Dennis Davis shares a letter he sent recently on behalf of the Fire Sector Federation to Clive Betts MP, chair of the Housing, Communities and Local Government Committee.
"May I, on behalf of the Fire Sector Federation (FSF), an alliance of UK fire enterprises and institutions, say how much we welcomed reading your committee’s recently published report on building regulations and fire safety. The conclusions echo our concerns related to the pace of ‘real’ change post the tragic event of the Grenfell Tower fire, and on the current Building a Safer Future consultation.
I understand that the committee will be meeting with the Ministry of Housing, Communities and Local Government minister and Dame Judith Hackitt, presumably with these subjects in mind. The FSF clearly hopes you can explore in some greater depth the areas you have already identified. We would also wish to suggest that there are some other key issues that have yet to receive attention.
Defining the complete system – clarity on ‘buildings out of scope’
In reading the consultation, the proposed framework offers clarity for a section of the built environment. However, the challenges with fire safety are not just confined to this subset of buildings. We are naturally concerned about the creation of a two tier system of building fire safety, and wish to help deliver clarity on how the complete system works, including those ‘building out of scope’; avoids gaming of the system; builds on current good practice; and neatly interfaces to existing legislation.
A clearer picture of the national building safety regulator
In the proposals, the strength of the solution relies heavily upon a yet to be defined building safety regulator (BSR). A BSR offers a controlling element which the FSF has been seeking; one common authority overseeing fire safety in the built environment. It is difficult to say if the BSR concept, like the new regime itself, will work without a detailed understanding. In deliberating on the BSR role, the consultation document has raised additional questions over how the functioning of the regulator with its many constituent parts will successfully oversee fire safety. Separately, the consultation is ambiguous when it comes to connections between local enforcement bodies to ensure the proper functioning of the framework at a location.
Three frameworks in one
The introduction of safety cases will see the built environment in England operate with all three major regulatory frameworks as one. We will have prescription, functionality and now a safety case process. Recent months of learning and discussions on one aspect, the external fire spread functional requirements, has indicated that there are challenges in application. The move to a safety case for buildings in scope is logical, but there has to be support to develop the skill, experience and competence for the successful application of this approach.
Third party certification
The matter for products, procurement, testing and installation for example remains a major concern, since arguably the failure to understand the technical limitations involved – as well as the successes of responsible industry – are given limited shrift in the official outcomes so far.
Neither is the matter of third party certification to offer public and client reassurance of quality and performance given prominence in the consultation. We believe that those acting responsibly in supplying services and products, who invest heavily in this approach only to see their quotations dismissed by those seeking lowest cost solutions, deserve better recognition.
Clear technical guidance
Our members have actively supported the clarification that was made to the now 13 year old guidance within Approved Document B of the Building Regulations.
We have promoted the call for a technical review over many years. The move to make it easier to understand is welcome. However, we are concerned about the continuing delays to the full technical review of this guidance. It is a pressing need as it underpins this whole system and support is required to see it delivered.
Dame Judith has articulated well, both in her formal review and more recently, the considerable challenge posed to driving cultural change and improved competency in the construction environment towards fire safety. This has been a downward spiral that must be arrested.
We remain in a situation where individuals continue to promote themselves with no professional background of assurance through third party schemes or organisations. The FSF believes the relationship between government departments that share responsibility for workplace and housing fire safety is a critical component in achieving the ambition of greater fire safety.
The practicality of the pathway we are about to embark upon is for many in the FSF questionable – the devil is certainly in the detail – so it is important that the challenges highlighted by your committee are addressed. The mandate needs to be strong to ensure compliance and, given we often hear calls for simplification from building owners, any new approach has to include practicality to make solutions work, and that requires the fire industry and regulators to be actively engaged. Only then will we know the proposed solution will work when it is introduced to a concerned fire sector and the public.
I remain happy to assist if you feel that may be helpful"
Dennis Davis is executive officer of the Fire Sector Federation.