The declared aim of the USHA Fire Group is to improve fire safety throughout the HE sector and this year it has members involved with 3 government sponsored committees setting legal standards, B.S.s etc. and has addressed 4 major national conferences.
It is working towards becoming the first public sector organisation to certify and register competency of fire safety advisors/officers. The Minister for fire has stated that he supports us in this move.
It is identifying the competencies required to develop training to be delivered via the USHA Training Group. This should ultimately deliver very cost effective consistent standards.
It is also in the process of signing a memorandum of understanding with CFOA (the lead body for the Fire Service)
Fire is perhaps the biggest risk to our institutions. Even with good insurance cover many costs are not recovered, reputational loss is considerable and business continuity is severely impacted.
Enforcement activity and prosecution are far more likely than for most other issues. Everyone in the Fire Service is an enforcement officer and checks are carried out at all incidents and in regular audits (usually annual).
Advisory and enforcement notices do not always take full account of the circumstances and can result in very considerable unnecessary cost. Challenging them requires expertise often not available in our institutions.
Prosecution, although a last resort, is much more problematic. There is an assumption of guilt and the only defence is due diligence. Legal expertise outside of the Fire Service is in very short supply and they have an over 95% success rate!
Its relationship with CFOA should deliver endorsement of the USHA Fire Guidance, lead to a better understanding of relevant HE sector issues and reduce the likelihood of legal action.
Chair of the Fire Specialist Group John Crust speaking at the USHA Autumn Seminar told delegates “Building design frequently fails to deliver the best solutions in relation to fire. Simple compliance with Building Regulations, which are generic and often prescriptive, is very unlikely to be sufficient.
The fire safety legislation encourages creative solutions relative to the actual use and management of buildings but is rarely well understood by building designers.
Without careful consideration of all the issues, a very old saying will inevitably apply:
“In theory, theory and practice are the same. In practice, they are not!” Albert Einstein.
Building designers, even using highly qualified fire engineers, cannot deliver the most suitable designs unless they are fully aware of the fire related challenges present; exactly the same applies to Fire Risk Assessors and ‘Competent Persons’. This is very unlikely unless they are in-house or very well advised.
Resolution of issues at a late stage is a difficult process often resulting in conflict, delays, less than ideal compromise and additional expense.
At best the result is likely to be unnecessary future managerial burden. At worst, unacceptable risk to building users leaving the Institution vulnerable to enforcement activity or prosecution of the institution and key individuals.
The Fire Group recommendations are:
1. Early and extensive involvement of the Competent Person on all fire related issues
This should be throughout the design and build process from concept to completion and at each RIBA Report stage.
The aim should be to achieve a design which allows the Competent Person to ensure that the requirements of the Regulatory Reform (Fire Safety) Order will be met as well as compliance with the Building Regulations such that the Fire Risk Assessment will be complete at handover.
Further, that the Fire Authority, Building Control Officer, Principal Contractor and other relevant persons are consulted on a regular basis throughout, in an open and transparent manner.
We believe these are key to achieving good cost effective fire safety standards compliant with all relevant legislation and avoiding the requirement to address issues at a late stage.
2. Ensure the Supply of an extensive Fire Safety Manual.
The Competent Person should be consulted on individual items of content during the design and build process such that the Manual will be compiled during it and only require minor ‘as built’ amendment at handover.
These ensure that all necessary information is readily available rather than being lost in O&M manuals etc. Compilation during the process is necessary for completion of the Fire Risk Assessment before occupation.
Although a legal requirement under the Building and CDM Regulations and BS9999 these as rare as hens teeth! Please ensure that all contracts require supply.
3. Develop institution specific Generic Fire Design Guides
- Facilitate high standards, best value and sustainability in terms of fire related design features.
- Align the requirements of the Building Regulations, the Fire Safety Legislation, the Institution and their insurers.
- Provide an indication of non-prescriptive preferred solutions and appropriate standards and detail prescriptive requirements where necessary.
They should apply to all new builds, changes of use and major refurbishments including property to be leased. Content may also be useful to advise design in minor works.
We have a working group busy finalising an example document. It is intended to be adaptable to cover local circumstances and building practices anywhere in the UK. It is not intended as a ‘sector directional document’ or for benchmarking purposes.
We have drawn on members to identify the issues for inclusion and provided example solutions in line with Fire Group discussions and guidance.
We have consulted many industry experts and are expecting the final copy to be endorsed by other leading organisations including CFOA.
We particularly invite input from AUDE and hope that you will endorse the final copy. Copies of the latest draft are freely available on request.
The content addresses the common challenges in respect of our institutions including:
Unpredictable and often inflated occupancy due to:
- Open public access or difficulty in controlling entry
- People waiting in corridors for class changes etc.
- Large numbers of people unfamiliar with the buildings:
- Visitors and the general public
- Conference attendees, contractors etc
- Considerable numbers of peripatetic staff, many part time or temporary.
- Staff and students using buildings or areas where they are not normally based.
People who may have difficulty evacuating:
- Most forms of disability including temporary issues such as broken legs etc.
- Young , old and infirm people.
- People incapacitated by alcohol or drugs.
- People with no experience of fire alarm systems.
- Increasing use of headphones, even when sleeping, resulting in not hearing fire alarm sounders.
- Poor evacuation performance.
- Flammable materials and obstructions in escape routes.
- Abuse of fire safety equipment.
- Door wedging
- Use of unauthorised high risk equipment.
- Large student bodies often working unsupervised.
- Contractors for facilities management, security, building works etc. not fully understanding arrangements.
- Designs based on a pick and mix of various fire safety standards.
- Insufficiently explained restrictions, particularly those resulting from ‘fire engineered’ solutions.
- Financial and managerial issues resulting in the need for minimal maintenance, testing and checking workload.
- Common changes of use and responsibility for areas.
- Those specific to student sleeping accommodation
- Designs not conforming to the most appropriate standard.
- Use for conference visitors and the public which requires different standards.
- Limited supervision and enforcement of fire safety rules.
- Extremely varied and unpredictable sleep, work and social behaviour patterns.
- Inexperienced people cooking with unfamiliar equipment (cause of >90% of fires in the sector).
- Extensive and often inappropriate use of electrical equipment commonly including items which do not conform to British Standards.
- False fire alarms; mainly due to cooking with the kitchen door open, steam from showers and use of aerosols near detectors.
Dual means of escape with slopes rather than steps and maximum travel distances to recommended disabled person limits wherever practical.
Avoid the requirement for assisted evacuation where practical: Horizontal escape routes into separate compartments and self operated lifts to evacuation standard.
Expected standard, specification and programming of fire alarm installations and equipment
Staged evacuation with manageable zones and associated compartmentation.
All electrical door closers, locks and hold opens to fail safe in the event of a power failure.
Maximum utilisation of mains powered magnetic hold open devices and free swing door closers; all closers set to within the recommended limit of opening pressure.
Minimal provision of extinguishers positioned for the use of trained people only; 10 year service free units suitable for all classes of fire other than metals and high voltage electrical risks
Third party accreditation of all passive fire protection.
Serious consideration of sprinkler, water mist and other suppression systems, particularly in high risk areas.
In student accommodation:
Automated cooking fume extraction sufficient to prevent operation of corridor smoke detection.
Mains powered tamper proof open door alarms on kitchen doors (have proven extremely effective at reducing false alarms from cooking).
Cooker cut off devices to prevent cooking being left unattended.
Sufficient electrical sockets to negate the need for multi point adaptors on sensitive RCD devices.
L1 detection with sounder beacons including at all bed heads. Bedroom detectors sited such as to reduce likelihood of triggering by aerosols, shower steam etc. Voice fire alarm systems.