Toxicity threats •
External Fire Spread – B4. – ‘(1) The external walls of the building shall adequately resist the spread of fire over the walls and from one building to another, having regard to the height, use and position of the building; (2) The roof of the building shall adequately resist the spread of fire over the roof and from one building to another, having regard to the use and position of the building.’
This regulation does not say ‘it should be reasonably possible to escape from a building in the event of a fire’, and makes no mention of the ability to rescue somebody; only through association with the word ‘adequately’ could you make that indirect connection. Yet the design requirements of Approved Document B of the Building Regulations (ADB) are frequently determined by poorly justified height threshold limits of modern firefighting equipment. Much to my constant frustration, in recent
consultations and responses the NFCC, London Fire Brigade and others have been virtually silent on the issue of restrictions on combustible materials and the challenge of preventing fires. From an engineering perspective, a fire in a high rise/risk building is as catastrophic a failure as an aviation disaster. Engineers aspire to a world where both are eradicated. This vision seemingly isn’t shared by the
FRSs, yet they exert significant influence. The two permanent members of the MHCLG Independent Expert Panel appointed after the Grenfell tragedy to issue guidance to building owners are both former firefighters. The most comprehensive submissions to MHCLG consultations often come from the FRS. They are highly detailed and very convincing, but they mostly relate to how to address fires that have already started. It’s clearly not in the interests of FRS existence or funding to eliminate fires in the first place. The same could be argued for insurance companies, test houses and fire academics with long term funding by product manufacturers. The existence or profitability of all these organisations relies on the existence of fires, and it’s no coincidence that they are resistant or silent on proposals to restrict the use of combustible materials.
Regulations and proposals
Wherever money and regulations entangle there will be failures, whether it’s in planes, satellites, cars or baby powder. We have an important consultation currently on ADB that is crucial for key design criteria, which I believe are consistently raised by those whose opinions I respect. I’ve campaigned for these criteria
requirements for over two years and had resistance from many directions. These design proposals come from different
sources, so can unfortunately come across as ‘alternatives’ – however, when they are combined, they form a coherent and powerful combination. These are the mandatory introduction of sprinklers, non combustible structures and multiple escape routes for buildings over 12m high (MHCLG prefers to define things in terms of storey height to prevent the scope including single storey large buildings). You could argue that I’ve listed these in
order of importance, but the order of the first two depends on whether the fire starts inside or outside the building. These three ‘design’ criteria, I believe, will do more for high rise safety than all of Dame Judith Hackitt’s 53 ‘process’ recommendations. In Wales we have mandatory sprinklers and a combustible ban; in Scotland we have multiple exit routes for buildings above 11m, and almost a combustible ban. In England we only have the combustible ban at 18m. The Hackitt report was a classic civil
service ploy straight out of Yes Minister. We were mollified into thinking that we were getting a much needed independent review of building regulations and fire safety, when in fact what we got was a review of ‘the system’, which is a very different matter. In the words of Sir Humphrey, they ‘deal with the problem in the title, not in the text’. As such, the regulations themselves and those who wrote them (her employers) went unscrutinised.
www.frmjournal.com MARCH 2020 25
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