Mazin Daoud examines the revised HTM 05-03 Part K, offering guidance on fire risk assessments in complex healthcare premises
Ensuring fire safety in all healthcare premises is of the utmost importance. Following the tragic fire at Grenfell Tower and the subsequent independent review of building regulations and fire safety, chaired by Dame Judith Hackitt, Health Technical Memorandum (HTM) 05-03 part K ‘guidance on fire risk assessments in complex healthcare premises’ has been revised with some extensive changes. This article sets out to address the role of an HTM, the risks specific to complex healthcare premises, what’s new in the revised HTM 05-03 Part K, and how this applies in practice.
What is an HTM?
HTM give comprehensive advice and guidance on the design, installation, and operation of specialised building and engineering technology used in the delivery of healthcare. They include use for developing governance and assurance systems which take account of risk, and the safety of patients, staff, and visitors.
They are issued by NHS England and focus on healthcare-specific elements of standards, policies, and up-to-date established best practice. They are applicable to new and existing sites, and are for use at various stages during the whole building lifecycle. In the hierarchy of guidance documents, they are akin to guidance issued under Article 50 of the Regulatory Reform (Fire Safety) Order 2005 (FSO). As such compliance with the guidance may be relied upon as tending to establish legal compliance with fire safety duties.
Fire safety is covered by the HTM 05 series, also known as Firecode, which includes the following subjects:
Why have specific guidance for complex healthcare premises?
Complex healthcare premises
The definition of a complex healthcare premises in part K is a “hospital or other healthcare premises which place a dependence on staff for evacuation”.
This, however, only really touches the surface of what one can find in a complex healthcare premises, which are less common to other buildings:
Meeting the needs of patients
- Very high dependency patients for whom the act of evacuation can only be in exceptional circumstances, and may not be immediately possible, for instance in theatres
- Dependent patients who rely on staff for evacuation
- Patients with conditions such as dementia who need close supervision during a fire emergency
- Children undergoing treatment or care who may have relatives with them or nearby
- Business continuity is vital to ongoing patient care.
Evacuation protocols
- A high level of training and competence for staff is required
- Evacuation not routinely commenced on the fire alarm sounding in many patient treatment or care areas
- Progressive horizontal evacuation is the usual methodology for evacuation
- An environment in which a sounding fire alarm can be extremely disruptive and distressing
- A greater emphasis on the importance of fire wardens both in preventing a fire and in fire safety, should one occur.
Medical gases and building set ups
- Piped medical gases including oxygen and nitrous oxide (50% oxygen)
- Extensive use of cylinders including those containing oxygen
- Extensive use of compartmentation and sub-compartmentation
- The separation of any higher risk areas in a ward or department into a 30-minute fire-protected hazard room.
Other hazards
- The risk of arson is much higher in hospitals than other buildings.
The above is only a small sample but it is vital that the risks are properly assessed and managed to minimise damage and disruption. For example, a historic fire incident involving the medical gas pipeline system at a hospital caused extensive fire damage, whilst a similar, more recent fire at a hospital caused relatively minor fire damage.
The main difference was that the medical gas pipeline system was isolated at an early stage in the latter, a product of an effective training needs analysis and management system.
How does this affect me?
If you are considering completing fire risk assessments (FRAs) in complex healthcare premises, an in-depth knowledge of part K and some knowledge of the rest of Firecode is essential.
Some of the methodology in part K may be useful in other buildings, for instance remediating existing fire seals where the manufacturer is not known.
Part K is a newly revised document and provides a pragmatic means to achieve regulatory compliance. Familiarity with the document would be helpful for the continuous professional development of persons completing FRAs.
Items of note in the revised Part K
Risk assessments
- A primary FRA is now required for the whole building including common areas and will include building management arrangements such as the fire strategy, fire alarm system, external wall system, and compartmentation.
- A secondary FRA is required for locally assessed or managed areas such as wards or departments.
- The methodology outlined in PAS 79 is generally adopted, although the risk matrix is still on a 5 x 5 to fit with NHS reporting systems.
- Guidance on external wall risk assessment is included.
- The most severe level of potential consequences resulting from a fire has been amended to “catastrophic” to align with PAS 79.
While the revised HTM states that it is not necessary to provide indicative timescales for completion of the recommendations within the FRA, it is essential that a level of priority and importance to these recommendations is provided within the relevant management system. Action must be taken immediately if there is catastrophic risk or if risks can be reduced by simple immediate action.
There is also an emphasis on the legal requirement to reduce the risk to “as low as reasonably practicable”, that is the point at which the benefits of risk reduction become grossly disproportionate to the cost. This will vary as the risk varies and does not simply include financial cost but also cost in terms of reductions in the ability to provide treatment or care for patients.
For instance, an area in which all persons can easily and quickly evacuate will have a different risk profile to one in which the act of moving very highly dependent patients may endanger their lives. In the case of the latter, the benefits are likely to be far higher than in the former, and thus the point at which the costs become “disproportionate to the risk”. It is this which the FSO differentiates at the start of many of the articles by including e.g. “17.—(1) Where necessary in order to safeguard the safety of relevant persons”. This means that there may be variations in, for example:
- the acceptable standard of fire doors
- maintenance regimes both in frequency and applicable standards
- the provision of fire extinguishing media
- the level of training
- the frequency and type of evacuation exercise.
Any such variation should be supported by and detailed in a fire safety protocol (HTM 05-01 appendix E) or training needs analysis (HTM 05-03 part A).
Competence
There are many reading this article who will be fire risk assessors. As is clear from the previous bullet points, complex healthcare premises are very different from a typical factory, office, or shop, and more complex than even a high-risk residential building.
Fire Risk Assessments (FRAs) may be undertaken by both (or either) internally employed staff or externally appointed contractors. Whatever the appointment status of the fire risk assessor, a robust process of due diligence should be employed to ensure that the appointed fire risk assessor holds an adequate level of competence to the satisfaction of the responsible person. Only suitable persons who have relevant comprehensive training or experience in FRAs should assess healthcare premises. The level of the training and experience should be commensurate with the complexity of the premises to be assessed. Where relevant, the Fire Safety Manager and appointed Authorising Engineer (Fire) should be consulted.
In 2020, the Fire Sector Federation produced the ‘Approved Code of Practice: a national framework for fire risk assessor competency’ to establish industry standards for assessing the competency of individuals who conduct FRAs. The guidance includes matters of behaviour and details of the knowledge, skills, and experience expected for a competent fire risk assessor. The Code sets out the requirements for fire risk assessors for:
- appropriate third-party certification and/or accreditation and membership of professional bodies
- core competencies
- functional requirements for specific sectors
- methods of assessing competence of persons
- competency assessments recording and reassessments
- maintenance of competence training and continuous professional development.
Details of competence such as records of training, knowledge, and experience must be checked, including the risk assessment and method statements. In addition, it is important that the authorising engineer validates the efficacy of at least a sample of fire risk assessments completed, including areas where there are very high dependency patients.
Further guidance
More comprehensive guidance on assessing and maintaining fire doors has been included in HTM 05-03 part K. It outlines different options for existing fire doors that may not meet current standards, such as accepting “notional” fire-rated doors if professionally assessed as likely to perform adequately, upgrading them with new seals/strips, or full replacement. Competent assessors must evaluate fire doors against their intended purpose in the fire strategy, considering factors such as fire load, patient dependency, and evacuation times.
There is a new chapter on maintenance recommending that the frequency of maintenance should be risk-based and evidence-backed. The overriding risk to healthcare from contamination and the risk of infection means that there should be a proportionate maintenance programme that is unlikely to pose a risk to patient safety. This may result in varying the frequency of checks from generally accepted standards and recommendations with a greater emphasis on utilising local staff.
Appendices now include guidance on assessing the remediation of existing passive fire protection and a hazard room assessment matrix.
In the case of existing fire compartmentation seals which require remediation, the process shown in Figure 2 (above) should be adopted.
Conclusion
The revised part K provides extensive guidance and a methodology to achieve a “fire safe” environment in complex hospital environments, where the risk is to be reduced to “as low as reasonably practicable”. However, the process relies on the professional completing the assessment to be competent – not only in completing fire risk assessments but in the specific and unique environment of complex healthcare.
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Mazin Daoud is the Head of Fire Safety for NHS England