Using TLX Batsafe™
The NBCRMs steering group have been working to support the SNCO’s as the regulatory authorities to publish position statements on their respective websites on the issue of NBCRMs that have passed the snagging propensity test.
TLX Batsafe™ has passed the Snagging Propensity test and can be submitted for licence applications to Natural England (NE) and NatureScot (NS) please visit their websites for their position statements in the links below:
Position statement for Natural Resources Wales< (NRW) is to follow but advice is expected to be very similar, however until NRW’s position has been formally changed, the use of NBCRM’s will not be licenced. For further information please contact NRW through the details below:
This guidance is supported by a FAQ document which is outlined below and there will be a flowchart to follow shortly to help guide industry stakeholders through this process, to protect bats and avoid offences being committed.
Please note, although BCT facilitate the steering group and are currently hosting this guidance we are not involved in assessing or approving NBCRMs, this is a technical and regulatory issue and therefore the appropriate guidance should be sought through the contact details above for SNCOs and below for technical information.
FAQ’s
Q: Has TLX Batsafe™ been agreed for use by Natural England, Natural Resources Wales and NatureScot? Batsafe has passed the required snagging test (E., Essah et al. 2020) for NBCRMs and has received the certification so that it can be assessed in a licence application submitted to the SNCO’s. Natural Resources Wales (NRW) has not formally changed position however advice is expected to be very similar and is currently going through the formal review process, at this time NRW will not licence the use of NBCRMs.
Q: What industry tests do NBCRMs such as TLX ‘Batsafe™’ have to pass? It has passed all UK Building Regulations requirements. NBCRM’s are covered in Part L. (this section is concerned with the energy performance of new and existing buildings). It is not a public document. Please refer to your architect or Local Authority Building Control or call TLX Insulation hotline on 01204 674 730 for more information.
Q: Has the steering group considered other tests for NBCRMs in relation to their impacts on bats? The steering group will continue to monitor and consider other tests as appropriate. It is likely there will be a requirement for a longer monitoring period as is standard for all novel products on to the market.
Q: What is BCT’s role in this work? BCT have brought together Natural England, NatureScot, Natural Resources Wales, senior academics, bat ecologists and industry experts in roofing materials to form the steering group that has set up the test protocols for roofing underlays intended for use where bats are present. BCT facilitate this work but are not involved in a regulatory capacity (this is the SNCOs role) or technical capacity (this is the materials experts role) to give advice. Batsafe™ has passed the required snagging test for NBCRMs that has been endorsed by the steering group and has received the certification so that it can be assessed in a licence application submitted to the SNCO’s.
Q: Does passing the snagging propensity test mean a NBCRM can be used in a bat roost? Any roofing underlay that has passed the required snagging test (E., Essah et al 2020) for NBCRMs and has received the certification should be included within licence applications connected to locations where bats are present. However, this is considered to be a gateway requirement and the relevant SNCO will then assess the mitigation licence application as a whole along with the suitability of materials proposed for usage.
Q: Does 1F roofing felt need a snagging test? You do not need to provide a certificate for licence applications involving bitumen 1F felt that has a non-woven, short fibre construction.
Q: Is TLX Batsafe™ breathable? Yes. TLX Batsafe™ is a breather membrane that allows water vapour in the house to escape through the membrane, rather than through openings in the ridge and the eaves.
Q: How is TLX BatSafe™ used? TLX Batsafe™ is installed in the same way you would traditionally install a breathable membrane. Further details of installation can be found on the TLX website www.tlxinsulation.co.uk
Q: Can TLX Batsafe™ be used with insulation? Yes. Further details can be found on the TLX website www.tlxinsulation.co.uk