Who Writes the SFG20 Industry Standard?
Jump to a topic
- 00:00 Introduction
- 00:44 Introduction to Jason
- 01:32 What working with Facilities Managers is like
- 03:08 How to become a Technical Author
- 04:50 How Technical Authors contribute to the Industry Standard
- 05:55 Adopting an Engineer's mindset
- 07:07 How SFG20 helps Engineers on-site
- 08:34 How do Technical Authors turn legislation into the SFG20 Industry Standard
- 10:23 How SFG20 defined what constitutes a statutory task
- 13:42 Why don't SFG20 task instructions read like regulations
- 15:24 Linking Primary Legislation to industry
- 16:50 Why don't SFG20 schedules tell engineers exactly how to do the steps
- 18:19 Qualifications and competence in the Building Safety Act
- 19:50 How to create a schedule using SFG20 software
- 21:26 What are 0Us - what are they and why can't frequency always be specified
- 23:15 How to SFG20 calculate timings for tasks in a schedule
- 24:14 How can 0U task competence be simplified
- 26:46 Does SFG20 have their own CAFM system
- 27:40 Why is it important to access the latest version of the standard
- 29:13 What are the risks of working to out of date guidance
- 31:25 Your next steps
Transcript
Who Writes the SFG20 Industry Standard?
Who is writing the SFG20 standard guidance? In this interview, you'll hear from Jason Instrell, Senior Electrical Engineer, IET industry representative and technical author at SFG20 on how he and the team produce the SFG20 standard from legislation. Jason talks through his journey from electrical engineer through to running his own business and now a technical author at SFG20. You are going to learn about how to turn legislation into a schedule, who is writing the SFG20 standard and the importance of an engineer mindset when producing the industry standard. Let's jump over to the interview, but if you've got any questions, pop them in the comments below this video.
Lisa Hamilton: Jason, can you start off by introducing yourself? Tell us a bit about your background and what it is that you do at SFG20.
Jason Instrell: Yeah, hi. Hi Lisa. And hi, everybody listening in. So, yeah, my name's Jason Instrell. I'm a Senior Electrical Engineer. I've been in the electrical engineering industry now for, feels like a very long time, 27 years.
So I carried out full old-school apprenticeship. I'm also the IET industry representative and technical assessor. And I sort of wear two hats for SFG20. So on one hand I'm a technical author, and on the other hand I'm an industry representative. So, yeah, that's me.
Lisa Hamilton: Brilliant, thank you. So, thinking about when you had your own electrical engineering company, Jason, can you tell me a little bit about your experience working with FMs and building owners?
Jason Instrell: Yeah, sure. So, I started my company when I was, ooh, I'd say 22 years old. So I started in a van, just myself, sort of grew that to 40 engineers over a very long period of time.
I liaised with numerous blue-chip clients all over the country, so nationwide. Our projects were very complex, so we seemed to fall in the high-risk type of projects with what we did. So we undertook high-level manufacturing projects, labs, schools, large commercial fit-out, Cat A, Cat B design, which I've seen some of the people listening in will know.
But what that allowed me to do, or sort of got me involved with is I was liaising with multiple people on multiple sites. So numerous facility managers, numerous owners, numerous directors, numerous contractors. So it was always very, very complex. And I think briefly for me, what I found complicated or the most complex with all that really was communication.
There seemed to be, when you have a lot of people involved, it might be okay at one level, but by the time it came down to the engineer level I suppose where I was at, there could be a lack of detail there. So that was sort of, for me, probably the most difficult thing in running my own company. And that's over a long time, Lisa. So, yeah. That's me really.
Lisa Hamilton: So I'm keen to understand a little bit more about that transition that you made from engineer to technical author. How did you end up being a technical author?
Jason Instrell: Well, yeah, yeah, no, that's an interesting one. So, basically, personally, I've always studied regulations, standards, being part of the IET, running your own company, you know, creating complex designs. You're always looking at multiple regulations, calculations. So I was always in depth with that, I suppose, and had a bit more knowledge out of BS7671.
The book sort of stopped with me, really, because all my engineers came to me, all my clients came to me, so I had to have that understanding there. And I think it was November 2022 when I came on to SFG20. So I was working in, sounds a bit strange, but I was working in an end-of-life hospital environment and a contact of mine called me out of the blue and just basically said, I've got this role. It's for a technical author. My first thing is, what is that?
I've never heard of it. I'm an engineer. What's a technical author? He sent me the information through, and I read it and I just thought, well, that sort of fits my experience. And I thought that being a, because I knew nothing about SFG20 or who writes it at this moment in time.
So I just thought for me, you know, being an engineer, perhaps I could help change, mould, adapt the schedules that I've seen and I've used. So yeah, I just sort of saw it as an opportunity to bring my experience as an engineer to the technical author that I'd never heard of before, basically. So that's, yeah.
Lisa Hamilton: How interesting. Would you mind telling us a bit more about the technical authors that you work with? Because you work in quite a large team, don't you?
Jason Instrell: Yeah, so basically we have a huge team of technical authors. And again, just leads into what I said. I didn't know anything about how it worked until I came on, and then I soon realised that we're all engineers.
So the team's fantastic. So I'm electrical, we have mechanical, we have gas, civils, building. So we're all engineers. And what I see is we're engineers writing for engineers. We're engineers before we are authors. And I think it's keen to say that, Lisa, you know, because I didn't think that was the case when I was on the other side.
I thought they were just writers doing this. But no, they are experienced engineers. I think one of us, you know who you are, if you're listening, we say he's been chiselled out of stone. He's been here that long. So, we call him the oracle. So it just says the type of people that are involved.
But yeah, so we are all engineers from all different disciplines. And we all obviously liaise together because on some schedules you'll have multiple different things.
Lisa Hamilton: Brilliant. So you're engineers, experienced engineers writing the schedules. How important do you think it is to have that engineering mindset when you are producing the SFG20 maintenance schedules?
Jason Instrell: I think so. For me personally, I wouldn't have taken a role if I wasn't an engineer because the way I look at a schedule and I develop a schedule, I look from an engineer's view first. So having stood in front of most of the assets that we write for, you have that additional dimension. So not only are you looking at the British standards, but then my mind and the team's mind will go, okay, hang on.
How did I do this? How did I maintain this when I was on site? And it brings that additional dimension. I'm not saying we are right all the time, you know, everybody does things differently, but at least having that, when you are developing your schedule, lifting that dimension puts you in the same position as our subscribers.
So I think that that is a key where SFG20 is different and what sort of placed me here really. Mm-hmm.
Lisa Hamilton: I've heard you say before when I'm writing the schedule and you actually get, I close my eyes and I'm there, I'm in front of the asset and I'm writing it as I'm actually doing that task. Yeah, which is brilliant.
So when you were working as an electrical engineer, how did SFG20 help you and your team?
Jason Instrell: So again, we were on numerous sites. So, I'll go back slightly when I was just on my own. So when it was me, an apprentice and probably another electrician, so I was introduced to SFG20 by a facilities director.
I can't remember his name, so I apologise there, but a long, long time ago, he introduced me to it. I'd already used many other schedules and things, and I found SFG20 the most easiest to follow. I mean, we're going back probably 20 years now, Lisa, so this would've been, you know, when it was still developing.
And I continued to bump into SFG20, as did my engineers, over hospital sites and with some of our blue-chip clients. We found it easy. I sometimes received it in PDF format. As I'm sure others have done. I sometimes was emailed the schedules. I sometimes had access to the laptop of the facilities manager and they showed me, you know, so I've seen it in all different aspects.
I liked personally, I liked the hyperlinks. I liked that I could look at it and check myself. Because you know, I'm sure engineers still do that. You know, we check, we make sure, and my guys found it very easy to follow step by step. So yeah, for me it was definitely what led me to come here because I had used it and I knew the ease of using it.
Lisa Hamilton: Got it. Thank you. Can you talk to us about how the team of technical authors turn the latest legislation and all the technical updates? How do they turn that into the SFG20 standard?
Jason Instrell: So it's quite, it's more of a complex procedure really than I understood when I was on site. Because I think we're all guilty of thinking, well, it's very straightforward. You just move that from a regulation into a schedule. It is, you know, and it's not like that.
So it can come from many forms. We know that legislation and standards change, adapt consistently. So what we have to do, we have to look at that. It may come from a technical inquiry where somebody's messaging saying, look, can you look at this?
It may come from one of us where we'll say, look, this has happened. It may come from a legislation change. So that's, shall we say, step one. Step two then is we have to look into that. So we don't just accept that, we have to research and we have to look into that. It can, we have to look over numerous legislations, regulations and standards.
It may have been updated in one regulation, but may have not been in another, and we have to bridge that gap. So it can be very complex, very time-consuming and, you know, creating one schedule can take months, absolute months. Absolutely. And I think, and it just lends back to your own experience as well, Lisa, where you know, you bring in your own experience and you think, well, I've not seen that before or I have seen that before.
So that also helps with your research. But we are like librarians maintaining a huge bookstore, and we have to go into that bookstore, research a thousand pages and 400 books to just find that little bit of information that relates to that updated standard. So, yeah, it—
Lisa Hamilton: Seems to be very passionate librarians, might I say? Yeah, indeed. Yeah. So there's a new definition isn't there, of a statutory task. What constitutes a statutory task? And this has been jointly agreed by SFG20, CIBSE, IWFM, and BESA. Can you tell us a bit about that definition please?
Jason Instrell: Yeah. So this was a huge moment really, and I'm sure a lot of other people listening will know. Over my career this has always been a problem, so you know, you may be on one site that shows you a document that has an amber task.
You'll be on another that shows you a document that says a red task and you are then all in the middle, stood there going, what do I do? Is it red? Is it amber? Who's correct? What this has done is it's allowed all, as you mentioned, everybody in industry now to agree a definition of statutory red task and I'll say briefly, I won't go into too much detail with it, but it allows us now to denote a task as red if we can have a traceable definition to primary legislation.
That's without going into too much detail. So that's a traceable link to primary legislation. I'll quickly do an example, Lisa, because it can be a bit complicated. So if I take an electrical schedule for a moment, like a periodic inspection testing, it's a red task, okay, how did we get there? Why do we put that as red?
So what we do as a team, we look at the British standard, which is BS7671, the wiring regulations, which is secondary legislation, non-statutory. We then think, where can that link to? So then we start almost climbing stairs. So we're at the bottom of the stairs at the moment. So we come to the next step and we say Electricity at Work Regulations.
So we link, but we've then got to get up those stairs right to the top. So then we think, well, how can we link that to primary legislation? We do by using the Health and Safety at Work Act, which is an act. So primary is an act, Health and Safety at Work Act, Building Safety Act. And because we have found that traceable link, we can define that as red, which is what the rest of the parties will also do.
So what we're saying to industry is when we do that as red, the other parties will be denoting that as red as well. It's a lot more detailed than that and we obviously have to bulk that up with real, in-depth regulations. But that's roughly how we sort of denote that as red. Can I just say as well, Lisa, with amber, because what I want to say as well is amber, what we class as an optimal task, is no less important.
And the reason we put that as amber is just because we don't have that final step. We can't quite get to the primary legislation, but it's no less important. Okay? We've still got all secondary legislation there. We've got guidance notes, we've got statutory instruments. We just can't quite lift up to the next stage to make it statutory with our defined definition, which is obviously now what we have to stick to.
Lisa Hamilton: Absolutely. And if I understand correctly, the reason that you're saying that ambers are so important is that, you know, if that asset was to break down operationally, financially, it could have a catastrophic impact on an organisation, but you just don't have to legally do it. So that's why you're saying it's not—
Jason Instrell: Exactly important. Exactly. Just because it's a red task. Yeah. You know, not a red task. I'll say it's no less important. It can create a health and safety risk if you don't do it.
Lisa Hamilton: Why don't SFG20 task instructions read like regulations or British standards? Because you told me earlier that they don't, but I'm keen to understand why.
Jason Instrell: That's, I get asked that quite a lot and I get asked that as part of my IET work as well. Yeah. Okay. So let's take a British standard. I'll try to be, I have to apologise, I've tried to be as brief as I can, but it's quite complicated. So in a regulation, a British standard will have design, installation, verification. It has a multiple of things within a British standard.
Obviously we are dealing with a small per cent of that. We're dealing with, although it's large, it's a small per cent in a British standard, so we can't, we don't want all that information in there. So when we are trawling through the regulations, there may be a task in there, but it's also aligned with parts of design. Everybody that's read a British standard will know there can be paragraphs of design and only small elements of other parts, so we can't take that, put that into a standard. We can't plagiarise, we're not allowed to do anything like that.
So we can only pick the parts that we need, then write them in a way that you guys out there on the call today will understand and easily be able to use. For me, I wouldn't want to stand there in front of an asset and have to read paragraphs and paragraphs of information. You know, I would just want to say, check the booster, check the pump, check the, you know, I would want it quite straightforward.
So that's why we don't take paragraphs of information and move it over because the British standard has multiple things in there, not just maintenance. It has design, verification, and we are just concentrating on one part of that British standard.
Lisa Hamilton: Got it. Okay. I've got a question here from the audience. Well, it's a comment really, relating to your climb the stairs analogy. Yeah. So this person is saying if you climb the stairs, you can link almost anything to primary legislation. For my organisation, this has not been a useful change. What would you say to that, Jason?
Jason Instrell: Well, we have had technical inquiries on similar to that. And I understand what they're saying, but it is, as I mentioned earlier, it is actually not that straightforward. I've given just a brief analogy of how we do that there.
But in between that we have to actually link, for one there is 13 documents we have to link. Just for the electrical tasks I've just mentioned sort of two with Electricity at Work Regulations and BS7671. So yeah, it is more complex. I feel personally it is better for the industry in what we've done.
I understand that there may be implications for some, but without this being in place, we are back to square one again where everybody's doing things differently and I think that has more of a detrimental effect on the industry than having, without having something there. So I would just say, what you led to that information we've got Lisa, that goes into a bit more depth, I would say to the subscribers, have a look at that. It will hopefully be in a bit more detail and show you.
Lisa Hamilton: Brilliant. Thank you. So just kind of following on from that, Jason, why don't SFG20 tell engineers exactly what to do down to each level of detail with the schedules?
Jason Instrell: Yes. Yeah. So, so basically as an engineer, we have to look at it in two aspects here. So we are here to tell people what to do, not how to do it. Mm-hmm. So fundamentally we are saying, if I've taken an electrical analogy again, we're saying check continuity of protective conductors, which is one of the electrical tests.
What I can't then say is check continuity of protective conductors by taking your meter out of the box, use lead A and B, put it onto X and Y, because that's reliant on the person undertaking the test. There's 400 different ways of carrying out that one test. We are relying on the skills of that person undertaking the test at that asset.
And, you know, we do have skill sets which will say electrical, mechanical, competent person. So you imagine if we did that, how large as well? One action would be, you know, rather than, so long it would be huge. And there's too many differences on different sites, on how people carry out tests.
So all we can do is just say, you do this, not how to do it. Mm-hmm. So that's how we operate and how we develop our schedules.
Lisa Hamilton: And this ties really well into qualifications and competence, doesn't it, which is such a focus of the Building Safety Act, which doesn't just affect people who are responsible for maintaining high-rise residential buildings. This piece applies to everyone, doesn't it?
Jason Instrell: Yes, it does. And the Building Safety Act, high-risk buildings and obviously we know it's high-risk buildings in different documents. We've also found a link there for that. The Building Safety Act, I think there's 12 occasions where the Building Safety Act mentions maintenance.
But what we have to do is go to secondary legislation to obviously use that for our schedules. And I was on site at the time when the Building Safety Act was implemented and I remember I was on a commercial site and I remember the contractor coming in saying, what's this, what's happening there? Because we were actually on a high-risk building that was defined as that.
So there's still a lot of grey area out there with the Building Safety Act. But what we try to do with our schedules, we have implemented changes in our schedules to accommodate the secondary legislation. Fire Safety Act, Fire Safety England Regulations, which is where the actual maintenance task goes.
Because I just say again, Lisa, that the Building Safety Act mentions maintenance and importance of maintenance. We have to—we're back to the stairs analogy again. We have to use the stairs analogy to find out where those tasks are that relate up to that. So yeah, the Building Safety Act sort of affects us all in one way or another. It doesn't matter what type of contracts you are, what you do.
Lisa Hamilton: Thank you. I've got a question here from the audience saying, can you advise on how to create a schedule using our software? So, so we have the functionality to do that. I mean, I guess the first thing would be are you competent and qualified to do that and knowledgeable enough?
Jason Instrell: Yes. Yes. I'd say it goes to skills. Because like I said, Facilities-iQ enables you to create a bespoke schedule for your asset. But I would always say that if you are creating an electrical schedule, make sure you are competent at creating or adapting that electrical schedule. If you're creating a mechanical schedule again, et cetera, et cetera.
It becomes down to skills, competence, training, which is what I'm involved with with the IET. So as long as you are competent, you're competent with that asset, you follow our guidelines as well. Because obviously we, as the technical team do all the legwork for you. I suppose, you know, we look for those legislations and regulations.
So as long as you follow those during your change on the schedule and you are competent to do so, then, yeah, yeah. You can create bespoke schedules. I, you may have to correct me if I'm wrong, or the product team may have to correct me, but when, if a task is denoted as red, you can't change the task from red.
That's all I would just say. It's red, it's red.
Lisa Hamilton: So we have a really extensive library of schedules, but I suppose that, you know, this particular person might have some highly specialised equipment or something and want to create their own guidance. So yes, it is possible. And we also have a team of professional services as well that can help guide you through that process as well.
Jason Instrell: Yeah, yeah, indeed.
Lisa Hamilton: Can we talk about zero U, Jason? What are they and why can't SFG20 always specify frequencies for tasks?
Jason Instrell: Okay, so zero U has always been a problem. It's been a problem when I was on site and I can look at it from an engineer's view and say, why do we always have these? We hate them as engineers.
Well, technical authors hate them. Okay, so the technical team do not like zero U. We do not like doing them. But if people, I'm sure if people read regulations like we do that they'll understand that it's very rare to get a frequency within legislation. It's, sometimes you can just look on one of your hands and find set frequencies.
I can think of a few in my head. BS9999, where we have frequencies in there. So we can only place a frequency on a task when there is a frequency in legislation, regulations, or standards that we can follow. So we can't just, for example, put 12 months because it's mentioned in a document somewhere. If we do that, we're liable to be challenged because what may be 12 months for one person would not be 12 months for another.
So what we are saying when we are placing a zero U is that we are saying it's user-defined. Okay, it's unspecified, so you need to use your site-specific information there. Just as I would, I'd have to look and think, well, there's four distribution boards on this site. There's only three on that site, so this will take me that long and only needs doing three-monthly.
This will only need doing six-monthly. So it's site-specific based on a risk assessment. But again, I would love to be able to put a frequency on there. I'd love to be able to say six months, three months, just as the team would, but it's very difficult to do. So we will only ever do it if we have the backup there to be able to do that.
Lisa Hamilton: Yeah. So there's a question here relating to timings. How do you calculate the timings within a schedule?
Jason Instrell: Yeah. So again, timings are based on our experience, basically. So if we have an asset that one of us has maintained, we will look at that and we will go, okay, so that asset, I've maintained that boiler, that took me 30 minutes.
So the engineers and the team will place that on there. As I do in the electrical schedules, I think, well, that's a 20-minute task. That's a two-minute task. That's a three-minute task. So it is thought about when we do it, it's not just something that's plucked out of the air. We do actually look at it and we liaise as a team, you know, because somebody may say, well, you forgot the booster pump. You forgot the secondary pump. You forgot the, you forgot the valve.
And we'll go, okay, so we'll add up. What time do you think? So yeah, we think about that as a team and it's a team effort. Each engineer will look around and think, well, that used to take me five minutes, actually take me three minutes. And that's the way we come up with the timing for specific tasks.
Lisa Hamilton: Okay, this is a topic that's causing a lot of interest. So one person is saying it makes it difficult for service providers to evidence compliance for assets that have a zero U red task attached to it. How can this be simplified to make it more practical and achievable?
Jason Instrell: That's a very good question. And that's, you know, again, that's, I, it can be simplified by making every standard statutory. So if we take the wiring regulations, it's non-statutory. It will be simplified by making them statutory and putting frequencies in there, but it's very difficult.
If every regulation had a frequency in there, even on basic checks, weekly checks and things like BS5839 does for checking fire alarm systems, then it would be happy days as we say in industry. But unfortunately it doesn't. So there's always going to be an aspect and an element of you chaps out there having to look at that asset and having to figure out a specific frequency based on previous testing, based on previous maintenance, and based on the condition of your assets.
So I would love to say it will be simplified, but I think until British standards, legislation, guidance notes, shall we say catch up probably and put some more information, it will always be very difficult.
Lisa Hamilton: And we are doing what we can to make life easier for users as well. So this is functionality that we're going to be introducing relatively soon to our new software Facilities-iQ is a way of looking at zero U tasks and saying, well, I've got 400 boilers and they're all new, so you know, I'm going to take a view on the frequency that that needs to be serviced.
And then you can apply that frequency blanket across that six-monthly, so you're not going through each schedule line by line. So I think that there are things that SFG20 can do and are about to do to help users. And I think we are—
Jason Instrell: Doing that though. And also we're also sort of, we're going to be introducing asset mapping and when we bring in asset mapping, that's huge. That's a key thing because the moment you start mapping your assets, the more information you can gather from site, the more you're going to be able to remove those zero U and the more you're going to be able to implement a frequency in there.
So, I mean, it's absolutely, the Facilities-iQ software is going to give the subscribers all of that in a package.
Lisa Hamilton: Do we have our own CMMS system? No, we don't. SFG20 are not a CMMS system. We're not trying to be a CMMS system, but CAFM systems are very much our friend and we integrate with them. So we, our software Facilities-iQ has been built to easily and freely integrate with all CMMS, CAFM and IWFM systems. So the answer is no.
But we integrate really, really smoothly and we've been doing a lot of work on our schedules, haven't we, Jason, to make them more kind of CAFM-friendly because different CAFM systems have different restrictions or different rules around accepting like number of characters into them. So we've been doing a lot of work to make it really simple for our content to directly flow into, I'm going to say CAFM systems, but you know what I mean, all different.
Yes. Operational planning systems. Okay, I think that's all of the questions for now. I've just got one final one for you, Jason. You talked about PDFs of SFG20 back in the day when you were an electrical engineer. Why is it important to access the latest version of the standard and not work to out-of-date paper printouts?
Jason Instrell: Okay, so I'll take an example of what we're doing at the moment. So the technical team are in what's called a blackout at the moment. So for us, we are implementing at the moment quite a few changes over our schedules. So we've had an amendment, which is called Amendment 3 of BS7671, the wiring regulations.
So to implement that, we are having to black out to put that into all the schedules. So if you were not accessing our system and you were not using it the correct way, and you were using it with PDFs, you wouldn't be privy to those changes. So when I used a PDF in the past, it was five years out of date, you know. So and if you're not, and if you're not looking at the hyperlinks and you're using that, we could have updated—all my word.
I think in the last year we've updated thousands. There's been, I mean, the Building Safety Act implemented changes. So if you are using PDFs pre-that, obviously it's going to be out of date, so it's crucial guys that you do use the software. You use the facility that SFG20 offers so that you can keep up to date with that and the technical bulletins that we also put out there.
Lisa Hamilton: Mm-hmm. Because the standard changes on a monthly basis, doesn't it? Not saying that every schedule will be updated on a monthly basis, but there are significant numbers of updates that are issued, published every single month. Yes. So what risks are people putting themselves at if they're working to out-of-date SFG20 guidance?
Jason Instrell: Well, we're talking about safety. We're talking about safety here. So if there have been changes or there's been additional tasks, which there were with the implementation of the Building Safety Act, there were additional tasks and additional checks that were brought in there. So if you're not carrying those out, say for example, there's a new regulation that states you need to do this additional weekly check on your asset because it's a safety issue and you are still doing a six-month check because you've not looked at that update, then your building and your asset will be at risk.
Whether that's a red task, whether it's an amber task, you know you are at risk there, and SFG20 is here to keep you compliant. We do all the legwork for you, basically in the background so that you guys stay compliant. And we work hard at doing that, at capturing it. And we want to make sure you are, you are safe in your buildings, not at risk.
So to do that, you've got to use the software and you've got to follow the bulletins that we put out there and try to avoid paper copies if you can, and stick with the digital that we do, because you can guarantee then that your assets are safe. You are working to current legislation because that's what we do. And you're maintaining correctly and that's key really.
Lisa Hamilton: If something, you know, perish the thought, if something were to go wrong, that you can evidence that you've done everything that you could and you've been following compliant guidance, which you know, protects you or puts you in the best possible light, doesn't it? If something were to happen?
Jason Instrell: Well, it is. Because this is the golden thread and the key with SFG20 is it's digitalisation. So this is your digitalisation of data. And I just want to quickly say, Lisa, that the golden thread's not a new thing. You know, we've always, the data's always had to be there. You know, I, I probably show my age now, but I used to have to issue O&M manuals, hard copies with a USB or with a CD.
Granted that may have disappeared. What the Building Safety Act is saying is we want this digitalisation now, and what SFG20 does is it gives you that because you can show that you have been carrying out the task, you can show that digitalisation of information. So you know that's, that's why it's key, really.