Fixed for life

THE RESPONSIBLE Person often sees the fire risk assessment (FRA) as the only piece of the fire compliance “jigsaw”, without fully appreciating other fire safety factors that are equally important in the overall life cycle of a building.

The life cycle of a building can be broken down in to three distinct phases:

• Design – either new-build or refurbishment/extension;
• Construction; and
• Occupation – use and maintenance.

Design phase

The design phase determines how a building can be effectively used. Although post-build alterations can be made, they are likely to incur significant cost and disruption, so it is important that the designers fully understand the project brief and develop a fire strategy based on a realistic understanding of how the building will be used, occupied and managed. This should include occupant mobility, staffing levels and any foreseeable variations in the long-term occupancy.

In particular, the fire strategy should describe the fire safety approach to protecting the occupiers, any limitations on the use of the building and any additional management controls that will be needed for its safe operation. The fire strategy should be reviewed by the client and end-users to confirm it meets the needs of the occupants and has a realistic approach to the ongoing management of the building.

The use of 3D design and Building Information Modelling (BIM), which can influence operational design, often reduces costs, as it facilitates a “right first time” approach. 3D modelling is particularly beneficial in complex projects, such as the fit-out of manufacturing facilities, where the layout of production lines can change several times before a final design is agreed. These models allow the design team to visualise the impact of the decisions they make ‒ for example, the effect that changing the orientation of the conveyer system can have on the means of escape.

Typical failures that can occur at the design phase are:

• The client is too remote from the design team, and the fire strategy is developed with little input from the end-user on the intended use of the building;
• Focus is on life safety when the cost benefits of property protection controls should also be properly explored, through correctly applied cost-benefit analysis;
• The building’s fire strategy relies on management requirements, which clients may not be aware of and were not highlighted to them during the design phase. For example, the design of atria often places the responsibility for implementing strict management measures, such as controlling fire loadings and occupancy levels, on to the end-user;
• The fire strategy relies on particular staffing levels and training, which had not been planned for by the building user. While this may not cause problems in all cases, it’s important that the design team fully understands the client’s proposed staffing levels and that the client is aware of any special training they may need to provide for staff to ensure effective evacuation of the building. The design team should also highlight solutions, which may reduce the number of trained staff required by the building occupiers to manage a site. For example, installing a fire evacuation lift could mean that those with a mobility disability don’t have to rely on trained staff to provide support during an evacuation; and
• Failure to consider fire safety deficiencies in existing buildings. Clients and end-users should make the design team aware of any fire safety issues they have experienced to encourage them to consider how these could be mitigated by the new design. In buildings with high footfall, cross-corridor fire doors can often suffer regular damage through constant use, so simple measures such as installing hold-back devices can mitigate these issues.

Construction phase

Although clients often have much less input in the construction phase, positive interventions can be made, such as overseeing that the building is constructed in accordance with the fire strategy. Clients and designers often believe that once a building has been signed off by Building Control it must be compliant with building regulations and thus fit for purpose.

Unfortunately, compliance with the Building Regulations does not guarantee that the building is fit for purpose, as these Regulations do not consider every possible aspect regarding use and occupancy of a particular building. Additionally, Building Control has only limited oversight through construction, with fire safety just one of many elements of compliance that they need to review. Serious fire safety deficiencies may therefore be missed.

So, occupiers need to be aware that even though the completed works may have a building-control completion certificate, the fire risk assessment may identify significant fire safety deficiencies with the building. These deficiencies may be expensive to resolve and the intrusive nature of the work might cause significant disruption to the building and its occupants.

There is a number of steps clients can take to help avoid construction deficiencies, such as:

• Appointing competent contractors based on the quality of their work, who are able to provide references from and case studies of similar projects;
• Requiring the contractor to keep a photographic record of various phases of the construction – in particular, photos of completed compartment walls and voids, which may not be visible once the building is constructed; and
• On larger scale projects, appointing a clerk of works, who will be able to attend the site regularly to check that the building is being constructed in accordance with the fire strategy.

Typical deficiencies that can occur at the construction phase include:

• Construction-phase design changes that affect fire safety are not fed back to the design team and the fire strategy is not updated to reflect these changes;
• Compartment walls and fire barriers are not constructed in accordance with the fire strategy and the relevant manufacturing standards;
• Service penetrations made through compartment boundaries during the fit-out stage are not managed and suitably fire-stopped;
• Fire safety features that have longer-term benefits are value-engineered out of the design; and
• Fire safety systems, such as alarm systems, do not operate in accordance with the fire strategy.

Building occupation

Once construction is complete fire safety information must be passed on, so that the occupier can make effective arrangements for the ongoing maintenance and operation of the building. This information handover is a requirement of Regulation 38 of the Building Regulations and should be part of the Building Control sign-off procedure. However, the quality of fire safety information provided can range from patchy to non-existent. Indeed, many clients are not familiar with this regulation, incorrectly believing that this information will be included in the health and safety files, which are produced as a requirement of the Construction (Design and Management) Regulations (CDM).

On occupation, the client will need to ensure that a suitable and a sufficient FRA is completed. In simple buildings, the occupier may be able to complete the FRA themselves, but for more complex premises they will need to appoint a fire risk assessor. It is crucial that clients ensure that those appointed are competent and fully understand the use of the building, its occupancy and any management control limitations. Fire risk assessment tenders are often weighted towards cost rather than quality, with FRAs being seen as a “commodity service”. Consequently, the FRA received by the occupier may not consider the occupants and use of the building properly, and contain inappropriate/unrealistic recommendations. To avoid such a situation, clients should use an accredited risk assessor/organisation, where the assessor’s competency is verified as part of a recognised accreditation process.

Similarly, if the fire safety information provided to the building occupier is inadequate, they will be unable to put in place the necessary arrangements to ensure effective ongoing fire safety maintenance and operation of the building. For example, on reviewing the fire safety information provided for a new-build block of flats, the information on the smoke ventilation shaft was no more than a sheet specifying the equipment installed. Key information needed by the client, such as the testing and maintenance requirements of the system, had not been provided, even though Regulation 38 of the Building Regulations requires it to be, as part of the handover process.

Another issue is poor management control over contractors working in the building. This can result in deficiencies in the fire compartmentation, as fire barriers/compartment walls have become compromised. Other issues include inadequate FRAs, i.e. simple inspections or defect lists (against current standards) rather than a proper assessment of the risks.

Sometimes, the fire risk assessor assumes that the existing fire strategy must be suitable and sufficient, or there is reluctance to challenge the existing strategy, even when it does not tally with how the building is being used. For example, in purpose-built blocks of flats, we often find communal fire-alarm systems, which are not required, as they are counterproductive in buildings of this type, which have a ‘stay put’ evacuation procedure. Also, some FRAs only focus on the physical deficiencies of the building and fail to considere maintenance, procedural and training requirements.

So, it is only by considering the actual use and occupancy of a building, along with the realistic manner in which it is to be managed, that a building can be truly described as fit for purpose, with all the pieces of the fire safety “jigsaw” in place.

Paul Lane is associate director of safety, health and quality at Turner & Townsend