David Poxon, practice principal, covers Fire Protection Association responses to government consultations and what it wants to see changed.
Over the last 12 months, a number of government consultations have been carried out in response to Dame Judith Hackitt’s Independent Review of the Building Regulations: Final Report. These include consultations on assessments in lieu of tests, the banning of the use of combustible materials in external walls of high risk residential buildings, the clarification review of Approved Document B of the Building Regulations (ADB) and a call for evidence for the technical review of ADB. Additionally, there has been consultation in Wales and Scotland along with a Ministry of Housing, Communities and Local Government modern methods of construction (MMC) inquiry.
The consultations have provided an opportunity to participate in the review and shaping of future fire safety legislation and guidance. The FPA, in conjunction with RISCAuthority, has submitted responses to all the consultations to date, and would encourage individuals and organisations with an interest in fire safety to do the same.
Historically, improvements to fire safety legislation and standards have essentially been reactive, usually in response to tragic events. It is imperative that a more proactive approach is adopted through the regular review and updating of legislation and guidance, including a review of the lessons to be learnt from any large life and property loss fires that may occur, both locally and internationally.
MMC has been addressed in two of our responses. Generally, we feel that the present building regulation guidance and inspection may not always be suitable for all types of MMC, because of the nature of the products and their speed of assembly and installation on site.
As a result, it is imperative that design and installation standards, product standards and certification, building regulation guidance, and reaction to fire testing (including large scale testing, where deemed necessary) are all adequately addressed. There is also the potential for losses to be disproportionate to the event from fire spread in concealed spaces; firefighting water; and escape of water from plumbing.
Our response to the latest consultation calling for evidence for the review of ADB included comment on a range of topics. Amongst these topics were the need for a more clearly defined scope and purpose (particularly relating to buildings likely to fall outside of the scope of the document); limits on compartment sizes for large, single storey commercial and industrial occupancies; revised thresholds for the provision of fire suppression systems; support for the mandating of third party approvals; improved fire and rescue service (FRS) access; and the need for ongoing research on smoke and toxicity.
In addition, addressing building resilience and property protection more thoroughly would help to reduce the potential for disproportionate loss and consequence following a fire. Life safety and property protection are more closely related than we may sometimes appreciate.
For example, the objective of limiting the spread of fire within a building – which is normally achieved by limiting compartment size, separating high fire hazards areas or providing automatic sprinkler protection – has the potential to contribute to life safety, property protection and FRS access alike.
Clearly, the fire safety legislation and guidance landscape is going to change. To what extent we do not know; only time will tell. What we do know, however, is that we have an opportunity to be part of the process. Participation is key!