NEWS Regulations review submissions shared


BAFE, THE FIA, RIBA and the ABI have all published submissions to the building regulations review. BAFE recommends fi rstly that


regulations ‘be strengthened and clarifi ed to enhance requirements’ for resilience, as well as ‘enhancing the life safety risk elements’. New materials, digital reliance and new fi re detection and suppression methods place ‘greater needs for regulations to be applied and enforced by competent organisations and staff’. Second, the requirements of Regulation 38 should ‘be consolidated’ so new and existing buildings have a ‘full record’ for the responsible person as to ‘how the building is protected’, and so a ‘full and proper’ fi re risk assessment (FRA) is possible. This is ‘vital’ when alterations,


refurbishments and use changes happen that are ‘often overlooked and not incorporated’ in protection. The third recommendation is that third party certifi cation of protection organisations ‘should be made mandatory’, backed up by ‘detailed requirements based on national standards’ accredited by UKAS, including products and materials plus ‘related services’ such as FRAs, design, installation and ongoing maintenance. Fourth was that the ‘critical


function’ of FRAs should be ‘carried out and regularly updated’ by a ‘demonstrably competent person within a certifi cated or accredited framework’. This should become a ‘mandatory requirement at the very least for [...] high risk premises’, with a ‘signifi cant increase’ in procurement and specifi cation of certifi ed services, though these are ‘by no means a standard requirement’ nor ‘universally accepted as good practice’. A ‘general lack of understanding’


of competence is ‘especially true in procurement’ of FRAs, BAFE believing this should be ‘linked to the critical functions’ of fi re engineering in design and construction. BAFE concluded that ‘there is a genuine desire to improve fi re protection for both life safety and property protection’. However ‘without regulatory support’, there is ‘no guarantee that


this vital work across the fi re sector will be carried out by competent providers and raises the prospect of future exposure to unnecessary risk for both the general public and emergency responders if these regulatory requirements are not enforced’. The FIA (Fire Industry Association) added that regulations contain ‘too much complexity’, and that the industry needs a ‘simplifi cation of the rules and better enforcement of existing requirements’. Its Special Interest Group (SIG) provided ‘rigorous feedback’, stating there are ‘also a large number of detailed aspects of fi re safety regulations which are not well understood’. RIBA’s ‘wide-ranging’ submission,


developed by its expert advisory group on fi re safety, recommends the Regulatory Reform (Fire Safety) Order be repealed, and ‘mandatory’ fi re certifi cates be reintroduced for ‘designated premises’, based on ‘independent inspections’ by services with ‘statutory powers of entry to individual dwellings where necessary’. Another recommendation is a


requirement for ‘central fi re alarm systems in multiple occupancy residential buildings’. RIBA asks that the desktop study approach to ‘demonstrating compliance’ be removed, and that sprinklers or automatic fi re suppression systems be installed in ‘all new and converted residential buildings’ or ‘at least’ for buildings over three storeys. More than one means of ‘vertical


escape from new multiple occupancy residential buildings’ over three storeys was urged, as well as ‘no use of compensatory features for omission of a staircase or alternative means of escape’. Requirements for natural and


mechanical smoke vent or exhaust provisions should be reviewed for corridors, lobbies and stairs ‘to ensure current performance capacities are suffi cient’. Finally, external walls of buildings


over 18 metres should ‘be constructed of non-combustible (European class A1) materials only’, RIBA calling for sprinkler and fi re alarm retrofi tting in existing residential buildings over that height, ‘or maybe even three storeys for sprinklers’. Separately, ‘consideration should be given’ to revising principal designer and contractor roles, ensuring ‘so far as is reasonably practicable health, safety and welfare’. The designer should have power during design or ‘contractor design’ periods to ‘enable safe design and construction’, requiring ‘greater level of approvals and inspection’ by building control offi cers, independent clerks of work or site offi cers. In turn, the principal contractor should have a ‘greater responsibility’ to work alongside fi re services, clients and the principal designer to achieve ‘fi re safety objectives’. Finally, the Association of British


Insurers (ABI) wanted regulations’ fi t-for-purpose’,Construction Index reporting that it added ‘it is time to end the use of combustible materials on the outside of new and refurbished buildings, as well as limit the use of combustible material on the inside’. It also called for ‘more robust


testing regimes to prove materials are not combustible’, to replicate how materials are ‘used in real world conditions’; ‘more clarity’ on roles and responsibilities in fi re safety; and ‘mandatory installation of fi re sprinklers in new schools, care homes and warehouses over 2,000m2


’ www.frmjournal.com DECEMBER 2017/JANUARY 2018 7


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