Managing Non-Conformities Under PAS2035

Non-conformities are deviations from the PAS2035 standard or project specification that emerge during retrofit work. They range from minor documentation gaps to significant quality issues. Effective management of these non-conformities is essential for maintaining project integrity, demonstrating compliance, and protecting all parties involved in the retrofit process.

What Constitutes a Non-Conformity?

A non-conformity exists when work or documentation fails to meet the requirements set out in PAS2035, the retrofit design specification, or relevant building regulations. Examples include:

• Installation quality falling below standard (gaps in insulation, poor air tightness sealing)
• Missing or incomplete survey data before retrofit begins
• Design changes implemented without proper authorisation
• Inadequate commissioning or performance testing
• Incomplete handover documentation or operation manuals
• Non-compliance with thermal bridging requirements
• Failure to achieve specified air permeability targets

Not all non-conformities carry equal weight. The framework distinguishes between major non-conformities (those affecting safety, performance or compliance) and minor ones (documentation issues or minor quality variations with limited impact).

Early Detection and Prevention

The best approach to non-conformities is prevention. This requires:

1. Clear specifications – Ensure detailed retrofit design and site-specific specifications are agreed before work starts
2. Competent teams – Confirm all operatives are trained and competent in PAS2035 requirements
3. Pre-construction planning – Undertake thorough surveys and risk assessments to identify potential issues
4. Regular site inspections – Conduct planned inspections at critical stages, not just at completion
5. Quality assurance processes – Implement daily toolbox talks and peer checking on site

Many non-conformities emerge because communication breaks down between design, specification and installation teams. Establishing clear lines of communication and regular progress meetings reduces misunderstandings significantly.

Identifying and Recording Non-Conformities

When a non-conformity is discovered, it must be formally recorded. Documentation should include:

• Date and location of the non-conformity
• Clear description of what does not conform and why
• Reference to the specification or standard being breached
• Photographic evidence where relevant
• Impact assessment (does it affect performance, safety or compliance?)
• Name of the person identifying the issue

Assign responsibility immediately. The project manager or retrofit coordinator should establish who owns resolving each non-conformity and set a clear deadline for resolution.

Resolution and Corrective Action

Non-conformities must be resolved before the project can be signed off. Resolution typically follows one of four routes:

1. Correction – The work is redone to meet specification (most common for installation issues)
2. Rework – The element is rebuilt or reinstalled to standard
3. Concession – All parties agree the non-conformity is acceptable as-is, documented in writing
4. Redesign – The specification is modified and approved by all stakeholders, with work adjusted accordingly

For each non-conformity, document the chosen resolution method and evidence that it has been implemented. Photographic records and signed-off inspection reports are essential here.

Testing and Verification

Once corrective action has been taken, verification is required. This might involve:

• Re-inspection by a qualified person
• Repeat air permeability testing if insulation work was involved
• Thermal imaging to confirm bridging issues have been resolved
• Re-commissioning where systems were affected

Only when verification confirms the non-conformity has been resolved should it be closed on the register.

Documentation and Handover

Non-conformities must never be hidden or omitted from final documentation. Your final report to the client should include:

• A summary of all non-conformities identified
• How each was resolved
• Evidence of resolution
• Any residual issues or concessions granted

This transparency is not a weakness—it demonstrates rigorous quality management and protects you and the client by creating an accurate record of the building's condition post-retrofit.

Learning and Continuous Improvement

Once a project is completed, review all non-conformities to identify patterns. Questions to ask include:

• Did certain trades consistently produce the same types of issues?
• Were particular design elements prone to non-conformity?
• Could better pre-construction planning have prevented these issues?
• Do our teams need additional training?

This analysis feeds into your continuous improvement cycle, reducing non-conformities on future projects and improving profitability by avoiding costly rework.

Managing non-conformities effectively is not about punishing mistakes—it is about maintaining standards, protecting performance, and building client confidence. A well-managed retrofit programme acknowledges that issues will arise, responds to them systematically, and closes them properly before handover.