We receive an update from Peter Gannaway on progress in the fire safety management of tall buildings in England and Wales from the perspective of social housing landlords.
IN 2011/2012, the London Fire Brigade attended 786 high-rise fires. The potential for loss of life to residents and firefighters, as happened at Lakanal House in Camberwell, south London, and Shirley Towers in Southampton, is an ever present concern to housing providers who recognise their duty to try to prevent such disasters. In tall buildings, housing providers are on the front line with regard to fire safety, and failure to ensure that the whole fire safety system is maintained is always high on their risk registers and an area for continual debate and action. The National Social Housing Fire Strategy Group (NSHFSG) was established to assist the responsible person, spreading best practice and working with stakeholders in the Fire Sector Federation to improve fire safety standards in housing (see ‘Social evolution’, FRM March 2013, pp34-36).
Defining the risk
While it is useful to discuss fire risk in terms of tall as opposed to high-rise buildings, it is not easy to find agreement on what a high-rise building is. In my opinion, consideration of blocks under seven storeys as low risk would be a mistake. Defining the risk purely as a factor of building height is unhelpful, as it omits other factors. Some consider anything above two storeys as presenting a significant fire risk due to height, even if there are no other resident factors. Use of the term ‘tall buildings’ allows us to consider the individuals at risk at an address and not just the building itself.
We are also required to look at how multiple storeys can affect people most at risk, such as those with disabilities, for whom any evacuation that involves negotiating stairs is problematic. We could claim that height is not such an issue if we consider the impact of a ‘stay put’ policy, where residents are safe behind their own front door if not directly affected by fire. However, the reality for many social and private landlords is that it is not always possible to guarantee in every case that full compartmentation is in place and is providing comprehensive assurance, although it is a goal they all work towards.
Regulation and guidance
Although replacing inadequate systems with appropriate ones has always been a key element of fire safety, it is primarily since the introduction in 2006 of the Regulatory Reform (Fire Safety) Order 2005 [FSO] that this has gained momentum, leading to significant resource consumption in a sector not known for having surplus finances. It will take time to carry out some improvement programmes to ensure that adequate compartmentation and other systems are in place in all tall buildings. However, the problem also extends into new builds, as well as existing stock.
A particular concern is that key elements of fire protection in taller blocks of flats, such as fire stopping, are often incomplete approaching building handover. The preparation of suitable fire risk assessments is often impaired in new builds by developers failing to provide appropriate information under Regulation 38 of the Building Regulations. Although these are required to be provided prior to handover, in reality they could be prepared much earlier, giving social landlords a meaningful opportunity to discuss strategy with the developer.
While current evacuation strategy guidance tends to lean towards stay put policy, landlords need to recognise that simply designating stay put is not an end in itself, but rather a recognition that steps should be taken to implement and maintain measures to ensure the strategy is safe.
Collaboration is key
Collaborative working between landlords, residents and enforcement bodies is the way to improve fire safety, and the NSHFSG believes the introduction of the Primary Authority Scheme is a good example of such working.
Accurate and immediate information for both residents and firefighters was identified as a key factor in fire safety in the Lakanal House coroner’s report and social landlords are developing methods by which risks in residential blocks can be communicated to all relevant parties. It is noticeable how housing providers and local fire and rescue services are now working together to manage risk
in tall buildings.
A fire safety forum for residential tower blocks has been set up with housing associations and local authorities by London Fire Brigade, which is leading to closer ways of working. One example is a project with Barking and Dagenham Council, which recently permitted the Brigade to simulate a fire at Lexham House. These exercises are not just useful for firefighters, but also bring home to housing providers the manner in which fire spreads – particularly where compartmentation has not been maintained.
The need to maintain systems such as emergency lighting, detection and risers has always been well recognised; but the interaction of other factors such as those introduced by residents and maintenance teams and how they may impact on the fire safety of tall buildings was perhaps not so well understood. Over the years, original design standards have been compromised when false ceilings have been introduced or heating and electrical systems changed, resulting in penetrations between communal areas, and flats not being adequately fire stopped.
Social landlords are now increasingly aware of the need to ensure that non-fire safety specialists know how their actions or those of residents can impact on the fire safety of a housing block. Carpenters are increasingly aware of the hazards of poorly adjusted fire doors, and housing officers of the importance of keeping escape routes clear and the impact cladding has on external fire spread. Key to this level of understanding is the production of a suitable and sufficient assessment that examines all aspects of fire risk.
This should recognise not just the physical controls such as compartmentation, detection, lighting etc, and the maintenance of these controls, but also understand how those we are trying to protect can act unwittingly to reduce the effectiveness of our controls – for instance, by removing signage, allowing build-up of combustible materials and interfering with means of escape. While all these factors are hazardous in any building, in tall buildings something as simple as wedging open a fire door to escape stairs compromises the safety of large numbers of residents.
So an additional problem for those in social housing is to determine how to liaise with residents to ensure engagement. The Chartered Institute of Housing has produced an excellent guide, How to communicate with tenants about fire safety, which provides good ideas on this very topic.
Tackling risk assessment
The size of the task to produce detailed fire risk assessments across the portfolio of premises many social landlords manage was only fully understood when they read the requirements in guidance to the legislation produced by the Department for Communities and Local Government (DCLG), which for many seemed less helpful than it could have been.
Introducing a risk assessment programme was a daunting task when we consider that in the 2011 census, 21% of the population of England and Wales (with a much higher percentage in our cities) lives in flats, maisonettes or other properties with communal areas that come under the requirements of the FSO. Many of these can be considered as taller buildings.
In view of the volume of work to be undertaken, housing managers needed guidance with a balanced approach that recognised the current fire protective properties of buildings, while setting boundaries beyond which it was known existing systems simply do not offer the requisite levels of protection.
We now have additional, clearly written guidance supporting a range of differing situations, produced by the Local Authorities Coordinators of Regulatory Services (LACORS), Colin Todd Associates and the Chief Fire officers Association (CFOA), along with subject specific documents such as those prepared by the Association for Specialist Fire Protection (ASFP).
Enforcement visits are linked to risk and many tall buildings rightly figure high on the list of places to visit. Prosecutions arising out of breaches of the FSO have increased and social housing providers are now aware that the fact no fire or loss of life has taken place will not protect them from enforcement action and that obtaining the right assessment is essential.
The risk assessor registers provide confidence to the responsible person that advice given is suitable and proportionate. There are discussions in the press about the merits of each register, but from a sector perspective the common beneficial factor is the requirement for an individual to demonstrate competence to an authoritative lead body before registration. In social housing, we also need to ensure the assessment matches the risks in taller/complex buildings, which require a significant understanding by the assessor of factors behind fire spread and how residents can respond in the event of fire.
Unfortunately, anyone can call themselves a fire risk assessor and the adequacy or otherwise of assessments is often picked up only as part of a fire service inspection or prosecution. A simple internet search reveals many more individuals offering fire risk assessment services than there are registered assessors. We have even heard of companies offering them free with other services or claiming to complete a dozen assessments a day and thus reducing cost. Across all property types, the fire and rescue service has discovered that just under 14% of risk assessments are non-compliant (see ‘DCLG: Fire and rescue Operational Statistics Bulletin for England: 2012-13’, November 2013, p17, Figure 9). We see this as posing a significant risk to public safety.
The FSO was not intended to be a mechanism by which the only valid assessment is that of a consultant. In the beginning, housing associations took two very different approaches to the process. There was an emphasis in guidance on the fact that people didn’t necessarily need external support and could carry out assessments up to their level of competence. A form on the internet encouraged people to do this, although guidance was quite clear on its applicability and the need for people to operate well within their area of competence.
A problem occurs when the responsible person does not have the knowledge to make a judgement on what constitutes competence. The Fire Risk Assessment Competency Council has provided guidance on this, but I believe that many organisations (particularly smaller ones) are not aware of it. I have been asked by a private landlord if I thought he was competent to carry out his own fire risk assessment on a Victorian, four-storey, pre-1891, converted town centre property with basement – he had no previous risk assessment training or experience in fire safety management. My reply was: ‘If you have to ask, you probably aren’t competent.’
The alternative approach was that organisations outsourced all assessments in the belief that they didn’t have the necessary skills to carry out even the most basic review of fire safety precautions on, for instance, a simple modern two-storey block. The outcome was the growth of an industry offering risk assessments without control, resulting in the potential for inadequate systems, unsafe conditions and waste of resources. Even when the assessments did adequately record the hazards and risks, often the documents were not fully understood by the customer and may have been left unactioned.
An essential part of managing fire risk in taller buildings is the implementation of a suitable risk assessment process, but assessment alone may not provide the necessary controls over an extended period of time to ensure systems are maintained and improved upon. It is good to see the release of PAS 7: 2013: Fire Risk Management System. Specification, which goes beyond risk assessment and examines the underlying management processes necessary to implement a fire safety strategy. This is not new to anyone used to working with safety management systems, but the link to fire safety provides a clear and relevant methodology on which to develop a suitable and sufficient management system.
The NSHFSG has been working with the Fire Protection Association, Skills for Justice and CFOA to develop a suite of qualifications in fire safety management for the housing sector. The introductory level award is aimed at non-fire safety professionals, such as those involved in estates inspection and maintenance who may be required to carry out routine inspections of tall buildings. The intended outcome is that unsafe conditions in all blocks are recognised and dealt with at the earliest opportunity.
We are now more informed on fire safety issues, as can be seen in our changed approach to something as simple as missing or damaged door closers – now considered a breach of compartmentation and not just a repair issue. The impact leaseholders have on communal areas is also now better understood when they change their functional but unattractive flat fire door for a shiny new UPVC door that provides little protection. Housing providers appreciate residents’ desire to have an attractive home and therefore, wherever possible, we work with them to produce acceptable solutions.
South Essex Homes is making fire safety improvements in its tower blocks, in consultation with residents. The Callow Mount sheltered project in Sheffield is another example of residents being actively involved in the fire safety process as part of a retrofit sprinkler installation in a multi-storey sheltered housing scheme. For many other social landlords, the necessary financial requirement in tall residential buildings is not as great, but the commitment to ensuring that standards are met is equally strong. It is fair to say that, while all of them recognise the need to introduce improvements, the costs involved mean that resources are prioritised and that in some cases improvement programmes are seen in terms of years, rather than months.
It is clear that the correct risk assessment in tall buildings is an essential element of fire safety policy. To ensure this, social housing providers believe that a simple way of identifying the competence of fire risk assessors, such as the introduction of a fire safe register and improved training for those charged with the daily management of safety precautions, would improve fire safety standards
Peter Gannaway is chairman of the National Social Housing Fire Strategy Group and group safety manager for Paradigm Housing Group.
The initial one-day course towards the Level 3 Award for Reporting Fire Risk in Residential Properties qualification will be provided by the FPA from March
2014. For further information on this course, please contact firstname.lastname@example.org; 01608 812 520