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The principles of maintaining fire safety systems are universally applicable across all building types, and this is especially true for the mixed-use offices/commercial/residential modular construction that is the WRaP building. Compliance with fire safety regulations is not merely a legal obligation but a critical element in managing risk and safeguarding occupant safety.

Fire systems must remain functional, and their design, installation, and maintenance should account for both technical specifications and the evolving needs of the building. Changes in use, occupancy levels, and technological advancements can all influence fire safety requirements, making adaptability a cornerstone of maintenance strategies.

Key to effective maintenance is the assurance that fire systems and equipment – whether fire extinguishers, alarms, suppression systems, or emergency lighting – continue to function as designed. Neglecting this responsibility can result in catastrophic consequences, including loss of life, property damage, and legal repercussions.

Legal framework and risk management

Under national fire safety legislation, the Responsible Person (RP) or dutyholder is legally mandated to ensure fire safety precautions remain in good working order. These obligations are reinforced by fire risk assessments, which must explicitly address maintenance requirements.

Enforcement authorities assess the adequacy of these measures, evaluating whether the building’s fire systems protect all occupants effectively.

The role of dutyholder is complex: while the law establishes clear obligations, it often leaves room for interpretation regarding competency, which can lead to inconsistent practices. For this reason, many dutyholders turn to third-party certified providers to ensure adherence to fire safety regulations. Certifications such as those from UKAS-accredited bodies like NSI provide assurance that fire safety systems meet legislative and operational standards. Furthermore, the use of approved providers bolsters defences against legal challenges or insurance disputes, underscoring a commitment to due diligence.

Fire systems maintenance often overlaps with other important activities, such as portable appliance testing which ensures electrical appliances and equipment are safe to use. While visual checks are helpful, the involvement of a competent person to conduct more formal inspection and testing of equipment is required at appropriate intervals. However, in legal terms ‘competency’ is not specifically defined at present, leaving it up to the dutyholder (who could be the building owner or manager) to determine the most appropriate measures.

Competency pitfalls

Fire risk assessments must include provisions for ongoing maintenance, and dutyholders are expected to assess whether equipment such as fire extinguishers, alarms, and emergency lighting meets the required standards. These systems are critical for safeguarding all individuals on the premises.

Third-party certifications provide a benchmark for evaluating service providers’ competence. These certifications involve rigorous audits of processes, qualifications, and compliance with industry standards.

Using certified contractors will ensure that the WRaP building’s life safety systems are maintained according to legislation and operational codes of practice. This certification offers proof of due diligence, serving as a defence in legal proceedings if needed. It also provides reassurance to dutyholders, reducing the risk of insurance issues, as poorly maintained systems or equipment could lead to invalidated policies or reduced claim payouts.

UKAS-accredited certification bodies authorise professional certified fire safety solution providers to issue an NSI/BAFE Certificate of Compliance, a trusted benchmark for ensuring high-quality maintenance measures.

While third-party certification helps to verify competence, enforcement of the Regulatory Reform (Fire Safety) Order in England and Wales – and its equivalent legislation in Scotland and Northern Ireland – remains inconsistent. This lack of enforcement has led to poorly installed or inadequately maintained life safety systems, contributing to unreliable equipment. Certificated providers help address these challenges by offering end users and system procurers confidence in their professionalism and expertise. Certification bodies ensure providers meet rigorous standards, adhere to best practices and operational procedures, and undergo background checks on both the companies and their management teams.

Mixed-use buildings

A prime example of the value offered by competent systems maintenance is seen when helping to prevent fires from occurring within ground-floor commercial units, such as offices and restaurants, where residential units are located above, as is the case with the WRaP. The particular risks posed at some mixed-use buildings were identified by BAFE, which introduced its SP206 ‘Design, Installation, Commissioning, Recharge and Maintenance of Kitchen Fire Protection Systems’ Scheme in 2018.

Fires in food-related establishments are a significant concern, accounting for nearly 10% of all large-loss fires. Data at that time, from the FPA/RISCAuthority and other insurance sources, revealed that these fires are most likely to occur between midnight and 6am, a time when buildings are less likely to be staffed. The often inaccessible, grease-laden sections of extract ducting, fans, and other filtration plant poses a common problem, particularly in view of its structural importance within many buildings. Maintenance of these areas is essential to mitigate these risks.

Failure to address these areas can allow fires to spread unchecked, endangering occupants, and causing extensive property damage.

Commonalities related to these timing issues were also causing significant concern – including the important positioning of kitchens at ground or basement level within buildings, together with their related ductwork for extraction purposes. In practice, this exposes the occupants of buildings to risks from fires spreading upwards at especially vulnerable times of night. The reality is that with kitchen staff vacating premises at the end of their evening shift, dormant fire conditions can take hold unobserved and unchecked.

NSI became the first UKAS-accredited certification body licensed by BAFE to audit providers of these commercial kitchen fire systems in commercial situations. Approval to BAFE’s SP206 scheme involves the demonstration of competence as a key criterion. Buyers are able to select the right contractor, who understands how the equipment works and has a proven track record of their use. Buyers sometimes blame equipment suppliers for operational problems that occur, when the fault may lie instead with their maintenance provider. For example, suppression equipment nozzles may have been moved for practical working/convenience reasons and an effective maintenance regime, such as one provided by a BAFE SP206 certified maintenance provider, will identify these issues and restore the system to its original state; its optimal operational performance is thus maintained.

BAFE SP206 certified maintenance providers are also required to identify the critical component parts within kitchen fire protection systems such as cylinders, nozzles, and fusible links, so that during maintenance procedures these parts can be identified according to their age and point within the system’s maintenance cycle – thereby helping ensure the overall system’s integrity and operational conformance and reducing the potential for unreliability.

The maintenance of fire safety systems is a cornerstone of building safety, requiring a meticulous, informed, and proactive approach...

High-rise hazards

The tragic Grenfell Tower fire brought renewed focus to fire safety in high-rise residential buildings. Approved Document B Volume 1: 2022 update introduced mandatory evacuation alert systems, adding an additional layer of protection. These systems are not intended to replace fire detection and alarm systems but serve as critical tools for expediting controlled evacuations in emergencies.

Evacuation alert systems allow fire and rescue services (FRS) to notify occupants in specific areas to evacuate without requiring door-to-door communication. This targeted approach enables firefighters to prioritise high-risk areas, optimising resource deployment during emergencies. These systems must be inspected and tested by a competent person every six months, with the system’s Certificate of Compliance renewed accordingly. Failure to do so results in non-compliance with BS 8629 – introduced to ensure the efficacy of these systems – potentially making ‘Responsible Persons’ liable to prosecution and rendering insurance invalid. Certified providers under BAFE SP207 ensure that evacuation alert systems meet the highest standards of reliability and effectiveness.

Fire and rescue service liaison

Effective fire safety extends beyond building systems to include collaboration with local fire and rescue services (FRSs). The Fire Safety (England) Regulations 2022 implemented the majority of the recommendations made by the Grenfell Tower Inquiry in its Phase 1 report, which required a change in the law. This legislation requires RPs to share detailed information about high-rise residential buildings, such as floor plans and the composition of external wall systems with their FRS. This information enhances the FRS’s ability to respond effectively during emergencies.

The legislation also mandates reporting out-of-service firefighting equipment, such as dry risers and evacuation systems, within 24 hours. Prompt communication allows the FRS to adjust pre-determined attendance (PDA) resources. Depending on the height and nature of the building, the FRS may require additional appliances and manpower when attending, along with aerial platforms, command and control units, pumps, hose laying units, water bowsers, or even a salvage unit. Impaired equipment within the building being responded to may require additional PDA resources to deal with the nature of the fire involved – hence this mandatory legislative liaison.

Challenges in modular buildings

The modular build nature of the WRaP also introduces additional challenges for fire systems maintenance. These pre-fabricated units must be properly installed and maintained to prevent fire risks. Passive fire protection measures, such as compartmentation, should be integrated with active systems, including emergency lighting, smoke detection, gaseous fire suppression, alarm systems, and extinguishing equipment, to provide comprehensive safety.

Maintenance of modular buildings must adhere to the Building Regulations 2010 Approved Document B, to include stringent provisions for fire stopping through “fire resisting construction elements” and a range of other compartmentation measures including walls, floors, cavity barriers, and stairs and service shafts. These measures are particularly critical to residential buildings over 11m high, with additional provisions for those over 18m where the risk of fire spread increases - which is the case for the WRaP.

Incorporating net zero

Solar panels are included in the scope of Approved Document B, reflecting their growing use as part of integrated ‘net zero’ measures. These measures, increasingly adopted in commercial, public, and residential buildings, often involve photovoltaic (PV) solar panels connected to battery energy storage systems.

However, the physical maintenance of solar panels is often overlooked, especially when they are installed on rooftops. This neglect can result in partial shading caused by factors such as algae, moss, lichen, airborne dirt, leaves, litter, and bird droppings. Such shading may create hot spots that can overheat and potentially lead to panel fires.

To mitigate these risks, regular building maintenance routines that include regular inspection and cleaning of photovoltaic (PV) systems are highly recommended. Similarly, PV array disconnection switches, also known as fire service switches, should be tested as part of planned maintenance.

Conclusion

The maintenance of fire safety systems is a cornerstone of building safety, requiring a meticulous, informed, and proactive approach, integrating with other maintenance regimes to ensure they effectively function throughout a building’s lifecycle. This includes revised procedures following building repairs, upgrades and changes of use, in line with the site’s current life safety fire risk assessment. In doing so, duty holders not only fulfil their legal obligations but also protect lives and property, providing a system demonstrably fit for purpose.

John Davidson

Article written by
John Davidson
Approval Schemes Manager National Security Inspectorate (NSI)

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