On 17 March, the FPA submitted its response to the DLUHC consultation on sprinklers in care homes, the removal of national classes, and staircases in residential buildings.
Sprinklers in care homes
In relation to sprinklers in care homes, the FPA once again reiterated its position that health and life safety should be realised alongside the consideration of property protection. Its response calls on those responsible not to design and build solely to the ‘life safety before collapse’ objective, and for the application of the LPC Sprinkler Rules.
One of the key points raised around the protection of the property of care homes related to the vital service to residents and their families in the wider community that they provide.
“We encourage DLUHC to recognise that the protection of care home buildings as an asset and place of healthcare that provides a vital service to residents and their families in the wider community warrants a commitment to the LPC Sprinkler Rules. Other systems providing suppression or extinguishment for health and life safety only are not sufficient to protect the asset.”
The FPA made clear its opposition to both a 10-bed threshold, noting that an arbitrary threshold will simply encourage 9 bed facilities, and the proposal to limit the sprinkler requirement to new care homes only, stating:
“Most care homes already exist, and this DLUHC proposal limited to new care homes does not retrofit the existing stock as it should.”
Removal of national classes
Regarding the removal of national classifications, the FPA broadly agrees with the DLUHC proposal, but notes the issues surrounding the historic problems arising from the Class 0/B transposition in Approved Document B. Another issue raised includes the fact that nowhere in the BS EN 13501 series is smoke quality in the form of toxicity addressed, also an oversight of the BS 476 series.
The FPA also accepts that, for most products, the European Fire Resistance tests are more onerous and that the European Fire Resistance standards do generally provide a more onerous test condition, particularly in higher furnace temperature and pressure.
It notes that the UK fire door sector may want a longer transition period, but in wanting that, the sector risks losing business to manufacturers who have already made the transition to BS EN 13501-2 classes. However, full adoption of European standards, if forced quickly, will immediately invalidate accumulated test data generated against BS 476 20 series of standards. This may reduce the availability of Fire Resistance products and overtly pressurise some smaller UK businesses financially which may increase imports.
Staircases in residential buildings
The FPA believes that the question of evacuation and intervention should be addressed for all buildings regardless of height or occupancy, rather than there being a maximum threshold for the provision of a single staircase in multioccupancy residential buildings. It does note, however, that the
“call for two stairs is simplistic. It ignores the combination of measures that may be considered to provide for evacuation and intervention”, as even in lower rise buildings that have other fire safety inadequacies, single stairs can become impassable. The provision of stairs is just one factor, and the FPA believe it is important not to leap to the conclusion that all single stair buildings are dangerous.
However, the FPA does believe that there will be no shift to a new understanding of residential typology without published research on evacuation.
You can read the FPA’s full submitted response to the consultation below.
FPA response to DLUHC consultation - March 2023