Seven recommendations guide the direction of travel. Our destination is a safer future!
The Independent Review of Building Regulations and Fire Safety has found that the current regulatory system for ensuring fire safety in high-rise and complex buildings is not fit for purpose. This applies throughout the life cycle of a building, both during construction and occupation, and is a problem connected both to the culture of the construction industry and the effectiveness of the regulators.
1) Interim recommendation to government
The first interim recommendation is for government to consider how the suite of Approved Documents could be structured and ordered to provide a more streamlined, holistic view while retaining the right level of relevant technical detail, with input from the Building Regulations Advisory Committee. They have specifically been asked to consider any presentational changes that will improve the clarity of Approved Document B.
It would be beneficial to adopt a more joined up approach to ensure the 17 approved documents do not contradict each others objectives.
We agree that Approved Document B does not have the narrative structure of a novel. It’s not a document one can read from beginning to end, there’s no climax or twist in the middle. It’s not “Fifty shades of green”. Approved Document B is a document that you learn to navigate by applying it on real projects. It prescribes standard solutions to standard problems. Modern design and the way we now use our living and work spaces presents new challenges and Approved Document B has not kept up with that change.
We agree it could do with a review and welcome the prospect of it, however it has also been said that the guidance is written by experts for experts. We would temper the thrust towards ‘dot-to-dot’ fire safety or simple ‘Janet and John’ guidance and suggest that fire safety design, engineering and management is complex and as our built environment and the challenges it faces becomes more complex, so will fire safety.
2) Interim recommendation to the professional and accreditation bodies
There is a need to be certain that those working on the design, construction, inspection and maintenance of complex and high-risk buildings are suitably qualified. The professional and accreditation bodies have an opportunity to demonstrate that they are capable of establishing a robust, comprehensive and coherent system covering all disciplines for work on such buildings. If they are able to come together and develop a joined up system covering all levels of qualification in relevant disciplines, this will provide the framework for regulation to mandate the use of suitable, qualified professionals who can demonstrate that their skills are up to date.
We wholeheartedly agree that professional and academic qualifications are important and that competency is imperative where life safety is concerned. Having a regulatory model that holds all built environment professionals to a globally recognised set of standards is vital to inspire confidence among clients and the public. The professions must maintain the public trust. Rigorous entry requirements are not enough. Codes of conduct must be more consistently enforced. We would support the idea of a mandate ensuring all fire reports are peer reviewed and signed off by a Chartered professional specialising in fire, with appropriate professional indemnity to cover the criminal, contractual and tort liabilities that go hand in hand with this role. We would support a move to encourage the current third party certification schemes and registers for fire risk assessors to come together to form a single scheme type with a number of providers, and companies to be listed on a single national fire risk assessor register.
3) Interim recommendation on the consultation process
Consultation with the fire and rescue services is required on plans for buildings that are covered by the Fire Safety Order, but does not work as intended. Consultation by building control bodies and by those commissioning or designing buildings should take place early in the process and fire and rescue service advice should be fully taken into account. The aim should be to secure their input and support at the earliest stage possible so that fire safety can be fully designed in.
It is essential that fire safety is embedded through design, construction and management. Fire safety professionals have an important role to play at each of the seven RIBA work stages.
- RIBA stage 2 is an opportunity to agree first principles contained in a concept fire strategy with an independent Building Control Body;
- Formal consultation with the Building Control Body on the developed design fire strategy should occur at RIBA stage 3;
- The Building Control Body should formally consult the Fire Authority on the technical design fire strategy at RIBA stage 4;
- The Building Control Body will undertake site inspections throughout RIBA stage 5
- The Building Control Body will acknowledge receipt of an ‘As-built fire strategy’ and issue their final certificate or completion certificate at RIBA stage 6.
4) Interim recommendation for developers
Building developers need to ensure that there is a formal review and handover process ahead of occupation of any part of a new high-rise residential building. While there are legitimate reasons to allow occupation in a phased way, the practice of allowing occupancy of buildings without proper review and handover presents barriers to the implementation of any remedial measures identified as part of the completion process.
We agree. Not enough consideration is given to the effective provision of fire precautions during the construction stages. The importance of suitable construction site fire risk assessments, construction site fire strategies and a programme of inspections is often over looked. Pre-occupation fire safety assessments are a useful tool that can provide assurance that the fire strategy has been implemented, and necessary fire safety design measures incorporated prior to handover and subsequent occupation. They go hand in hand with a phased occupation strategy and are often a necessary step to ensuring an as built fire strategy is issued.
5) Interim recommendation for Building Control Bodies
There is a need for building control bodies to do more to assure that fire safety information for a building is provided by the person completing the building work to the responsible person for the building in occupation. Given the importance of such information for ongoing maintenance and fire risk assessment, proof should be sought that it has been transferred.
We agree. Some time ago we wrote an article entitled “The mystery of missing fire strategies”. We also published a BB7 white paper entitled: A guide to fire safety information for owners and occupiers of premises. If security concerns could be overcome we would support the idea of Local Authority Building Control keeping the public record.
6) Interim recommendation for responsible persons
It is currently the case under the Fire Safety Order that fire risk assessments for high rise residential buildings must be carried out ‘regularly’. It is recommended that the responsible person ensures these are undertaken at least annually and when any significant alterations are made to the building. These risk assessments should be shared in an accessible way with the residents who live within that building and notified to the fire and rescue service.
Fire risk assessments on high rise residential buildings must be carried out annually by a third party certificated fire risk assessor registered on a UKAS accredited scheme.
7) Interim recommendation
The government should significantly restrict the use of desktop studies to approve changes to cladding and other systems to ensure that they are only used where appropriate and with sufficient, relevant test evidence. Those undertaking desktop studies must be able to demonstrate suitable competence. The industry should ensure that their use of desktop studies is responsible and in line with this aim.
We agree that the restriction on desktop studies be limited to those with knowledge and experience of how materials behave within a system when that system is subjected to fire. In regards to the holistic fire engineering approach, this method has its merits when looking at cladding in isolated areas of a building where the risk of fire spread via the external wall is low. This can be demonstrated by a fire risk assessment of the external wall and may include quantitative data if necessary. Having such a method available can enable complex building designs while also minimising the risk of fire spread over the external walls. In both the desktop study method and fire engineering methods, each building should be studied on a case by case basis and the report should not be used for subsequent projects.
Our overwhelming view of the Interim report is that it is well written, professionally produced and covers many issues that we have been talking about for years. The general trend of reduction in the number of fires and associated injuries and deaths is a testament to the advances this country has made in understanding fire safety, innovation in fire engineering and progressive regulatory controls. The UK does have world class fire engineers and can deliver world class fire engineering. I am pleased to say we are on route to a safer future.
Ben Bradford BSc MSc MBA CEng FCIBSE FRICS FIFireE PPCABE
Founder and CEO at BB7
Published February 2018