Can you hear me?

Since the election of the coalition government in 2010, the school construction programme has experienced a major change of direction, resulting in general uncertainty regarding the future of acoustic design and legislation for schools, and there is a risk of the importance of acoustic design in schools being undermined.

Statutory Requirements
In 2008, Partnership for Schools (PfS) and the Department for Communities and Local Government (DCLG) set in motion a process to update Building Bulletin 93, the 2003 guidance document produced by the Department for Children Schools and Families (DCSF) to provide the acoustic performance standards for normal compliance with Requirement E4 of the Building Regulations, enforced by Building Control. The bulletin needed updating after eight years to take account of new trends in learning styles and inclusion of vulnerable listeners, who are particularly adversely affected by poor acoustics (high noise levels and long reverberation times), in mainstream schools.

A draft revision of the BB93 update was presented to DCLG and PfS in March 2009, however the document was never published.  Later on in 2009 the then-minister for schools & learners, Vernon Coaker, published a ministerial statement confirming the government’s commitment to acoustics in schools. However the status of this statement under the new government is unclear.

In addition, Section 1.2.1 of BB93 allows alternative acoustic standards to be proposed by the acoustics consultant in specific cases. As the progression of school design gets further and further away from the scope of BB93, more alternative performance standards are applied to school buildings. In some cases this clause is being mis-used to allow acoustic specifications which are significantly below those in BB93 for commercial reasons, without adequate technical justification. The wording on this section is generally clear but it should be emphasised that this is not a licence for derogation, which risks schools being approved by building control bodies while being acoustically inadequate. Well-publicised examples, such as the infamous ‘open plan’ schools in the first wave of academies, have shown how easily the best of intentions can result in something which is, acoustically, not fit for purpose.

At the end of 2010, DCLG released a document called Future changes to the Building Regulations – next steps, which indicates that DCLG are looking to explore the scope for streamlining and deregulation of this requirement by working with the Department for Education. The Institute of Acoustics (IoA) and Association of Noise Consultants (ANC) have expressed serious concerns that section E4 might be withdrawn or watered down without an alternative statutory mechanism for maintaining acoustics standards that carry at least as much weight.

The impact of poor Acoustics
There is a substantial body of scientific evidence that poor acoustics are linked with impairment of cognitive performance amongst children. Good acoustic design is essential for good pupil/teacher communication. Research in many countries over the past 40 years has shown that high noise levels and poor acoustics (i.e. long reverberation times) cause health problems for teachers and reduce pupils’ academic performance. Children with special needs and those whose first language is not English are particularly vulnerable to the effects of noise and poor acoustics. Put simply, if pupils are unable to hear what they are being taught they are less likely to be able to learn. Likewise if teachers have to regularly raise their voices to be heard, then they risk vocal damage and/or increased stress. For instance, last November a teacher who damaged her voice due to having to teach in poor acoustic conditions was awarded £150,000 compensation.

As a result of a study commissioned by PfS, there is also evidence that many new school buildings (including high profile BSF and academy designs) are still failing to achieve suitable acoustic performance standards (particularly when commissioning testing has not been requested by the client), with teachers and students struggling to cope in the new spaces. Acoustic pre-completion testing to verify that the proposed acoustic design standards are achieved is rarely undertaken except as a contractual requirement or to achieve BREEAM credits. As a result, poor sitework can risk negating good acoustic design and performance.

A further problem is that the major drive towards refurbishment and re-use of old buildings is not adequately covered in BB93 so there is an unfortunate risk of suitable acoustic performance standards not being applied to refurbished buildings. 

Learn from past mistakes
The new Academies Bill and the proposal for free schools open the door for a repeat of the mistakes made by previous governments. The fundamental principles of building physics and psychology do not change however: if teachers have to strain their voices and children cannot understand what is being said, then these buildings are not fit for purpose as teaching environments. Suitable acoustic conditions are essential for teaching and learning, not a luxury.

In response to this situation, the Institute of Acoustics (IoA) has written a letter to Andrew Stunell, the minister responsible for the building regulations, expressing the concern held by our profession on the effects of the proposed changes, together with the implications for future generations of school children and students, and teacher’s health. A similar letter has also been sent to the Department of Education. The IoA’s line is that there is a need for statutory control but we remain open about what form that might take. The IoA’s campaign is supported by the Association of Noise Consultants, the Noise Abatement Society and the National Deaf Children’s Society.

In their reply, DCLG have advised that a public consultation would take place if any changes to the regulations were proposed. Representatives of the Institute have also had discussions with Partnerships for Schools, the Department for Education and MPs to emphasise the necessity of good acoustic design for all schools, and attempt to get the matter discussed in Parliament.

Future guidance
The ANC and IoA are also currently working to formulate suitable acoustic guidance to be issued if the revised Building Bulletin covering school acoustics is not published by Government. The School Premises Regulations 1999 contains a similar requirement to Regulation E4, although this is not currently enforced in practice by any particular control body. There are a number of possibilities and options for using BB93 (or a suitable replacement document) to strengthen the School Premises Regulations, although it is generally accepted that mandatory controls are required to maintain minimum acoustic design standards (the industry having witnessed an improvement in standards as a result of mandatory controls, including pre-completion acoustic testing, in recent years). It is crucial that a carefully thought-out alternative to Requirement E4 is necessary to maintain a statutory control on acoustic design standards in schools, to avoid school buildings being built that are unsuitable for speaking, listening and learning.