Andy Slaughter
MP for Hammersmith and Chiswick · Labour · United Kingdom
“I welcome the Bill, and thank the Government for introducing it and bringing it back to the House before the summer recess. It is the result of years of committed campaigning, led by the families of the victims and survivors of Hillsborough.”
“I know that case means a huge amount to the hon. Lady as a constituency MP, and I thank her for all the work she does on the Justice Committee. I think we have only begun to scratch the surface. This Bill will be a transforming piece of legislation. I will make one final comment.”
“This would be a new, independent public body that collated, analysed and followed up on the conclusions and recommendations made after official investigations into deaths and state failings, in order to improve oversight and implementation of them.”
“I think I have taken enough time, but I thank the Member for that intervention. This afternoon, the Justice Committee signed off a new major report on legal aid, which will be published on Friday. Those who are interested can read more there.”
“In the time that I have, I will focus my remarks on clauses 1 to 16, which create a new appeals body for immigration and asylum cases known as the independent immigration appeals authority.”
“From that visit, our diagnosis was that these are operational problems. There are two key questions for the House: will the IIAA fix the problems with the current system, and will it be truly independent from the Home Office?”
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“It is a great pleasure to follow the hon. Member for Southend West (Sir David Amess) and my hon. Friend the Member for Croydon Central (Sarah Jones), who have set out amendments to the Bill that are reasonable, proportionate and non-partisan, and I cannot see any reason why the Government should not support them. I do not intend to repeat the arguments they have made so cogently; I will just add a few comments of my own. As the hon. Member for Southend West said, he has chaired or been part of the all-party parliamentary group on fire safety and rescue for more than 20 years. I cannot claim to have been a member for that length of time, but I have learnt a huge amount in the time that I have been. It is one of the most effective groups in Parliament. The all-party parliamentary group on online and home electrical safety, which my hon.”
“It rather feels that we have been overtaken by events because we now have the draft Building Safety Bill. That is a much more detailed piece of work, but I already have some criticisms of it—I will not bore the House with those tonight—and I look forward to more discussions on that as we go forward. I know that the Minister takes these matters seriously, but I do not feel that the Government are addressing them with the rigour or the detail that they need to be. Let us make a start on that today by adopting the amendments that have been put forward.”
“The Government should be better at directing those responsible and, where necessary, providing the means for those responsible to remedy the serious risks that are apparent. That is the problem with the Bill, which the amendments go some way towards clarifying. Whether we are looking at the source, the construction or the modification, the consequences can be the most serious. They can be matters of life, of the destruction of people’s homes, or of people living daily in fear of the risks that apply to their homes. I cannot think of anything less reasonable than that, frankly, so more than three years on from Grenfell, will the Minister look seriously at what is proposed and either adopt the amendments or, at the very least, say that the Government will bring forward their own legislation soon?”
“We are looking at height, but we are also looking at the type of buildings, the type of users of buildings and the type of cladding that is used on buildings. They could be hospitals, hotels, care homes or schools; they could be low-rise as well as high-rise buildings. They all have risks attached to them. It sometimes feels like getting blood out of a stone to get the Government to widen their ambit and look beyond the very narrow classifications they have already dealt with in terms of ACM cladding, possibly high-pressure laminate cladding and possibly buildings down to 11 metres. The Government are very good at giving advice to others, and we all know the problems that that has caused with the sale and remortgage of properties and the necessity for inspections when the professional staff are not there to deal with these matters.”
“Had it not occurred in the middle of the afternoon on a summer’s day, the consequences of that would have been dire. As it happened, there were no serious injuries, but the trauma of being involved in a fire of that nature, I do not think can be imagined. If I were the Minister, this would give me sleepless nights every night until these matters are resolved. What I fear is that the Government are continuing to take what I can politely describe as an incremental approach here. Yes, these are complicated matters and more issues come to light—every time an investigation takes place, we find more problems with more types of building—but that is the world we live in, and it does not excuse the Government from responsibility.”
“Those have been found appropriate for the private rented sector, and I wonder why they are not appropriate for high-rise buildings where we know, as a consequence of fires such as Lakanal, Grenfell and Shepherd’s Court, that people are particularly at risk. Let me say a brief word about that because it is in my constituency. It is just over four years since the very serious fire at Shepherd’s Court. A tumble dryer, which not just should have been recalled and had not been recalled, but was going to be repaired and was awaiting repair, was being used according to the manufacturer’s instructions—wrong instructions—and therefore did catch fire, destroyed somebody’s home, spread to several other flats and caused the evacuation of an 18-storey block.”
“It is rather a truism to say that, if we can control that source, we are going to get a lot fewer fires, whether or not they spread. There are many issues that are being pursued here. Tomorrow, there is a ten-minute rule Bill from my hon. Friend the Member for Makerfield (Yvonne Fovargue) on the registration of electrical appliances, so that where there is a need for recall, those matters can be in hand. What we are doing today is not comprehensive, but the two measures that have been proposed in the hon. Gentleman’s amendment and new schedule are entirely sensible. Yes, they are quite onerous because what we are looking for is both a register of white goods and regular checks.”
“New clauses 2 to 5—I am not going to go through those in detail—are, as I say, sensible and proportionate measures, which are designed to ensure that this legislation the Government are properly bringing forward works more effectively. I wait with bated breath to hear what arguments the Minister can advance for not adopting those. Let me come on to the amendment standing in the name of the hon. Member for Southend West, because I think that that is an important amendment. I am glad that it was found to be in scope and is being taken because he is absolutely right to say that, whereas a great deal of the focus has properly gone on construction and modification, particularly in relation to external cladding, insulation and so forth, it is also important that we look at the source of fires.”
“My hon. Friend makes a very good point. It is my experience from dealing with blocks in my constituency, and I am sure it is many other Members’ experience, that nobody wants ownership of this, nobody wants to pick up the tab and nobody wants to take responsibility—whether it is those who designed the building, those who built the buildings, those who manage the buildings or those who modified the buildings in ways that were not conceived. Somebody has to do that, and if they will not do that, it is Government’s responsibility to ensure that they do, and I do not think this Bill goes far enough in doing that.”
“In Grenfell Tower, there will have been secure tenants, leaseholders and private tenants. Why should regulations apply to some of those groups and not others just on the basis of tenure?”
“The Government are really missing the point on this. The thing about events, meetings, conferences, exhibitions and wedding receptions is that they are organised and regulated, and yet they are more constrained at the moment than pubs and restaurants. Rather than talk about pilots and permitted venues that are not defined in the guidance, will the Government look at a faster and fuller opening of the sector before October?”
“Does my hon. Friend agree that the Government’s response has been entirely inadequate? Not only are not all tall buildings with flammable cladding identified, but neither are medium-rise buildings above 11 metres high and those with valuable occupants such as hospitals and care homes.”
“There are 24 prisoners on death row in Bahrain, of whom 10 are in imminent danger of execution. Those 10 include Zuhair Abdullah and Husain Rashid, whose cases I raised with the Foreign Secretary when he gave his statement on human rights abusers on Monday. His reply that the designation of abusers will be blind to ulterior considerations was somewhat undermined by the decision the next day by the Secretary of State for International Trade to resume the arms trade with Saudi Arabia. Will the Minister look again at the responsibility of individuals in the Bahraini regime, and in particular Prince Nasser bin Hamad, the son of the King, who is alleged to have an involvement in torture going back to the Arab spring and whose diplomatic immunity was removed by the High Court here?”
“While the Chancellor has made welcome announcements on the hospitality and cultural sectors, he has said nothing in support of the events industry and those who work in it, despite the Prime Minister promising a timetable for reopening last week. From wedding receptions and conferences to world-famous exhibition centres, such as Olympia in my constituency, events make a £70 billion contribution to the economy. When will safe, organised events with more than 30 people attending be permitted, as they are in most other countries?”
“I congratulate my hon. Friend on securing the debate. Does she agree that black, Asian and minority ethnic children are particularly affected? Almost 60% of them benefit from the scheme at the moment. That is particularly important given the effect on BAME communities of the covid-19 pandemic generally.”
“Bahrain, the United Arab Emirates and Saudi are all classed as close trading and political allies of the UK. What they also have in common is locking up political prisoners, torture and execution without due process. Zuhair Abdullah and Husain Rashid are in imminent danger of execution in Bahrain, having exhausted legal remedies. Will the Foreign Secretary be sure to sanction human rights abusers in so-called friendly countries, as well as those that are not so friendly?”
“Q I had a couple of questions, mainly for Mr Daly. Could I just clarify something from your opening statement? Is it your view that this Bill does not add in new types of premises or new responsibilities but is simply clarifying what should already be happening? Dan Daly: That is certainly my understanding.”
“I do not think that creeps any further forward what buildings are in scope, but it makes very clear those areas to which it does apply.”
“Q Therefore, do you think the attempt in clause 1 to specifically include building structure, external walls and common parts goes far enough? We will be debating amendments this afternoon, some of which have been supported by the fire brigade, which obviously you have had a distinguished career with. One is to say that when defining “common parts”, it would be better to include all parts of a building except private dwellings. Do you think that would be a helpful amendment? Dan Daly: Absolutely. The concerns we have and the clarifications we are seeking are shared in the submission from the National Fire Chiefs Council. There is no intent to apply this legislation inadvertently to buildings inappropriately, but we should be very clear that parts that are used in common between properties would be subject to the order.”
“Q So if we are engaged in a clarification exercise, it would be better that we do so properly. Because there are different definitions of what “common parts” means, we should ensure that they are defined as every part of a building that is not within the individual tenant or leaseholder’s domain. Dan Daly: Yes, absolutely. As I say, we are working very well with colleagues on those clarifications and on commitments to getting those definitions in. Our reason for repeating to you our concerns about those clarifications and commitments is not to suggest that work is not going forward; it is partly to place it on record that we think those issues are hugely important to the success of this Bill and its application.”
“I was in my old role with the London Fire Brigade at the time, and we sent a letter to registered landlords to advise them to look at what was on the outside of their buildings. We debated for some time whether that letter could go further and suggest enforcement action, but it eventually became an advice note because we were unable to bottom out clearly what that legal advice should be. I think the clarifications we are seeking will make it much clearer that external wall systems are covered.”
“Q It has been said that the purpose of this Bill is specifically directed against those parts of the structure that are liable to be dangerous, obviously with a view towards cladding. That itself covers a multitude of sins: different types of cladding, compositing—that is, a mixture of materials—the way in which the cladding is applied, and indeed the way it is modified: whether there are breaches and offences in that way. Do you agree that that is the purpose, and do you think that the Bill will enable that to happen? Dan Daly: Yes. This issue, particularly if we talk about external wall systems—which encompasses insulation and fixing everything, as you have suggested—has been debated for some time. In August 2016, I attended an incident in your constituency that you will be very familiar with.”
“Q So you think enforcement will follow from this, and responsibilities will lie squarely with the owner or manager of the building. Dan Daly: Absolutely. It is for the property owner.”
“We have spoken to the insurance world about that as a trade body—our people have contacted them—and the people who want that level of insurance can get it. You are dealing with a broad spectrum of risk, and we need to get the elephant down to bitesize chunks.”
“We are working with the Government, hopefully through a new task-and-finish group, to try to move that forward in a positive way. There has to be due diligence from the responsible person to make sure this is happening, but it is worth remembering that a lot of these people are in relatively low-risk low-rise buildings, which are now within the scope. We need a process to manage that that is very open and transparent, so that tenants know they are safe. We can work on that together. The EWS1 form has created its own problem. It was intended originally for high rises, but it is now being used to free up the whole mortgage market. The problem that we see with that is that you get unqualified assessors signing off forms just so that the market can move. Risk assessors have found it difficult to get indemnity cover.”
“The clarity that we are seeking is around definitions, for some of the reasons that have been touched on. External walls are a team event, as I have made clear. Therefore, it is about scaling part of this process—how many people are available to undertake the sort of area of cover that we are dealing with. The impact assessment suggests that it is a very large number of properties, rather than just the over 18 metres. On the example of over 18 metres, where the Government has funded the schemes of remediation, you can see how progress can be made. Equally, even with funds, dedication and teams, it is a relatively slow process. We are three years on and the National Audit Office is saying we are getting there. The issue is how we manage it. As Mr Carpenter said, it is about managing the process through prioritisation of the risk.”
“People should be able to buy and sell their homes regardless of whether the walls have a different material on them. It is right that we all work towards the end goal of making sure all those buildings are safe. We can look at the numbers for how much money it will cost to resolve some of these buildings, but we must deal with it by risk. It has to be about safety risk, where we have concerns with lower-rise buildings that might be able to move if we can solve the cladding issue by just issuing a certificate. We need to keep focusing on safety risk. We have to continue working with and lobbying mortgage lenders, with the Government, to make sure those measures do not hold up the lending process and stop people moving. Dennis Davis: As a first answer, we are very much aware of these issues, and I think that comes out in our evidence.”
“The G15, as a wider group of housing providers in London, has over 1,100 buildings, and the estimated cost could be as high as £6.8 billion for those buildings. I appreciate that there are extreme challenges with buildings. On the point about sales, I think it is really important that the insurance industry, which seemed to be holding up the EWS1 forms being completed, works with mortgage lenders to try to open the market again, to allow at least one of those problems to be resolved. If the building insurance covered the cladding, would mortgage lenders be happier to lend, on the basis that their money is not at risk, because it is covered by the wider building insurance? The situation of leaseholder and mortgage prisoners, as they have been referred to in the press, is extremely unfortunate, and I do not think that that is right at all.”
“For example, a social landlord—and social landlords are much better than private landlords, in my experience—that is not L&Q is telling occupants of a particular building in my constituency that it might take four years for this to be done. That is problematic in itself, and it has the additional problem that the EWS1 form and the process to be gone through effectively stops any sale or movement during that time. Are you aware of those problems, and how can you see them being resolved? James Carpenter: L&Q currently has 191 buildings that are over 18 metres, and we estimate at the moment that those buildings will cost in excess of £450 million to resolve, which may take up to 10 years.”
“Q I think there is quite a lot of support for this Bill. The issue is whether what it is trying to achieve is clear enough and how it will be enforced. It is already clear that, where landlords are trying to do remedial work, that is highly problematic, first because it is confusing what types of building it applies to—what sort of height and what sort of materials—and secondly because there is prioritisation. For example, a building that is mainly brick but has some detailing made from aluminium composite material or high-pressure laminate will have a much lower priority than one that has complete cladding. Also, there just are not the people there to carry out the enforcement.”
“Q I am persuaded that you understand what the problem is, but who will solve it, given that there are so many interests involved? It is unacceptable to expect people to wait 10 years before they can sell their flat, apart from anything else. Who will resolve it? Will it be a joint industry initiative? Does it need Government intervention? Who are you looking at to do this? You have explained the problem, which we are all familiar with, but I do not see the solution there.”
“We now have Government bodies looking at reviewing the evacuation policy and saying that it might take two or three years. Firefighters were apparently supposed to decide on new strategies on the night, even though the people reviewing the policy have told us that it will take them two years or more to reach such a conclusion. I come back to my point about a joined-up approach. We should have bodies in the British fire service that take account of the views of all professionals, take account of research and develop answers to these questions as we go along. We should be horizon-scanning. There had been fires in clad buildings elsewhere in the world. It is staggering that no one in leadership positions in the British fire service or at Government level was monitoring those and seeing what should happen to alter policy in Britain.”
“All those things need to be built into a proper fire safety regime. I do not think the Bill addresses the question of evacuation. That is obviously a huge concern to people living in high-rise residential buildings; it is also a huge concern to firefighters, who have been trained for decades in ways to fight fires in high-rise residential buildings that are based on the construction and design of those buildings. Over the past 20 years or so, those buildings have been modified in a way that was never intended, which has altered the whole structure and fire behaviour in those buildings. In our view, there is no simple answer to the question of evacuation. Again, we raised the question of a review of evacuation at the close of stage 1 of the Grenfell Tower inquiry.”
“Matt Wrack: I see the Bill as a clarifying Bill, as has been suggested. On that level, we welcome it, with some of the amendments in particular. You highlight an important point—much of the national focus is on cladding. There is clearly a national scandal about flammable cladding being put on to buildings, but we are aware from Grenfell and other fires that there are many other failings in fire safety in buildings, particularly with the risk of the breakdown of compartmentation. Cladding is clearly one mechanism by which that happened at Grenfell, but issues around other materials used in renovations and modifications of buildings are also relevant. If people have fire resistant walls and drill holes through them, that will clearly alter the fire resistance of the compartment.”
“Adrian Dobson: There is quite a range of questions there. Essentially, in my view, the Bill is just clarifying and pointing to some key facts, as it is not fundamentally changing the nature of the approach. I could not agree more that, although it is useful to highlight the issue of external wall construction and cladding, there are lots of other known issues in relation to fire safety. For example, the Scottish schools report talks a lot about fire compartmentation and lack of proper fire barriers. You have pointed out the issue around means of escape and evacuation strategies. To return to my earlier point, I see this as only part of the jigsaw. What we desperately need is clarification of the building regulations themselves and a stronger enforcement or competency regime around that, so that the two work together.”
“Q Good afternoon to you both. We have heard that this Bill is a clarifying Bill rather than one that introduces new powers. Do you agree that that is its purpose, and do you think it achieves that? The specific point that I would like you both to address is that it appears, as there is a specific mention of “external walls” in clause 1, that the Bill is directed at what we have already seen coming out of the Grenfell inquiry in relation to external cladding and cladding systems. But lots more issues have emerged from that, such as the way that buildings are constructed or modified, means of escape, alarm systems and the processes for evacuation in that way. Do you think that they are also adequately covered in the Bill or do we need other legislation? Do you think we have the means to carry out all those matters?”
“The lesson of Grenfell is that the voices of tenants were ignored. The voices of tenants are often ignored in relation to building and modifications to the places where they live. The vast majority of tenants are respectable, sensible people and their views should be heard. They were not heard at Grenfell. I think they, us and firefighters would have greater respect for a risk-based approach if we could have the confidence in such a risk-based approach. Unfortunately, experience shows that risk-based approaches are often driven by commercial and financial interests, and that is why people have scepticism about them.”
“In relation to combustible external wall materials on high-rise residential buildings, we have at the moment a fairly prescriptive piece of legislation that makes best practice pretty clear. As you say, however, there is a certain element of lobbying to say that we need a more flexible approach, so you can already see attempts to row back on that. In terms of what has actually been regulated, fairly good practice is in place. We know there is quite a lot of good retrofitting work happening on buildings above 18 metres, even if it is very slow, but we do not really have much idea in terms of combustible materials below 18 metres. Matt Wrack: I would like to comment on the lobbying that was mentioned by a building developer recently and in some earlier comments in your session. One of the voices we are keen to hear are those of tenants.”
“Q I think we understand from what you have said that there is a lot to do, and that there are limited resources at the moment. Where work has been going on, do you think the best practice is being followed? Is that being done in both the maintenance and the construction of buildings? We had a story in the press last week about Berkeley Homes rowing back on whether all types of cladding, including ACM cladding, should be removed from buildings. Do you think this is being taken seriously? When buildings are being given planning permission, being constructed or being modified, are best practice and best standards being adhered to? Adrian Dobson: I think I would answer broadly yes, in those aspects that have now effectively been covered by prescriptive regulations.”
“The evidence was excellent; it would have been good to have time to digest it and perhaps propose amendments on the basis of it. We now have three hours for debate—I will be brief so as not to eat into that time—and we also have a Committee that is smaller than was originally envisaged. That is partly to do with the constraints of the room and social distancing, but it is an unhelpful precedent. I do not know whether it is a matter for the Chair or for the Government to take away, but I wanted to put on record my concerns. The matter before us needs to be explored in depth; it has huge complexities and different streams, even within the limits of the Bill, which is one of several. I hope that the authorities and the Government will take away the message that scrutiny should not in any way be constrained.”
“On a point of order, Sir Gary. I apologise for rising so early. I do not want to start on a contentious or sour note in what I am sure will be a consensual Committee, but there was some consternation about the way in which the Committee was timetabled. I make no criticism of the necessary rigours enforced on us by social distancing; the staff have done an excellent job in that respect. The issue of fire safety in tall buildings, particularly in west London, is very important. It is one of the very few issues that keep me awake at night. We are dealing with the whole the Bill, which, as the evidence session this morning showed, ramifies in many ways, in one day. We had the evidence session this morning, and we are dealing with line-by-line consideration of the whole Bill, albeit a short Bill, this afternoon.”
“I beg to move amendment 1, in clause 1, page 1, line 6, leave out lines 7 to 14 and insert— “(1A) Where a building contains two or more sets of domestic premises, the things to which this order applies include— (a) the building’s structure and external walls and floors, and any common parts; (b) all doors between the domestic premises and common parts (so far as not falling within sub-paragraph (a)). (1B) The reference to external walls and floors includes— (a) doors, windows or penetrations in those walls and floors, and” This amendment would apply the Fire Safety Bill specifically to penetrations that pass from a dwelling, through a fire-rated wall or floor into a common space.”
“I will wait to see what the Minister says in response; he might want to break the habit of a lifetime and say that we can allow an Opposition amendment to get the Bill Committee off to a flying start.”
“It was only because of the excellent action by one concerned resident—this was the opinion of the emergency services—that the matter did not end up in disaster. What happened late at night in January was that the gas did not pass through doors or windows but up through the building, potentially causing great stress. My point is that, with fire, smoke and other noxious fumes passing through a building, it is complacent to say that simply ensuring that fire doors work and that windows are properly sealed and do not have combustible material around them means that a building is entirely safe and the fire will not spread internally. I hope the Government will accept my amendment. It is a relatively technical addition, which improves the Bill rather than changes it materially.”
“The gas had effectively filled the whole block, from the ground floor reception up to at least the eighth or ninth floors of the block. This matter ramifies endlessly. Why should an unsafe gas appliance be allowed in a block anyway? Modern gas appliances have failsafe mechanisms—if the gas is left on, they will shut off after a while—but unfortunately the reality is that some people, particularly poorer people perhaps, will have very old gas appliances that do not work in that way, and therefore the gas, after being turned on, will fill the whole flat. In this case, the occupant, who had obviously made a genuine mistake, needed oxygen. Many people had either opened their windows or were confused about what was happening.”
“In January this year, a resident of a block of flats with over 20 storeys was returning home late at night when she noticed a strong smell of gas. She checked her flat but could not find anything that was causing the smell. Fortunately, there was a member of staff, a concierge, on site even at that late time. They investigated, and the National Grid was called out, but it could not find anything. Neighbours’ doors were knocked on, and the emergency services were called out. By this time, it was the early hours of the morning and neighbours on several floors were being woken up. Eventually, the source of the gas leak was found four floors below. An elderly resident—over 80, I think—with an elderly gas stove had turned on the gas and left it on.”
“The danger is that anything of that kind will allow the spread of fire—but not only fire, as I will come on to explain in a moment—throughout a building very quickly, particularly if there are pipes and ducts. If the opportunity arises for fire to spread, it can go through them very quickly. As I say, it is not just fire, but smoke and other gases. A major factor at Grenfell was the spread of smoke through the building. That can make escape difficult and, particularly if it is created by the burning of toxic materials, can create a toxic atmosphere, which has an effect on the respiratory system of those trying to escape the fire. To explain my point, I will provide an example from my constituency. It did not end in disaster, I am pleased to say, but it easily could have done.”
“That could be through a window that is open or through a door that is insecure, but it could be through any other means of entry. There are other ways for fire to spread that are perhaps more serious than doors and windows. That is why I used the word “penetrations”. They could be ducting, pipework or openings that have been created for good or bad purposes: it could be shoddy workmanship, but equally it could be something necessary to do with the supply of services through the building. One other point on amending clause 1 was to add the words “external walls and floors”. It is clear why clause 1 mentions doors and windows—generally we have doors and windows; I understand that point—but other openings or apertures created in a building may well be through floors.”
“My amendment addresses a specific point by dealing with opportunities for fire to penetrate into a building other than through doors and windows. Doors and windows are a major way in which fire can enter a dwelling. If a window is open or a fire door is not—as my hon. Friend the Member for Croydon Central explained this morning—sufficient, sufficiently well fitted or has other defects that do not maintain a 30 or 60-minute barrier, there is that opportunity. It is perhaps stating the obvious to say that the reason that flammable cladding is such a danger is that it allows fire to spread across the face of the building in a very short space of time, as we saw at Grenfell. That in itself is not what is causing the problem; it is the ingress of that fire into the building itself.”
“The money, time and resources the Government have spent so far—many of us believe they have not gone far enough—have gone on looking at aluminium composite material cladding and then perhaps at high pressure laminate and other types of cladding. No doubt, as we consider the Bill, there will be some focus on that. My amendment, and that of my hon. Friend the Member for Croydon Central, go slightly beyond that. As Matt Wrack, the general secretary of the Fire Brigades Union, pointed out this morning, Grenfell has exposed not only that there are issues with cladding, but that there are fire safety issues in the construction, management and operation of tall buildings, in particular, that go far beyond that.”