BAFE responds to government fire safety consultation
THE ORGANISATION shared its response to the consultation on risk prioritisation in existing buildings, which closed at the beginning of this week.
Last month, Housing Secretary Robert Jenrick announced ‘the biggest change in building safety for generation’, including a new regulator, changes to height limits and new consultations. A call for evidence was published on risks within existing buildings, with the consultation – which was open until 17 February – undertaken into fire safety risks and the combustible ban, including proposals to lower the 18m threshold to ‘at least’ 11m.
BAFE has now reported on its own response to the consultation, with chief executive Stephen Adams having encouraged the sector to review the document and ‘respond accordingly’ last month, as the call for evidence aimed to align with government ‘commitment to conducting a full-scale technical review’ of Approved Document B of the Building Regulations, and also provide advice to building owners and residents.
In its response, BAFE agreed that a ‘case by case risk-based approach should be taken for existing buildings’, noting multiple factors beyond height that should be considered ‘when classifying building risk’. Among these included fire risk and fire protection, BAFE asking ‘what is identified’ in a fire risk assessment (FRA) and ‘what is the current level of fire protection?’
In terms of occupancy meanwhile, it asked whether there are ‘vulnerable residents in the building that would be at higher risk in the outbreak of fire’, and on construction methods and materials - and current means of escape – the organisation queried whether these could be ‘improved in the interest of life (and building) safety’. Finally, on change of building use, BAE enquired whether an FRA has ‘been reviewed/updated’ and if this has ‘changed the fire safety requirements needed?’.
Its belief is that building height ‘is only partially significant when classifying building risk’, noting two ‘clear examples’ of this in the Rosepark Care Home fire in 2004 and the ‘fact that the greatest number of fires occur in domestic premises’. The care home was ‘not a tall multi storey building’, with the fire killing 14 elderly residents, and questions arose as to whether ‘lessons had been learned from this event’.
On the second example, height ‘should be one of the factors considered from the inception of the building design to the ongoing maintenance and risk assessment of any building’, but was ‘categorically not the key factor to classify building risk’. BAFE highlighted that the consultation asked to specify the ‘areas of research on the prioritisation of risks in buildings’ to be considered, and noted that it had ‘without hesitation’ referenced materials.
This, it pointed out, was an ‘obvious answer’ post Grenfell ‘and the evidence that the materials used aided the fire to spread at such an alarming rate’, while competence coincides with this, BAFE adding again it ‘strongly’ held belief in quality evidence of competence, such as UKAS accredited third party certification. In its view, ‘greater emphasis on regulating quality of any provider of fire safety related services working in a building is paramount to improving fire safety in existing buildings’.
Referencing Dame Judith Hackitt’s review of building regulations and fire safety, BAFE highlighted her discussion of the “golden thread” of responsibility, and added that ‘stronger regulation’ such as the aforementioned third party certification of fire safety service providers ‘can aid in establish[ing] a far more competent industry and a safer built environment’. The government consultation had also asked for provision of ‘innovative ideas’ in terms of assessing risk in existing buildings.
On this point, BAFE stated that although third party certification of fire risk assessors ‘has been established for a while now’, it was ‘still seen as a pioneering model to assess their ability to fulfil this task’, and as such ‘needs further discussion’ via the government. This ‘comes back to’ the Hackitt Review’s mention of the “golden thread”, specifically relating to responsibility and accountability.
BAFE concluded that current legislation and the ‘enforcers’ of it, specifically the fire and rescue services, would need to ‘emphasis the importance of competency’ when completing an FRA, and ‘what clearly defines this competency’.