDNAS notice board.
All audit requests are sent to the Assessors registered email address. It is required that a BER Assessor responds to audit requests by SEAI within 21 days from the issue date. Failure to respond to an audit request will result in penalty points and possible revocation of the BER assessment. Audit submissions can only be accepted from the BER Assessors registered email address.
The BER Assessors registered email address can be changed on request by contacting the BER helpdesk at email@example.com.
Audits may be carried out at the premises of SEAI or its agents, of a BER Assessor, his or her principal, and/or at the site(s) where the relevant buildings(s) are located.
SEAI reserves the right to carry out audits and inspections without any prior notice to the BER Assessor or his/her principal.
Assessors should carefully review audit requests to ensure that the audit submission includes the relevant information to demonstrate compliance with the relevant methodology and BER Assessors Code of Practice. All items requested in the audit request should be included in the audit response.
In response to an audit request, the Assessor should include the audit number and should address each audit item with reference to relevant sections of submitted documentation, where appropriate.
The Assessor should refer to the relevant section of the methodology, technical bulletins, survey guide, FAQ's and Code of Practice when responding to the audit request.
The role of the auditor:
The core role of the BER Quality Assurance System is to monitor and ensure widespread operational compliance by BER Assessors with the Code of Practice and the relevant technical methodology. The system will thus help to assist BER Assessors in the effective discharge of their duties and to ensure the accuracy of assessments.
Auditors are appointed by SEAI to review compliance with both the Code of Practice and relevant methodology. The objectives of the QA process include:
- Improving the knowledge base of BER Assessors by providing feedback and direction on technical findings on an individual or collective basis, on common sources of error or misunderstanding
- Identifying possible requirements for adjusting the applicable automated inline validation boundary values when lodging BER data files to the National Administration System
- Informing the decision making process on selection of BER Assessors/assessments for more detailed or intensive auditing
- Informing the decision making process on corrective actions, including, where appropriate, disciplinary action.
Technical non-compliance sizing:
As part of the Quality Assurance System and Disciplinary Procedure, audits are carried out to confirm compliance with the Code of Practice and relevant methodology. Where technical errors are identified in audits, their impact on the rating is sized in order to determine the Severity of non-compliance based on the following sizing matrices.
Common audit non-compliances:
- Audit submission not submitted from the registered email address
- Survey form does not include the assessor details
- Audit submission is unclear/illegible
- Audit submission does not address the audit items raised
- Clear reference to supporting documentation not provided
- Audit submission is incomplete
- Audit submission does not include property address
- Audit submission contains survey detail on an email or cover letter rather than contained in the Survey form record
- Data retained is not adequate substantiation
- Assessors/employers not maintaining the registered email address in response to audit requests
BER Audit Selection
While we are keen not to unnecessarily burden assessors, it is vitally important that SEAI maintain a high level of monitoring on BER Assessors and the quality of ratings which they publish, thereby protecting the scheme integrity and the public confidence.
Every BER Assessor can expect to receive:
- at least one Data Review audit per year for which a typical response should not exceed 30 minutes;
- at least one Desk Review or Documentation and Practice Audit per year for which a typical response is 1 hour for the former or 2 hours for the latter;
- additional auditing on a frequency reflecting the number of BERs published, risk profiling, complaints or other indicators;
BER Assessors are required to secure and retain supporting evidence in accordance with the survey guide prior to BER publication – the availability of which will greatly accelerate completion of audits. Please note too that suspended BER Assessors’ ratings may be subject to audit.
BER Appeal Process:
As detailed in the Quality Assurance System and Disciplinary Procedure, an Assessor has the right to appeal all audit findings, penalty points resulting from findings, suspensions or terminations. Penalty point appeals must be made within 14 days of such points being formally notified to the Assessor.
Assessors must complete the audit appeal document and e-mail it to firstname.lastname@example.org The Assessor needs to clearly detailing the audit number and the grounds for appeal. An appeal should include reference to the particular audit and include, where relevant, any supporting evidence.
In lodging an appeal, the BER Assessor should carefully review the audit findings in the audit report with reference to the audit request and the audit submission. Where there are grounds for appeal, the Assessor should refer to the particular audit finding and detail clearly the grounds for why a non-compliance should be changed to one of compliance. The Assessor should make reference to the relevant section of the methodology, technical bulletins, survey guide and FAQ's and provide relevant documentary evidence in support of the appeal. Decisions arising from the appeals process are final
Revocation of a BER:
Under Regulation 17 of Statutory Instrument No. 243 of 2012, SEAI may revoke a BER assessment where it has reasonable grounds for believing that the BER data file was not completed or issued in accordance with the regulations. A BER assessments that has resulted in either a Severity 1 or Severity 2 non-compliance results in a revocation of the relevant BER from the National Administration System. A revocation of a BER data file does not affect your right to appeal.
When a data file and associated BER certificate is revoked due to a Severity 1 or Severity 2 error or for other reasons, the BER Assessor will be requested to:
- inform the BER client and other affected persons of the error and revocation;
- request the BER client to destroy all printed copies of the revoked BER certificate and associated advisory report;
- re-submit a BER data file with correct values;
- re-submit the BER for publication;
- provide the BER client with the replacement BER certificate.
BER Assessor Independence - Guidance note
The document available to download below provides important guidance to BER assessors and SEAI scheme participants as to how they can meet the recently revised obligations for assessor independence when operating in certain SEAI administered schemes.
BER Assessor Independence - Guidance note.pdf (size 610.2 KB)