Tom Gilbert examines the current place of fire testing in the provision of passive fire protection and looks at where and how the industry can improve for the future
The present landscape of passive fire and testing is one of change, with a number of crucially important reports, such as the Hackitt, Morrell/Day, and Grenfell Tower Inquiry Phase 2 reports, being released over the last few years.
Historically, passive fire protection was often seen as an afterthought. It was usually a small package on a construction job, with relatively low value that would be procured very late on in the process, probably during RIBA Stage 5, while the building was actually being built. That could have been the first touchpoint anybody with any passive fire protection installation and product knowledge may have had with the project. The passive fire protection contractor might have been presented with an existing situation on site and would need to do their best to solve the passive fire protection problems that arose – hardly an ideal situation and one that these various recent reports have raised as an issue and looked to address to one degree or another.
The findings and recommendations in these reports, alongside changes to legislation, has seen a change in approach, particularly by the large Tier 1 contractors, to one of early engagement. The thinking is that by bringing in specialist fire protection contractors earlier, they can review the project and give their insight on installing compliant passive fire protection solutions.
To most Tier 1 contractors, a compliant solution will mean either a manufacturer’s approved detail or a technical assessment, but it could also mean having a bespoke test performed for that particular scenario on that particular job. Indeed, some Tier 1s have gone even further, and have mandated that all passive fire protection solutions must be a tested solution.
Whilst this is a great idea in theory, the reality is it is impossible to test everything. Some things are just too big to physically test, for example with long spans of steel work, you can test the performance of a small section, but you could not realistically test a 50-metre-long steel column. Although some elements of a building can be physically tested, others will require an element of technical evaluation, which in itself requires a high level of competency. Capacity and competency within the testing sector are important issues that will raise their heads again and again.
Competency
As the Building Safety Regulator implements the requirements of the Building Safety Act, planned passive fire protection solutions will have to be stipulated at RIBA Stage 4. Testing will obviously play a part in specifying an appropriately compliant detail during the design. As long as it is built the correct way and as per the design, then in theory, contractors won’t need to do any more last-minute testing prior to practical completion.
However, as more early engagement takes place to provide this required information, we are finding that it is not the design, but rather the competence of builders and installers that is the problem.
For example, the services within a builders work opening could have been designed from the outset to be separated appropriately as a tested solution. But if the mechanical and electrical contractor fails to install the services as per the design, then the passive fire protection contractor may well find themselves back in the position of having to come up with an ad hoc solution to solve the incorrect installation. These ad hoc solutions to provide appropriate workarounds mask the issue of poor trade coordination and contractors not understanding the importance of their installation in relation to follow-on trades such as the passive fire protection operative. This is why early engagement around passive fire protection does not stop at the design and must influence trades, such as the mechanical and electrical contractor, so that they know the importance of installing as per the design and there can be greater coordination and cooperation between these various trades.
In reality, these problems around installation that we face on site can never be solved by testing alone, but where testing can play a role in mitigating the coordination and cooperation issues is that when mistakes are made and service details are installed in the wrong place, testing can be used to help find an appropriate solution. It can support the provision of tested solutions in new or non-standardised conditions, or the use of new products in specific situations that are being used to resolve these installation errors.
Newer products generally have less test evidence, so the opportunity to come up with a tested and appropriate solution in the built environment is dramatically reduced with the newness of the product that is planned to be used. For example, a newly manufactured specialist service, such as a busbar (for carrying high voltage electricity through walls) may have been tested by the manufacturer in a simple configuration such as a blockwork wall. After passing a fire resistance test for 60 minutes fire resistance, the manufacturer can offer a tested passive fire protection solution.
However, the passive fire protection contractor may find that they need to fire stop it in a blockwork wall but with additional services going through the penetration at the same time, or through a dry line partition wall or even a shaft wall, none of which are situations that it has been tested for. As a result most products will need to be tested in multiple scenarios over the course of its life. The situation we find ourselves in is that the newer the product is, the less likely there is to be an appropriately tested solution for different scenarios. We are therefore more likely to have to do bespoke testing for those particular elements that we are seeing on site.
Certification and capacity
Designers and contractors will often look to the presence of certification when choosing the products and systems they use as a means of ensuring appropriate passive fire protection is present. All products that have been certified, will however in time need to go through a process of recertification. Alongside this, with changes and updates to British Standards, there are many products that will have been tested to an old standard, but not to a new one. An example of this is the case of fire doors, where the announced removal of the BS 476 series will see an entire suite of products needing to be tested to the new EN 13501 standard.
Alongside this, there are a number of bespoke passive fire solutions being used in novel building conditions that will have a wide range of different variables and scenarios. These will all require testing, particularly as the drive from clients is for more tested solutions.
Additionally, when something as terrible as Grenfell happens, you get a justifiable public outcry which can actually drive a change at building regulation level. The whole scope of building regulations is basically a manifestation of public opinion on what is acceptable and what is not. Tragedies like the Grenfell Tower fire move that dial as to what will be considered acceptable in areas like passive fire protection, and so designers, contractors, and installers respond.
For example, building regulations do not have a requirement for all buildings to have fully tested solutions in all of the builders work openings in a project, but we are starting to see contractors making the decision to do this. In order for contractors and principal accountable persons to feel comfortable about what they are legally responsible for, they are requiring a greater level of assurance, despite the regulations not stating this is necessary. This is particularly relevant given the increase in time to the defects liability period to 30 years.
Therefore, at the moment, we’ve got new standards requiring more testing to be undertaken, as well as clients demanding more physical tested solutions, and this raises the issue of capacity within the testing system.
The lack of capacity in the testing sector is, however, not as simple as there not being enough furnaces. The real issue is a lack of appropriately qualified people at every part of the testing chain of custody. As an industry one of the questions that we should all be asking ourselves is how do we find more capable, competent people to support testing to the standard and level that is required?
This requirement is across the board, from designing new test standards, running the furnaces and interpreting the results, to writing the certificates and doing proper audit checks. This issue was one raised in the Morrell/Day report, which noted that competency and capacity in the UK market has been stripped out and moved abroad. As a result of that, we no longer have enough competent people in the UK to deliver what we need now, let alone to meet the needs of a changing sector.
In a recent OpenFire podcast episode, I posed to Dame Judith Hackitt how to address this issue, and her response was that it is actually up to the industry to solve it. There is not more building going on than there ever has been before, but instead the focus is now on doing this work properly, as it should be. There is a whole training and upskilling agenda that will form a key part of the capacity solution, but you cannot just flick a switch and create 20 new furnace engineers.
The testing industry faces a situation similar to that the fire risk assessment market faced in 2006. Very quickly people lacking the competency and capability to do the work became fire risk assessors, and it took several years before people started thinking about third-party certification scheme to prove competence. So we had a market full of people doing work, with no demonstrable way of being competent, and even now this remains an issue as you can see from a number of the Grenfell Inquiry report recommendations. It is important that the testing sector take the lessons learned from this fire risk assessor experience to ensure we can increase competency hand-in-hand with increasing capacity.
Scrutiny and impartiality
Testing houses and certification bodies have rightly come under an incredible amount of scrutiny in the Grenfell Tower Inquiry phase 2 report, particularly concerning the relationships between test houses and product manufacturers. The perceived looking the other way when products did not actually do what they were sold to do, is something I would like to think will be banished to the past, just by virtue of it being mentioned. It is likely, however, that these perceived issues will be legislated for.
The drive for the journey we have been on with the FPA to have our own UKAS-accredited laboratory, was not initially to support manufacturers, it was about us supporting our key clients around solving passive fire issues that arose during construction. But the response from manufacturers has been such that there is a real interest in testing with us.
By having an intermediary, in our case, the FPA, between CLM Fire Testing (the test house) and the manufacturer it means, CLM Fire Testing who hold the relationship with the manufacturer are not the ones that administer the tests. If you come to CLM Fire Testing, and we assist you to design and install a test into a furnace that we own, the moment the test begins, it has nothing to do with us at all and we have no ability to influence the result. This is how we can ensure that lessons from the Grenfell report can be put into practice as it is a means for testing houses to make themselves more independent than they currently are.
As a result, I think we will see this arms-length approach between the test house and the administrator of the test to be the model for the future of testing – a future that can help in the journey to deliver safer buildings for all.
CLM Fire Testing, part of CLM Group, a leading provider of fire safety solutions, has partnered with the Fire Protection Association (FPA) for the establishment of a cutting-edge, UKAS-accredited fire testing laboratory. This collaboration marks a significant milestone in advancing fire safety standards and fostering innovation within the fire protection industry.
In collaboration with the FPA, CLM Fire Testing will provide clients and supply chain with premier access to essential fire testing.
Fire & Risk Management is the UK’s market leading fire safety journal, published 10 times a year, and is available exclusively to FPA members in digital and print format depending on your requirements. You can find out more about our membership scheme here.
Tom Gilbert is the CEO of CLM Group