NEWS He also noted: ‘I am aware that


the provisions of the Bill will require potentially significant numbers of responsible persons to review and update their fire risk assessments [FRAs]. For many, that will require specialist knowledge and the expertise of the fire risk assessor. We are working with representatives of the sector to understand the particular challenges in delivery. ‘That will inform our approach


to the implementation of the Bill, while maintaining a clear and consistent approach to [FRAs]. In any event, and in line with the independent expert advisory panel’s consolidated advice, I would none the less encourage those with responsibilities to carry out a fire risk assessment under the order as a matter of good practice and to consider flat entrance doors and external wall systems as part of their fire risk assessment for multi- occupied residential blocks as soon as possible, if they have not already done so.’ BAFE called for a mandatory


requirement for UKAS accredited third party certification of fire risk assessment providers ‘for premises covered by this bill’, which would ‘provide independent evidence of the “specialist knowledge and the expertise of the fire risk assessor” which the Minister calls for’. Chief executive Stephen Adams commented: ‘BAFE welcomes the recognition by the Minister of the need for a clear and consistent approach to [FRAs]. We are involved in the work of the expert panel and will continue to promote the need for third party certificated competence (via UKAS Accredited Certification Bodies) for providers of this vital service.’


Height thresholds changed


Mr Jenrick meanwhile had announced in January ‘the biggest change in building safety for a generation’, including a new regulator, changes to height limits and new consultations. ‘Clarified and consolidated’ advice for building owners, proposals


to extend the combustibles ban and a consultation to lower mandatory sprinkler limits were launched, while a construction expert was appointed to review timescales and ‘identify what can be done to improve pace in the private sector’ in terms of cladding removal. A consultation on the combustible ban also proposed lowering the 18m threshold to ‘at least’ 11m. The 2019 sprinklers consultation saw the government propose lowering the height threshold for new buildings, with ‘detailed proposals’ to come on how a technical review of fire guidance would be delivered. The programme would require all residential buildings above six storeys to be covered by the new regulator, while those above 11m in height ‘will need sprinklers’. Mr Jenrick stated that the new


regime would apply to all buildings six storeys or taller ‘even when they are below 18m in height’, a change from the government view previously that it would ‘only cover buildings at or above 18m in height’. The plan had been to ‘retain that threshold’ but include any other buildings six storeys or more in height that are below 18m, and ‘in due course, extend to include other premises, based on emerging risk evidence’. From May, MHCLG would


‘effectively ensure’ sprinkler installations in all residential buildings above 11m in height via an amendment to Approved Document B of the Building Regulations, and ‘call for improved and consistent signage’ in buildings to help residents evacuate in a fire. In April, the government revealed all residential buildings over six storeys will be covered by the new regime, while sprinklers will be required on all buildings above 11m. However, Inside Housing reported that the government had made a ‘subtle change’ which will ‘see some buildings fall outside the scope’. The threshold of 18m or six


storeys, ‘whichever comes first’, has been altered to 18m or ‘more than’


six storeys, which the National Fire Chiefs Council (NFCC) said ‘would eliminate a number of potentially at-risk buildings’. Building safety programme lead Nick Coombe stated: ‘NFCC are disappointed that the scope of the new regime has departed from the intention laid out in consultation. ‘The change from 18m or six


storeys whatever comes first to 18m – or “more than” – six storeys (effectively seven storeys) has missed the opportunity to address existing risk. We know there are residential buildings out there which have been constructed around the measuring thresholds in approved guidance in order to avoid certain safety measures. For example, those which have commercial at the ground floor but are only six storeys due to the double height of the ground floor, will fall just short of the threshold. NFCC is disappointed at these lost opportunities.’ He expressed concerns that


mixed use buildings would fall under different safety regimes, adding: ‘NFCC believe that there should be a holistic approach to buildings in scope ie that there is a whole building approach to safety. ‘The current policy, as we


understand it, is that some of the new requirements will only apply to the residential parts of buildings in scope, and the [FSO] will still apply to the non-residential parts. The Housing Act will still apply to the domestic premises, meaning there will be three pieces of legislation governing the safety of the building instead of two. ‘NFCC are concerned that the


safety case regime, which needs to include structural safety, will not apply to the non-residential parts of these buildings. It may therefore be difficult to get a holistic approach to safety, especially where the commercial parts are on the ground floor. The building safety manager will not have any power in these parts of the buildings, again leading to a lack of cohesion in the safety of the building and its occupants.’


www.frmjournal.com JUNE 2020 13


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