FIRE SAFETY
unnecessary obligations on the Trust to be able to deliver it. The physical design must stand up on its own. While there must be some degree of management intervention, it’s inevitable in a building with very high- dependency patients that the physical design features, as much as possible, should stand alone.” Equally important, he argued, was ensuring that information in relation to management was passed on to the operator, ‘to understand how that building works, and how to develop their emergency action plans’ – for example, the fire strategies setting out the active and passive measures necessary to be able to deliver a safe building, compliant with the Building Regulations. Andrew Foolkes said: “You need to know what these features are in the building to be able to develop an effective emergency action plan.” This should form the heart of the ‘Golden Thread’, which ‘should start at the beginning, and run all the way through the design phase, the construction phase, and then into the building’s operation’.
No ongoing control The speaker stressed that Building Control have no ongoing control once the final certificate has been issued. He said: “They don’t have the power to take any retrospective action, and the responsibility then, under the Fire Safety Order, passes to the local fire authority as the ‘regulator’. We’re visiting all sorts of healthcare buildings all the time in my work with Tenos, and talking, for instance, to Trusts, other operators, and SPVs, about how they run their buildings. The absence of any sanction from the local fire authority doesn’t necessarily mean that everything is OK. It’s fundamentally important that that process of ‘planning, checking, doing, and acting’ is going on in a cyclical way, to ensure continuous improvement.” The Building Safety Regulator Turning to the new Building Safety Regulator, the speaker explained that it was a new body within the Health and Safety Executive created as part of the Building Safety Bill review, to review the design and construction of higher-risk buildings. Many hospitals, of course, had such buildings, and thus any new hospital would be considered to fall into this category. Andrew Foolkes said: “Gateway One is already out there, so any new hospitals will require a fire risk statement to be submitted for review. The Fire Risk Statement sets out the high- level principles of the design, and some of the fundamentals – such as fire services access, how firefighters are going to get to the building, the location of the hydrants, the firefighting shafts, and the evacuation routes, and whether the latter conflict with the fire service access routes, or are nicely separate. It also discusses the types of materials that the building is constructed from. Lastly,” the speaker said, “there is
48 Health Estate Journal February 2022
Published in August 2019 by the Construction Industry Council on behalf of the Competence Steering Group, the Raising The Bar report represented 12 months’ work by over 150 organisations from across the construction, built environment, fire safety. and owner/manager sectors.
the strategic planning authority. I am sure some of the delegates attending are from the Greater London Authority.”
The London Plan “The London Plan,” he continued, “is something we have now started to encounter. It was introduced last year, and is similar to Gateway One, in that there are particular aspects of fire safety design that now need to be considered at the planning stage – so typically at RIBA Stage Two.” Andrew Foolkes stressed that this not only applied to high-risk residential buildings, ‘but to all sorts of buildings’ and major developments. In fact the last Fire Risk Statement he had been involved with had related to an ice rink. Looking ahead, he again mentioned the Building Safety Bill, which had been laid before Parliament earlier in 2021, and was likely to gain royal assent in mid-2022. He added: “Draft secondary legislation was released at the end of last week, and we’re still digesting that and trying to get to grips with what it means. I think higher risk buildings such as hospitals that are over 18 metres tall, or are of more than seven storeys high, will be subject to the Building Safety Bill in their design and construction.”
HTM revision Discussing the revision of the existing HTM 05-02, Andrew Foolkes pointed out that it was no longer managed by the Department of Health, but instead by NHSI. He said: “Looking on the relevant website, it says it was withdrawn on 25 September. In my view, the current guidance is lagging a little behind currently, in terms of the changes that have been made to Approved Document B. Whether
the intention is to signpost Approved Document B from the latest HTM revision, and regulation 7, I don’t know, but the information on external walls in HTM 05- 02 is quite scant currently, and I think any revision will pay particular attention to this.” He continued: “The Building Safety Bill looks at buildings over 18 metres high, while HTM 05-02 steers towards designing lower-height, more ‘sprawling buildings’, and I think there may greater prominence on fire engineering techniques in any revision to enable the sector to deliver fire safety-compliant buildings. “Lastly,” Andrew Foolkes said, “I anticipate an increase in the prominence and prevalence of the role of Authorising Engineers in providing advice to Trust Boards. We’re increasingly being asked to fulfil that role. So,” he added, “in conclusion, as regards ‘Roles and responsibilities throughout the organisation’, it’s our experience that all these duties and responsibilities can just land on one person’s desk. That can’t be right; there needs to be some assistance in discharging those responsibilities, but from an individual who is genuinely competent to do so. My advice would be to seek assistance, and to use the third-party accreditation schemes, the professional body registration schemes, and the trade contractor schemes, to ensure you are appointing people with the qualities, training, and experience, needed to demonstrate competence. In terms of changes coming,” the speaker said as he concluded, “there are a lot on the horizon, in terms of the Building Safety Bill, the role of the Building Safety Regulator, and its implementation. Developments in fire safety are only going to occur at an ever more rapid rate in the future, I feel.”
Courtesy of the Construction Industry Council
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