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  • Writer's pictureDavid George

FM Insights - Compliance

With over 30 year's experience with global FM operations, our resident expert, Iain Clarke EUR ING CEng FCIBSE MAPM CIWFM shares some of his insights on trouble shooting FM contracts in the first of a series of FM insights.


How do you know if your portfolio, estate, building, or contract is operating within the compliance threshold?

What mechanisms are there in place for you to receive the level of information that satisfies your need to know?

Compliance and asset data management

A key component of knowing whether your portfolio, building or contract is compliant, is to understand the quantity and location of plant and equipment (assets) and the type of planned preventative maintenance (PPM) programme being used to manage the maintenance. Using an industry recognised PPM system, is a good way of managing maintenance from a statutory and mandatory perspective.

It is important to note that building services are designed and installed to operate safely and provide a satisfactory level of comfortable working environments suitable for the building occupants to work and operate with in the building. This may also include the provision of resilience to electricity, gas and water utility and security services. The requirement for a repairs and maintenance schedule for a wide variety of building services and plant are covered under legislation, which basically means there is a legal requirement for regular inspection and maintenance required to provide assurance and certainty the plant and equipment are operating safely and reliably.

Assessing compliance effectively starts with an up-to-date building services asset, equipment, and systems list. Without knowing what plant and equipment you have in your buildings across the portfolio, the likelihood of being compliant is zero. Some of you reading this may smile and think that you have certificates and logbooks for statutory plant to confirm PPM and records of remedial actions as required, and that is great news and I’m sure very comforting.

But do you really know for sure?

What about the assets installed because of refurbishment project, lifecycle replacement, maintenance upgrades, or just tucked away in a locked room long assumed to be a store cupboard only to uncover it housed a gas fired boiler and associated plant.

The last point may be considered randomly obscure or obscurely specific, but it happened to an organisation between the first and second lockdown in 2020. At the time, the engineering team were reasonable new to the building and were investigating a water leak. The managers and engineers on the contract were not part of the organisation when the plantroom was last known to exist. It transpired from the investigation, a lack of updated asset information led to an inaccurate asset list being used in good faith by a team transitioning new personnel, consequently the identity and location of the gas boiler was never updated on the asset register and remained unknown and missed until the water leak incident. Incidentally, the last time any work on the boiler could be found was in 2018/19

Whether you know or assume the asset list for your building, contract or portfolio needs updating, one thing is certain; asset lists are notoriously difficult to maintain and keep up to date. The quality of the asset information is often compounded by the lack of up dated information for a wide variety of reasons, some of the key factors may be

  1. · Budget.

  2. · Mobilisation.

  3. · Timescales.

  4. · Resources.

  5. · Change management.


Compiling an asset list with appropriate age and condition to make sure forward maintenance planning can be understood is costly. As a client, convincing a budget committee for a new budget to confirm the assets your team and managing and maintaining is difficult, particularly if the regular monthly reports and key performance indicators (KPI) have confirmed statutory compliance has been achieved. If you are lucky to get budget for a new asset age and condition list, what about the costs to maintain the integrity of the list? Relying on it being including in contract clauses with your suppliers, is not going to be sufficient unless there are robust process and procedures in place.

As a supplier, maintaining the asset records relies on receiving enough information in the correct format to add or omit assets from the list. This may extend to information being received from others who are linked to the client but not directly part of your contract. This criterion should be included in the contract specification, and even if it is, it is worth specific questioning relating to involvement, scope and responsibility as the costs will need to be sufficient to cover the management and administration time required for it to be successful.


As a supplier, maintaining an asset register begins at the start of a contract with asset verification. Not fully committing to this stage of the mobilisation process, effectively places every KPI, compliance certificate, planned maintenance schedule, forward maintenance and backlog recovery maintenance in jeopardy, compounding the contract functionality and exit planning process by not verifying the asset data.

As a client, if the supplier carries out a good asset verification stage, there may be a cost and compliance risk between the verified data and the tender data pack information. Verifying asset data takes time, therefore reducing the mobilisation time, compounds the risk of the supplier being unable to verify the assets sufficiently to understand the variances in on site data verses tender data. Being able to collaborate a sufficient period of time for asset verification will enhance the contract for both client and supplier, even if this means extending the mobilisation time scale for this element only, the benefits are worth it.


As mentioned above the time to either compile a new or revised register of assets with age and condition information is much longer than you generally think. Mainly because it’s complex and requires competent resources using a standardised approach to tagging, routing and gathering information. The same goes for the management and upkeep of an existing asset register, linking all the various facets that potentially have an impact on the change, omission or installation of new assets. Whichever method is used to gather asset data, the time taken to do it properly pays dividends.


asset information gathering requires competent resources, structured and diligent with detail. The same approach of using competent resources should be applied to setting up PPM schedules integrating statutory and mandatory tasks using the asset data. While the last two sentences are probably common sense to most reading this. It is entirely feasible for maintenance engineering teams to be engaged in collecting assets to a structured list or just collected, with the expectation the information will be sufficiently useful to make an asset list and PPM schedule. It is also entirely feasible the task of collecting assets will be in addition to their business-as-usual tasks. In this type of scenario, the time taken is a key factor, alongside the accuracy or consistency of the data being collected.

The competency of the maintenance engineering teams delivering engineering maintenance tasks is not in question, neither is the capable of multi-tasking, which is a usual trait in facilities maintenance engineering roles. However, it is the best use of resource when the output of the asset list is to deliver statutory PPM tasks and maintain asset to legislative standards.

Change management.

It is important to have a robust process to manage how the asset register is amended and updated when assets are installed or replaced. It is easy to forget to amend an asset register when like for like replacements happen, particularly when carried out as part of remedial or reactive works. Alternatively, giving the new asset the same asset number as the removed asset, often forgetting to amend the asset history, or age and condition. Changing the asset register, will need to link into the PPM schedule and ultimately compliance management and records.

If you need some trouble shooting help for your outsourced or in-house hard FM service, contact Iain for a free initial consultation at


Available information from Professional Institutions

There are several professional bodies and institutions that offer guidance and information on asset registers, gathering and recording information, statutory and mandatory PPM.

The information below is from the Chartered Institution of Building Service Engineers (CIBSE), specifically Guide M: Maintenance Engineering and Management (2014), which provides

“…best practice for those who have responsibility for the management and maintenance of the engineering services in a building. It also aims to inform those who design and construct buildings and raise awareness of the implications their decisions have on enabling effective management and maintenance.”

For information on compliance and legal obligations read Chapter 15 Legislation and Compliance and don’t forget to download the separate appendix document Statutory Compliance and Legislative Guidance from the CIBSE Knowledge Portal. The appendix document did not form part of the original 2014 publication and is available in download format only.

Related to asset register and specifically age and condition, Chapter 12 Economic life factors and end of economic life has useful guidance on the predicted life expectancy of plant and equipment. The information can be used to benchmark the lifecycle replacement timescales used to plan forward maintenance and backlog recovery maintenance.

Please note the new version of CIBSE Guide M will be available later in 2023, more information can be found at CIBSE Knowledge Portal by visiting


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