You know the contractor. That is not evidence.

An inspector is standing in your plant room with a clipboard, and she asks for the competence records for the contractor who signed off the fire door replacements last term. Not the invoice. Not the purchase order. The evidence that the person who did the work was competent to do it, and that you checked before they started.

You know the contractor. You have used them for years. That is not what she is asking for, and it is not what your name on the duty-holder paperwork stands for.

The duty is yours, not the contractor's

Under the Building Safety Act 2022, the Client is the person or organisation for whom the building work is done, and that is typically the developer or the building owner. In a school or campus setting, that means the trust, the local authority, or the estate department that holds the budget. The Client can be a public organisation, and it carries the legal duties that come with the role.

Contractors work alongside the Client. They carry out and may oversee the construction work, and their roles range from site supervisors and installers to engineers, joiners, plasterers and glazers. The Act introduced new legal duties for some existing roles, including those involved with designing, building and refurbishing higher-risk buildings, and the design and construction guidance sets out what clients, principal designers and principal contractors must do to create safer buildings.

So when a contractor's competence is questioned, the question lands on the person who appointed them. That is you, or the person whose name sits above yours on the paperwork.

What the inspector actually asks to see

The Building Safety Regulator expects evidence, not assurances. For building control work in England, individuals and organisations must be registered with the BSR, and the registers include the inspector's name, employer, and the BSR-regulated activities they are registered to do. That is the standard the regulator applies to its own people, and it is a useful mirror for what it expects from yours.

For contractors, the evidence test usually comes down to four things:

• Qualification and registration. The certificate, card or registration number that shows the individual is competent for the specific task. Not the company's accreditation. The person on site.
• Scope. A clear record of what they were appointed to do, and confirmation that the task sits inside their competence. The building inspector competence framework is explicit that professionals must recognise the boundaries of their competence and only undertake work for which they have relevant competence.
• Supervision. Where the work is done under supervision, the record should show who supervised it and what was checked. The framework says all supervised work should be recorded as appropriate, including details of the supervisor and supervisee.
• Currency. Competence is not a static achievement. It requires maintenance and development, and the framework is clear that it will be reviewed on a regular basis.

In a school, the practical version of this is a folder or a system that holds the gas safety certificate, the electrical installation condition report, the fire door inspection record, and the competence evidence for the person who did each piece of work. If those four things live in four different places, you cannot produce them in ten minutes.

Where the evidence usually lives, and why it fails the test

Most estates teams can find the contractor's public liability insurance and the method statement. Fewer can find the individual's qualification for the specific task, dated before the work started, with a named supervisor where supervision applied.

The gap is usually not dishonesty. It is that the evidence was collected for procurement, not for proof. The procurement file has the company's ISO certificate. The site file has the sign-in sheet. Neither answers the inspector's question.

The Building Safety Regulator's guidance covers the full lifecycle of higher-risk buildings, including duties of Accountable Persons and the golden thread of information. The golden thread is the principle that information about a building should be kept and handed over in a form that can be used. Competence records are part of that information. If they are not kept, they are not part of the thread.

For a head of property, the test is simple: if the inspector asked for the competence evidence for the last three contractors who worked on your fire safety systems, could you produce it before the meeting ends?

What good looks like on a campus

Good looks boring. A single register, updated when a contractor is appointed, that records the individual's name, their qualification or registration, the scope of work they are approved for, the date the evidence was checked, and who checked it. For supervised work, the supervisor's name and the record of what was overseen.

It also looks like a rule that no contractor starts work on a safety-critical system until that record exists. Not a rule that says the paperwork will follow. A rule that says the work does not start.

That rule is harder to enforce on a school site than on a construction project, because work arrives in small packages: a boiler service, a fire door adjustment, a leg of the EICR remedial work. Each one is small enough to feel exempt. None of them is exempt from the duty.

The Building Safety Act 2022 identified new roles and responsibilities for people and organisations responsible for the safety of occupied high-rise residential buildings in England, and the duties on clients, principal designers and principal contractors apply to higher-risk building work. Schools and campuses are not all higher-risk buildings, but the competence principle applies to every building where a safety-critical system is touched. The inspector who asks the question does not check the building's classification before asking.

Your 60-second self-check

• Could you produce the individual competence evidence for the last three contractors who worked on your fire safety or gas systems, dated before the work started?
• Does your contractor register record the scope each person is approved for, or just the company name?
• For any supervised work, is the supervisor named and the oversight recorded?

If you want to know your own control score before someone more senior asks for it, the free 5-minute Director's Risk Check gives you that score, your portfolio's breach exposure with official sources attached, and a board-ready briefing you can take into the next meeting. You can run it at hermanwa.com/risk-check.

Herman's verdict

A contractor's reputation is not evidence, and a procurement file is not a competence record. The inspector will ask for the certificate with the individual's name on it, and the only acceptable answer is the one you can hand over before the kettle boils.

— Herman