Quality evidence
To say that it has been a strange 12 months would be a gross understatement. Yet the resilience of the fire safety industry has been extraordinary throughout this period, and I believe the responsibilities to clients have been as well executed as possible in the circumstances. BAFE (British Approvals For Fire Equipment) has stressed multiple times that fire safety obligations are still very much in place and enforceable and this reiterates messages from fire and rescue services (FRSs) across the nation.

What is more impressive is the fire sector’s ongoing interest in and uptake of the United Kingdom Accreditation Service (UKAS) accredited third party certification (TPC) throughout the pandemic. Prior to COVID-19, the topic of competency was already at the forefront of minds – clearly as a result of the Grenfell Tower fire in June 2017, as well as other fire events such as at the Glasgow School of Art, bringing this issue to the top of the safety agenda.

UKAS and accredited certification bodies do an astronomical amount of work every year to define quality and competency. This is especially apparent in the fire safety industry, where demand continues to rise in the interest of life safety. Subsequent outcomes and opinions by respected and influential people and bodies have followed, stressing only the importance of providing quality evidence of competency to fulfil specific life safety work.

In the final report of the Competence Steering Group (CSG) for Building a Safer Future – Setting the Bar – in clause 70 (relating to third party assessment of organisations), Graham Watts, chairman of the CSG and chief executive of the Construction Industry Council, stated: ‘In some sectors, it is common for organisations (for example, installation companies) to be required to demonstrate that they employ competent staff who are properly assessed, managed and supervised.

‘This can be achieved by third party certification of the service provided by the organisation or of the competence management system operated by the organisation. The final recommendations, therefore, reflect this point and it will be for the working groups and the Building Safety Competence Committee to decide how this will operate in practice for each sector.’

A thriving, responsible and competent community exists within the fire safety sector. These are the proactive organisations anticipating stronger regulation, guidance and possibly legislation to provide life safety services. What is also important to note here is that many of these organisations have held TPC for multiple years now, completely voluntarily, to assess and demonstrate their competency without any compulsory requirement.

This is testament to their responsible practice to provide competent work and understandably evidence that in order to obtain lucrative contracts. At the Fire Sector Summit back in 2019, I recall the FPA’s managing director, Jonathan O’Neill, insisting on the mandating of UKAS accredited TPC. He stressed to government: ‘… Get on with it. Yesterday [04/11/19] I heard they aren’t planning to introduce the legislation that will see Hackitt’s recommendations become law until the middle of next year, and the law will take about a year to get through the parliamentary process.

‘That is four years after Grenfell – it’s too long. I make the plea to government, after the general election whoever is in power – get on with it. Make the changes in building regulations that are so obvious they really don’t require further scrutiny. Mandate third party certification, ban single staircases in tall buildings, install sprinklers and high integrity detection and evacuation systems and ban combustible materials in all high risk occupancies, regardless of a building’s height. This is not rocket science, so get on with it and get on with it immediately please.’

These words still ring true in 2021, and I fully support and echo that request. Chris Auger, BAFE’s director of schemes, reacted at the time by commenting: ‘BAFE fully support and reiterate Jonathan O’Neill’s statement and demands to government. An important factor here is to consider the entire life-cycle of buildings and their ongoing assessment for fire risk. The competency of fire risk assessors however continues to remain a largely unregulated and precarious market.

‘BAFE introduced the SP205 Life Safety Fire Risk Assessment scheme in 2012, developed with the request from government after the Lakanal House fire in 2009. The industry has regulatory procedures available, but whilst this remains voluntary only the overtly responsible providers are gaining third party certification to prove their competency in this realm.

‘Big changes are required to ensure only competent providers are being used for the appropriate work. Construction and fire safety providers cannot let all of the excellent work done in the Competency Working Groups go to waste through inactivity from government or the industry!’

Overlooked areas

Anticipating demand for TPC can be difficult to predict, even when the government has previously requested particular development. In recent times, since Mr Auger’s comments in 2019, what has been noticed is the uptake of this certification in certain services, including fire risk assessment and emergency lighting system work, which is a direct result of the Grenfell Tower fire and calls for stronger evidence of competency requirements.

For example, the Setting the Bar report recommended in clause 423 as part of Working Group 4 (WG4) on fire risk assessors: ‘A statutory requirement to use only fire risk assessors meeting the standards defined in WG4 criteria to conduct assessments of higher-risk buildings and those of complex fire risk will safeguard and reassure the public, regulators and firefighters that competent fire risk assessments have been made.’

In this aspect, the fire safety industry can reasonably be seen to have been proactive in its practice and it has begun evidencing competency before any fixed criteria are put into action. Regardless of what criteria are stipulated, this exercise has helped demonstrate the competency of many organisations across the nation. For others, it has exposed gaps that require attention prior to becoming eligible for TPC. That can be a bitter pill to swallow, but necessary in the endeavour to achieve this high level of competency.

What is harder to anticipate, however, is which other currently unregulated areas of fire safety require TPC, and their demand. New TPC schemes are developed due to multiple factors. For example, in October 2020, BAFE launched its SP207 scheme for the design, installation, commissioning and maintenance of evacuation alert systems. The demand for this scheme to be developed was shown in two ways.

Firstly, the FRSs wished to develop it, which is a more than good enough reason – any responsible body would work with the FRSs to enhance competency and safety. Secondly, it was evident that this was required following a Ministry of Housing, Communities and Local Government (MHCLG) consultation regarding sprinklers and other fire safety measures in new high rise blocks of flats.

In the published outcome of their findings, it noted that an overwhelming 92% of respondents agreed that Approved Document B of the Building Regulations should include
a requirement for an emergency evacuation system (which could support FRSs’ operational response by alerting residents if they need to escape). The document added: ‘Several respondents noted that an evacuation alert system being in place would provide both clarity and reassurance to residents’.

The consideration of installing evacuation alert systems is a somewhat overlooked part of high rise residential building (HRRB) or high risk building (HRB) management at present. BAFE anticipates that the demand for evacuation alert systems to be installed and maintained by third party certificated organisations will rise dramatically in the near future.

This will be a clear message to any managers of HRRBs and HRBs that stronger action is required to assist life safety of both the residents within the building and the safety of emergency services.

Personal experience

Reflecting on my experience with a major fire – evacuating a full multistorey block of flats at Waddell Court Glasgow in 2009. I experienced a range of operational difficulties and would stress the fact that a system to enable and signal the evacuation in a controlled way would have been of benefit to me and any fire commander faced with the same issues.

At the time of the incident, my colleague area commander Garry Milne of Strathclyde Fire and Rescue commented: ‘In my 20-plus years in the fire service I have never seen such a fierce fire in a property such as this.’

This fire was an example of fire spread that was not controlled well by passive systems and therefore required the evacuation of people who, for their own reasons, may have wished to stay put despite the interventions of the FRS. Such an evacuation brings its own problems and demands a huge physical effort to resource the incident ground sufficiently to make contact with tenants and have them evacuate.

It also places another dimension within the sphere of operations – managing a safe evacuation during fire and rescue. The FRSs are not an evacuation service, yet will always undertake actions to save lives; it is clear that on occasion this will involve mass evacuation. This requires careful planning, and having appropriate technology and systems to hand would be advantageous to say the least.

A standard system which is recognised and can be embedded within a new culture of safety will be essential to this moving forward. People worry about their properties and belongings and simply want to have access to these as soon as possible. This reluctance builds in a real world delay in terms of the speed at which an evacuation can take place, and therefore anything which assists must be seen as a good thing.

In the end, properties of this type were designed so that tenants could remain in place while firefighting operations could be undertaken. This was most notably witnessed by the public in the Grenfell Tower fire, resulting in large loss of life. I have experienced at first hand how this is not always the case, and we need to plan for this in harness with all stakeholders who have a claim in serving communities, either through response or safeguarding the built environment.

The frustration that arises here is the hesitation to become third party certificated to install and maintain these systems. In this particular aspect, the construction and fire safety sectors are still waiting to be told to do this rather than acting in the best interest of life safety.

In 2019, at a conference held at the Local Government Association in Westminster, Dame Judith Hackitt told the audience that the work of the CSG was ‘impressive’ but that ‘changing the regulatory framework, which some of you are waiting for, is going to take time’. She added: ‘My personal view is that the direction of travel is right, and progress on many of the aspects of implementing the recommendations [set out in the Building a Safer Future report] is encouraging.

‘But we’re not moving fast enough to change any of it. So, what are we waiting for? Why is there still a sense of waiting to be told? More importantly still, I think you need to examine why you are doing this. You should be doing this because it’s the right thing to do. Not because the rules and legislation make you do it.’

While UKAS accredited TPC has been widely adopted by the industry to regulate competency for many specific fire safety disciplines, as previously mentioned, professional bodies continue their demands to the government to mandate this.

In correspondence which was recently sent to Peter Baker, the appointed chief inspector of buildings to lead the new Building Safety Regulator (BSR), I made the following comments:

“The responsible and competent section of the fire safety industry is willing to accept stronger regulation. Many of which already hold Third Party Certification for one or more services delivered to evidence this.

‘The BAFE Fire Safety Register is ready for stronger collaboration with the HSE and BSR to aid in the advancement of life safety in respect to fire. We strongly believe in the value of introducing UKAS accredited third party certification as a statutory defence when considering fire liability. This would act in line with HSE health and safety documents, which are treated with the upmost consideration in the judicial system across the UK.’

It is important to conclude by stating that UKAS and other bodies, including BAFE, are ready to develop schemes to fill any gaps in competency evaluation that are identifed, to ensure that all services have avenues open to achieving TPC. This overarching method of evidencing competency is the direction in which we need to continue in, in order to raise the bar of competency and create a safer built environment throughout the entire life cycle
of buildings, not just when they are built.