Clarity needed on residential sprinklers above 30m

THERE HAVE been a number of occasions recently where our company has been advised by sprinkler contractors/engineers that residential apartments above 30m need to be provided with sprinklers designed to BS EN 12845: Fixed firefighting systems. Automatic sprinkler systems. Design, installation and maintenance, rather than BS 9251: Sprinkler systems for residential and domestic occupancies. Code of practice.

They have given this advice on the basis of their interpretation of the Building Regulations and their view of how the fire risk should be dealt with. However, the Regulations, through the supporting guidance Approved Document B (ADB), do make a number of statements that appear to lack clarity and can cause a degree of confusion with respect to the new recommendation to provide sprinklers in residential above 30m.

Outside the scope of BS 9251?

ADB states that ‘dwellings outside the scope of BS 9251’ should be sprinklered to BS EN 12845. As the scope of BS 9251 is clearly stated as being limited to buildings up to 20m, then some are advising that the systems need to be designed to BS EN 12845.

However, ADB goes on to state that the ‘limit on the scope of BS 9251 below 20m can be ignored’. Therefore, for the purposes of ADB, residential over 30m does fall within the scope of BS 9251.

We have been advised by the Loss Prevention Certification Board (LPCB) that a sprinkler contractor cannot issue an LPCB certificate for a BS 9251 installation in residential over 20m because it is a major departure from the British Standard. ADB does not recommend that a certificate be issued and, therefore, the authorities having jurisdiction will have to understand that they (via ADB) are asking for a system to be installed to a standard beyond the scope to which a contractor can issue a certificate.

It has also been suggested to us that sprinklers in these applications fall outside BS 9251 because the standard states that ‘care should be taken… that the fire/fuel loading in any given occupancy does not exceed that which would normally be found in a residential living room, kitchen and bedrooms’. The point has been made that we cannot control what fuel load someone introduces into their apartment, so we cannot be sure whether this limit will be exceeded or not. But this is the case in all applications; we cannot be sure that someone is not going to store polystyrene packaging in their apartment, but we would not be expected to protect to that level. Therefore, it should be perfectly acceptable to use BS 9251 in the application for typical residential apartments because, as the standard states, they do have a fire/fuel loading of ‘a conventional residential occupancy’.

Extent of sprinklers

ADB states that ‘where a sprinkler system is specifically recommended within this document, it should be provided throughout the building’. But, in relation to sprinklers for residential, the Approved Document states that ‘sprinklers only need be provided in individual flats’. Therefore, corridors in residential developments can be unsprinklered.

Life safety

ADB states that ‘any sprinkler system installed to satisfy the requirements of Part B should be regarded as a life safety system’. Some people are reading this to mean that the life safety requirements of BS 5306: Fire extinguishing installations and equipment on premises are to be applied. BS 9251 states that ‘it covers systems installed for life safety purposes’. Therefore, designing a system to BS 9251 satisfies the recommendations of ADB.

A number of other issues are open to debate in relation to the application of BS 9251, such as the type of sprinkler head, and recommendations for isolation valves and flow switches.

A pragmatic approach does appear to have been taken by some contractors where a zone valve arrangement (monitored isolation valve and flow switch) is provided at each floor level of the residential block (not to each apartment).

BS 9251 does state that the authority having jurisdiction should be consulted with respect to the use of concealed and recessed head sprinklers, together with the alarm arrangements in apartment blocks.

Definitions

It should be noted that BS 9251 is applicable to ‘domestic and residential occupancies’. On the other end of the extreme, some have suggested that we can design a BS 9251 system to operate only two heads, rather than four. This is on the basis that, as long as no single room exceeds 40m², then it would fall under ‘domestic occupancy’, rather than ‘residential occupancy’. This interpretation is based on ADB stating that, for ‘blocks of flats’, only ‘individual flats’ need to be sprinklered. Under BS 9251, ‘individual flats’ fall under the domestic category and only require 10 minutes water storage for two sprinklers operating.

More clarity

Unfortunately, some within the sprinkler industry are increasing the cost of sprinkler protection within residential for their clients, due to their interpretation of the regulations, rules and guidance documents.

It should be remembered that the recommendation on sprinklers for residential over 30m was introduced on the basis of a cost-effectiveness assessment using a system similar to one complying with BS 9251, not BS EN 12845.

Some clarity needs to be brought to this whole issue to ensure that clients, consultants, contractors and authorities having jurisdiction have a clear and uniform understanding of what is required and expected. Consideration should also be given to producing guidance on when an upgraded system should be provided (and to what specification), particularly in circumstances where ‘design freedoms’ are being applied due to the presence of sprinklers.

It would be of interest to know the thoughts and experiences of other readers.

Jon Barrett MIFireE
Foreman Roberts

Smoke detection is better than the sprinkler pipe dream

I AM writing with reference to Nick Ross’s and Ronnie King’s article, Personal and Political, which appeared on p.44 of the February 2008 edition of the journal.

I agree wholeheartedly that only continued political and media pressure will help in further reducing the number of fire deaths. My only concern relates to the focus on residential sprinklers being the solution to the problem. As highlighted in the article, there are a number of technical, practical, cost and legal issues with the provision of domestic sprinklers in existing residential property, and it is in existing properties where the highest numbers of people become casualties.

As a chartered engineer, I try to see the simplest solution adopted first. Fire Statistics, United Kingdom 2005, published by Communities and Local Government, states that, in 2005, a smoke alarm was absent in 203 of the 376 fatal fires, failed to operate in a further 69 cases, and operated but did not raise the alarm in 41 cases. The figures show that the smoke alarm only operated and raised alarm in the remaining 63 cases. Therefore, over half the fire deaths were in houses without working smoke detection.

An analysis of fatal unintentional dwelling fires investigated by London Fire Brigade between 1996 and 2000, by P G Holborn, P F Nolan and J Golt, identified that 54% of all fire deaths were among the retired. The next highest group was unemployed (14%), followed by children (8%). Therefore, fire strikes the elderly and low-income groups disproportionately to the remainder of the population. This is not just a UK phenomenon. The Centre for Disease Control in the USA found a similar trend. Identifying this allows us to determine the ‘at-risk’ groups as retired or low-income persons living in their own home, or in rented accommodation, sheltered accommodation, or local authority/housing association stock.

Dealing with rented, sheltered, and social housing is simple. The Government should simply make the retrofit installation of mains-powered automatic fire detection mandatory, and ensure that an annual operation check is provided, possibly in conjunction with the annual gas safety check. There, of course, would be a cost to private as well as social landlords, and a cost-benefit analysis would need to be done.

The principal problem would be dealing with private houses. To cut energy consumption in the home, almost all councils, as well as many other agencies, now offer free loft and cavity wall insulation to all low-income families, retired persons, and people on certain benefits. A similar free service could be undertaken with regards to the installation of hard-wired residential smoke detectors, with publicity for the scheme provided by both the usual poster campaigns and also by community action groups, such as Help the Aged, benefit agencies and health visitors (especially to the elderly and those with newborn children). Schemes have been undertaken using battery-operated detectors; however, this could be improved by offering a hard-wired service. The impact of retrofitting hard-wired residential smoke detectors will be far less than sprinklers and will have a lower cost, which will be more acceptable to the people holding the public purse strings.

I am not saying that there would not be problems, nor that the ideas put forward here are not simplistic and without cost, but surely these solutions are a far more uncomplicated and cost-effective method of significantly reducing the number of fire fatalities, in a short timescale, than pursuing the sprinkler retrofit pipe dream. Perhaps the smoke detection industry needs to start to lobby harder.

Gary Daniels MPhil, BSc (Hons), CEng, MIFireE
Executive engineer, Hoare Lea Fire

Fire Safety Order leading to confused thinking

DORSET FIRE Service has supported the removal of communal fire extinguishers from blocks of flats because, according to news reports, the public might put themselves in danger by trying to put out the fire instead of evacuating the building. Even though there may be questions about the type of fire extinguisher, this seemingly bizarre policy on such a common piece of fire protection equipment has drawn widespread publicity, causing confusion among the general public and those bound by the Regulatory (Fire Safety) Order.

For example, at a recent Rotary club meeting I was approached by a worried fellow member. He wanted to know how far he, as a minister responsible for several sets of church premises, was supposed to go about his duties of care now. Should he: a) remove all fire extinguishers from the place; b) send all likely staff on training courses; c) send selected staff and insist that church premises may only be used when suitably trained staff are present and so on, bearing in mind that, by ‘staff’, he means church members.

Another Rotary member, a senior nursing officer, said that nurses’ training was to ignore ‘first-aid’ firefighting, ‘even if it was something like a waste paper basket fire’, and to concentrate on evacuation if the alarm was sounded or a fire discovered. No ‘first-aid’ fire training was given.

On the other hand, in a paint factory, when we had a potential disaster with a fire in a paint-making machine, the in-house staff ‘brigade’, who had some training but little experience, extinguished the fire with the help of first-aid measures before the local authority fire service got there. Had we just evacuated, we could well have lost the factory and much more.

Surely this is confused thinking? The Fire Safety Order has not helped because it makes untrained people responsible for decisions, or allows self-styled experts to do the risk assessment job for them, and still leaves them liable in the event of disaster.

What is the responsible person meant to do about fire protection? What are we, as fire safety professionals, doing to help clarify the associated issues?

It is not for the Passive Fire Protection Federation to promote active firefighting measures, but commonsense says that passive fire protection measures are there to provide a safe platform for the use of ‘first-aid’ and active measures. They are not a substitute. Has commonsense gone out of the window as the Fire Safety Order came in the door?

Fire safety should be seen as complementary safety measures working together. A pick-and-mix strategy reduces levels of fire safety if we imagine that different measures can be dispensed with in turn, on the basis of presumed – but unproven – equivalence.

David Sugden
Chairman, Passive Fire Protection Federation

Houses in multiple occupation – the Scottish experience

THE LETTER from Tony Roberts in April’s Fire Risk Management about fire safety standards and how they are enforced in houses in multiple occupation (HMOs) is an area that I, too, am actively involved in. Most of the previously published articles in the journal concentrate on the situation south of the border so, for the interest of readers, I thought that I would outline the system
in Scotland and, in particular, Edinburgh.

When a landlord applies for an HMO licence, as required by the Civic Government (Scotland) Act 1982 Order 2000 (this is where three or more unrelated people live together and share some of the facilities), the local authority arranges for a joint inspection team to visit the premises.

The team consists of members of the fire and rescue service, the council’s Services for Communities department, building control and, in some cases, the police service. Each team member compiles a report relative to their area, and the combined report is sent to the landlord so that they can carry out the necessary works in order for the licence to be issued. To operate an HMO without a licence is an offence. Services for Communities (the enforcing authority for licences) actively enforces this and regularly prepares reports for the Procurator Fiscal.

Section 78 (5)(a) of the Fire (Scotland) Act 2005 determines that these HMOs are ‘relevant premises’ and, as such, come under the scope of the Act. The enforcing authority for most of the Act is the local fire and rescue service.

The main issue in previously submitted articles seems to be the lack of fire safety standards and the enforcement thereof. In Scotland, the Government has published a sector-specific guide, Practical Fire Safety Guidance for Small Premises Providing Sleeping Accommodation, and the scope of this publication covers HMOs that require a licence.

The fire safety benchmarks within the guide include:

• the requirement to carry out and record, in writing, a fire safety risk assessment
• automatic fire detection to BS 5839-6 LD2 system
• fire extinguishers and fire blankets
• self-closing fire doors (with strips and seals)
• limits on travel distances (15m one way and 32m more than one way)

The guide also states that, ‘where it is not practical to reduce travel distance or to increase the number of exits, the provision of an automatic life safety sprinkler system may be considered as an alternative’.

This sprinkler system option has so far been taken up by about 35 maisonettes. One landlord with six properties is currently challenging, through the courts, the enforcement notices issued by Lothian and Borders Fire and Rescue Service in relation to the fitting of such a system to each HMO. The court case is due to be heard in the autumn of 2008.

So, while the standards and enforcement seem, from the articles in the journal, to be causing some concerns in England, we seem to have it under control in Scotland. But, as these HMOs frequently house vulnerable groups, we must not become complacent.

Steven Sansbury BSc(Hons), DMS, MIFireE
Group manager, Lothian and Borders Fire and Rescue Service

Lack of Government interest in the Fire Safety Order

I WAS very interested to read the letter from R J Coates in the April edition of Fire Risk Management. I am curious as to the uncertainty Mr Coates felt in regard to the errors I pointed out in the article by the Passive Fire Protection Federation but, since he was unable to resolve his concerns by discussion with Communities and Local Government (CLG), I would be pleased to provide further information to him if this would assist.

In the meantime, he should not feel surprised or offended by the lack of knowledge and lack of interest that he perceived on the part of CLG. This is simply borne of lack of knowledge and lack of interest! The condescension he perceived was possibly borne of frustration at being troubled by something as trivial and practical as interpretation, in respect of which CLG have abdicated responsibility, along with responsibility for what Mr Coates so eloquently describes as the ‘mess the government has made in its efforts to revolutionise fire safety legislation’. Basically, central government ignited the touchpaper of an explosive restructuring of fire safety legislation. Having done so, CLG now, metaphorically, stand nonchalantly with their hands in their pockets, whistling jauntily and looking in the other direction, while those involved in the practice of fire safety are showered with the rubble of the fallout that, according to viewpoint, constitutes the settling dust before a new dawn of fire safety or indication of imminent structural collapse.

One hopes that, in the forthcoming CLG review of the Fire Safety Order, all such views are taken into account, rather than primarily the views of large businesses, whose views weighed so much in relation to the so-called simplification and rationalisation of fire safety legislation.

Meanwhile, I was also interested in what Mr Coates described as the ‘discernibly different, more clearly defined attitude’ north of Hadrian’s Wall. This, I suspect, has come about for a number of reasons: better clarity of legislation; common, centrally funded training for officers of all eight fire and rescue services at a single centre of excellence, prior to introduction of the Fire (Scotland) Act; continuity of expertise within the res-ponsible government department; common, centrally funded training for fire safety officers prior to appointment; and joined-up enforcement by the eight fire and rescue services, facilitated via a single Chief Fire Officers’ Association region.

Overall, nevertheless, I tend to concur with Mr Coates that the worst is yet to come. As Mr Coates points out, dutyholders who struggle unsuccessfully to meet the challenge of the new legislation risk the censure of the Courts. However, in the event of a worst-case scenario, a committee of inquiry might choose to examine, more broadly and fundamentally, whether the dutyholders on whom the burden has been imposed have been competently and properly served by those who imposed the burden.

C S Todd
Managing director
C S Todd & Associates Limited