Fire Strategies – Design brief to final design and beyond….

There is not enough clarity around how a fire strategy evolves throughout the building lifecycle or consistency in what it is called at each stage. Traceability of decision making, products and materials is a laudable ambition but there is no guidance on how this will be realised in practice.

As a fire strategy evolves from design, through construction, on to occupation and completion there are multiple stakeholders, each with differing interests and desired outcomes. There are multiple inputs from various fire professionals, each with differing competencies. A fire strategy has many stakeholders from other professions who’s interests vary at different stages of the building lifecycle. An Architect and the design team do not have the same level of focus or interest in how the building will be managed, when compared to the facilities manager or fire safety manager who is going to be solely focused on management. Those that are constructing the building will be less concerned with performance criteria and more concerned with how is all fits together. It is clear that through design, into assurance and as we proceed towards handover there is a huge opportunity to overlay management information which is relevant to each stakeholder. The lack of guidance in this area has lead to a significant lack of consistency in what is included and to what level of detail in each fire strategy report at each stage of the lifecycle. We are inconsistent across the sector on terms and definitions.

Consistency of terms and definitions

If the fire safety profession cannot agree what it calls a fire strategy at each stage, then how is the intended audience supposed to know what they must ask for, and the level of detail to expect? For example:

  • Concept Fire Strategy or Outline Fire Strategy?
  • Technical Design Fire Strategy or Detailed Design Fire Strategy?
  • Fire assurance or fire surveying?
  • As-built fire strategy or final design fire strategy?
  • Fire risk management strategy or fire safety manual, fire management plan?
  • As-built, Final Design, Retrospective, or Forensic Fire Engineering.

Many of these terms are at best applied inconsistently or worse misunderstood and confused. This isn’t helpful.

Design brief, concept, detail and technical design.

The formulation of a Fire strategy is an iterative process. After the first draft, you can make it better as many times as you need and as a living document dedicated to life safety, property protection and mission continuity it should be kept up-to date as the building changes and undergoes any alterations. It is part of a broader fire risk management system, essential for forming the safety case.

The evolution of a fire strategy starts with a design brief then evolves into a concept, detailed fire strategy report then technical design, final fire design and ultimately should result in a fire risk management strategy. When a Fire Engineer is developing a fire strategy it is a collaborative process with the wider design team, and other fire specialists. Together they test it, tweak it, and repeat the cycle with the goal of getting closer to the final solution.

Fire Engineering in the UK has evolved and it has become more complex requiring a range of new competencies. There are clearly three different skill sets and three different areas these fire professionals will have input, which address three different audiences. Strategy formulation and involvement of a team of fire professionals should reduce risk throughout the design and construction process so that a building is fit for purpose at handover, and safe to occupy and use.

Fire safety assurance and pre-occupation safety assessment

There needs to be a clear understanding and agreement of what level of assurance is expected, needed and delivered.  An updated fire strategy at RIBA 5 will take into account things like changing positions of fire-resisting walls to suit final build. It would have performance specification for that fire-resisting wall, but would not state that this wall has been inspected and in actual fact achieves this on site. However fire assurance statements go a step further towards improved control and traceability and confirm that this updated design fire strategy has been implemented correctly in the detailed design and construction. Many developers now want some level of assurance as their responsibility for ensuring correct implementation of fire strategy becomes clear, and the criminal, contractual and tort liabilities in law become more pronounced. The role of the Fire Engineer or Fire Surveyor at late RIBA 4 and throughout RIBA 5/6 is far more significant than a decade ago.

Fire risk management, policy, strategy and procedure.

The management strategy can be developed at any stage, and once again it will be an iterative process, but it would be better updated to suit actual management arrangements once occupied and once the responsible person and all other duty holders are identified.

Fire Strategies can sometimes fail to afford the attention to management that management deserves. That was the title of an article I wrote in 2017. Many end-users still complain that fire strategies developed during design and construction fail to recognise the information needs of the end-user. As can be seen in the diagram above cumulative management input should increase throughout the strategy formulation process until the final design fire strategy work is closed out and suitable and sufficient detail on how the building will be physically and practically managed enables the responsible person or nominated duty holder to formulate a fire risk management strategy.

A need for national guidance?

This is not a call to make the process of fire strategy development prescriptive. Guidance must not stifle innovation. It needs to balance the flexibility to adapt fire strategies to be specific and bespoke to different buildings and modern construction methods. This is a call to improve the consistency of high level terms, definitions and structure. It’s a call to consider the level of detail at each stage. I acknowledge PAS 911:2007 Fire strategies – guidance and framework for their formulation – (Withdrawn Standard). A question arises given the changes that have occurred in fire safety over the last decade, whether we need a new standard to address where we are now.

Is it time we had some new and improved guidance on the formulation of a fire strategy and how fire safety information is gathered throughout the building lifecycle?

We would welcome comments on the diagram above. It’s not perfect and could be improved. We have developed a slightly more complex circular diagram which covers gateway stages, RIBA stages and overlay’s management. This one works better to convey the idea in a post. Does it make sense to you? does it accord roughly with your terms and definitions for the various levels of fire safety information? Would further guidance in a full British Standard be useful?

 

BB7 Launch their New ESG Program – Cycle 7

BB7 is a company founded on seven values and this is enshrined in name, but we are clear that our actions must match our words.  We understand the importance of being a responsible firm, and the way we conduct ourselves, has an impact on society. The shift of focus on ESG (Environmental Social and Governance) policies and procedures has dramatically increased this past decade, and although many firms recognise this, it can often be seen as a challenge to truly adopt practices for a sustainable future.

We, have made a commitment to increase our ESG focus, as we know the interconnected cycle between how responsible we are, and how responsible society is, is the catalyst for a brighter future.

We are committed to maintaining a sustainable business that is socially and environmentally responsible. These commitments have been part of our organisation for some time, but it is important we now increase our transparency to ourselves, our organisation, and our community so that BB7 stands proud, clear, and confident in our contribution.

In 2021 we formed a dedicated team of professionals, led by our ESG champion, Regional Director and Chartered Engineer, Dominic Way to lead a committee focusing on ESG.  They have developed our ‘Cycle 7’ program. The sustainable development goals set out by the UN (United Nations) echo are values and highlight 7 key focus areas for us:

  • Health and Wellness
  • Community Engagement
  • Stakeholder Engagement
  • Talent Attraction and Development
  • Diversity and Inclusion
  • Climate Action
  • Corporate Governance

These 7 key focus areas will set the agenda for coming years, and we will ensure that we make a positive impact in all areas. We are committed to having living actions rather than satisfying an organisational chore. People are selecting organisations based on their ESG agenda because it is so important for the future, and we are engaging in it because it is so important to us.

We believe organisations must support their employees and their wellbeing, which also makes sense financially because we have found a “happy workforce is a productive one” and this is demonstrated in the many studies behind this concept.

Wellbeing is also going to be different for everyone.  Organisations who recognise this will get greater engagement and satisfaction from their workforce. Our Employee Experience team at BB7 have a great focus on well-being with different activities planned throughout the year to support our teams. Our senior management team have also partaken in mental health training to recognise and support anyone in need.

We recognise the importance of our people and the community around us, and our commitment is to act upon our 7 values and ensure that we do everything in our power to have a positive impact on the world around us. We want to be more than just a company with a name, we want to be a force for good.

Visit our Cycle 7 webpage for more information and watch our ESG video. 

 

BB7 Evolution

Brand Evolution

BB7 has and always will be a challenger brand.  We stay relevant, anticipate trends, and embrace innovation.  As we approach our 13th Anniversary it was the right time to look at our brand, and our values and concentrate on the future. With a diverse range of specialist services, we wanted our brand to reflect the evolution of BB7.

Love him or hate him, Jeff Bezos once said,

“A brand for a company is like a reputation for a person.  You earn reputation by trying to do hard things well”.

The BB7 Brand

Consistency is the key to successful branding and how an organisation delivers messages aligned with its core values, brand promise, customer experience, and brand identity elements.

Many companies talk the talk on values, but we walk the walk. In fact, the name BB7 arose because Ben Bradford founded the firm on SEVEN guiding principles which describe what we want to embody and the unique character, spirit, and identity that is BB7. Lots of companies now speak about purpose, values, valuing people, and wanting to become an outstanding employer, but we’ve been doing this from conception and consistently matching our actions to our words for well over a decade.

Our values inspire and guide our people, shaping everything we do. This shines through in all areas of our work – from recruitment and learning through to project delivery and innovation. Our values are the bedrock of our culture. Our unique culture is a hard strategic asset.

The firm has grown over time from a small independent with a single office to a large 150+ person firm with eight offices throughout England, Scotland, Northern Ireland and the Republic of Ireland. This has never been about size, nor scale. This is about leading and as one of the leading independent fire consulting firms in the UK and Ireland, we have reached a level of governance and sophistication that needed to be reflected in our branding, whilst still maintaining our culture and personality. So, we have had a revamp, making minor adjustments to our brand to represent the company we are now.

The New 7

Our new unique 7, is inspired by the world we operate within, mirroring architectural structure to create a bold, confident, structurally simple, and authoritative graphic device. Our company logo remains the same, as it embodies our company values and offers the consistency we desire.

Our Colours

We have also altered our colour palette with 3 primary colours to create a distinctive brand identity, which plays a vital part in building recognition with our clients. A secondary colour palette of blue and green tones allows us the flexibility to offer variety and character when needed.

The Future

We remain an independent consulting firm, focused on fire risk and resilience.  In the coming years, we intend to continue adding value to our clients and our people by being wise and leading. Our brand will continue to embody our unique culture and values.

There will be a lot more to follow on our branding as we go through our journey over the second half of the year and into 2023, so watch this space.

Is ‘Stay put’​ safe, could it be safer and is there an alternative?

In the years following the Grenfell tragedy, ‘stay put’ policy has received criticism, but often based on misconceptions which need to be addressed.

First, let’s consider the alternative.

Simultaneous evacuation is an alternative often put forward, but it presents some difficulties. This strategy is sometimes applied to buildings converted into blocks of flats, but usually only where it has not been possible to achieve the level of compartmentation required for a ‘stay put’ policy. In purpose-built blocks of flats, experience has shown that most residents do not need to leave their flats when there is a fire elsewhere. In some circumstances, they might place themselves at greater risk when they do so. This strategy is less equitable than stay put, when we consider that within the general needs population and that there will be people with mobility, cognitive, and sensory impairments who may require assistance. When thinking about high rise residential buildings, descending via stairs can cause exertion, and this may trigger life threatening situations. Anyone with an underlying health condition, such as lung disease or cardiac problems may find walking down numerous flights of stairs perilous. Vulnerable people within a general needs population such as pregnant women or the elderly may also be put at risk.

Simultaneous evacuation can be achieved by interconnected heat detection so that only a confirmed fire, triggers the alarm. A false alarm from smoke detection, should an occupant burn the toast, is undesirable. Inevitably, this would breed complacency among residents and raise the risk of the alarm being ignored. Heat detection can overcome this, as it is less susceptible to false alarm. However in the event of a fully involved fire in a flat, this increases the criticality of passive fire precautions doing their job because the strategy would automatically encourage occupants to venture out from the relative safety of their flat, into what could be a smoke filled environment and prior to FRS attendance. Passive fire precautions are critical in both simultaneous and stay put strategies. Malicious activation to trigger total evacuation may be a concern for residents and the FRS. Many Housing Associations and Councils are aware of the challenges related to gang crime within inner city areas. Terrorists have used fire alarm systems to evacuate occupants onto the street and then detonate an improvised explosive device (IED). In active shooter situations fire alarms have been used to entice sheltering victims out of safe locations. It’s worth us remembering that some of these locations have security grilles in front of doors to protect vulnerable people in society from gang crime or domestic violence. Fire professionals can look at the fire problem in isolation and fail to see other social issues which pose a greater risk in communities than the threat of fire and affect many people every day.

Simultaneous evacuation triggered by the sounding of an alarm throughout the entire building may also cause unnecessary anxiety or harm to those with mobility, sensory or cognitive impairments that may require assistance and may well be safer, remaining within their flat (like everybody else), rather than attempting to evacuate.

Evacuation lifts can be a solution for mobility impaired occupants and can be incorporated in new builds, but they generally still require someone to operate them at the ground floor or fire service access level, and the number of occupants wanting to use them may lead to congestion and take too long to evacuate – particularly for those closest to the flat of origin. The next revision of BS 9991: 2021[1] will likely include commentary on driver-assisted and occupant operated evacuation lifts. Fire-fighting / Evacuation lifts are of course incorporated into new build fairly easily. Incorporation of evacuation lifts retrospectively across the UK’s housing stock will be a challenging requirement if it were to be mandated, and existing smoke control designs may also need consideration if the evacuation strategy is altered.

A long stated challenge with evacuation in residential premises, stemming from the work on human behavior, from the late Jonathan D Sime [2], is the broad range of human behavior that can be anticipated within the general needs population within their own homes, and how this may effect pre-movement times. Sime highlighted that individuals with close psychological ties will attempt to escape with other group members. “A mans home is his castle”, was the old adage that expresses the fact people enjoy the position of rulers in their own homes and right of entry, or exit is a matter of choice. Some occupants will not evacuate without their pets, or possessions and therefore criticality of compartmentation is fundamental regardless. The most direct reference to human behavior was contained in BS 5588-1 [3] was in Section 31 on fire detection and alarm systems. It noted that common fire alarm systems should only be provided where some control could be achieved over the occupants so that a predetermined response could be initiated.

 

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The ability to manage a fire alarm system is rarely possible in a block of flats unless staffed at all times, eg by a concierge or caretaker. Allowing residents to silence and reset a system is inappropriate in these circumstances. Access to use of these facilities also enables major disablement of a fire alarm system. This could expose landlords and others with responsibility for managing fire safety to liability if, through the actions of a resident, the system is left inoperative and fails to perform correctly in the event of a fire.

It is preferable that evacuations are managed, and in a residential building, there would be potentially no-one to determine if it is safe to re-occupy the building, unless the FRS are called. In high rise residential buildings a simultaneous evacuation strategy poses risks during the evacuation and is less inclusive or equitable than the adoption of a stay put policy for all, and freedom evacuate if able.

Another challenge posed by simultaneous is that the fire service on arrival will be presented with a far more complex situation than they need have to deal with. Occupants evacuating down the stairs, without an assembly point is a consideration. The demands on the handful of firefighters who make up the first attendance will be greater in terms of physical work and command and control complexity. This can only lead to less favorable outcomes. Early intervention to extinguish the fire is critical to achieve the best outcomes in terms of life safety.

Stay put policy

The concept of stay put policy can be traced back at least as far as the beginning of the construction of high-rise residential buildings in the post-war years. The 1962 British Standard Code of Practice 3, Chapter IV, Precautions Against Fire, Part 1 (precautions in flats and maisonettes over 80 feet), [4] provided that:

“The assumption should no longer be made that buildings must be evacuated if a fire occurs, and high rise residential buildings should, therefore, be designed so that the occupants of a floor above a dwelling which is on fire may, if they choose, remain safely on their own floor. It may be necessary to evacuate the floor on which the fire occurs, and in some circumstances those floors which are in the immediate vicinity of the fire, but the occupants of these floors should be free to reach safety in any other part of the building via the staircase.”

In the UK, stay put is ‘Plan A’

One of the basic design principles is that buildings should be designed in such a way so that all people can escape to a place of safety without external assistance from the fire and rescue service. It states this in the current version of Approved Document B: Volume 1 – Buildings other than dwellings 2019 Edition [5]. This is one reason we should keep our focus on making sure ‘Plan A’ works and adopt a defense in-depth (DiD) or layered approach involving both active and passive measures to ensure plan A works and that the outbreak of fire is confined to the flat of fire origin.

The criticality of compartmentation to ‘Plan A’.

Regardless of whether Plan A is a stay put policy, or simultaneous. The integrity of compartmentation is imperative because we a talking about sleeping risk within high rise, and cannot anticipate the range of human behavior which may be expected with people in their own homes. Even if simultaneous is adopted it would be unwise to lose focus on the importance of compartmentation in this use-class of building. Many of those that contest the benefits of stay put and highlight issues with build quality, fail to recognise that in this use-class of building it will still be critical for simultaneous, and we will never be building purpose built blocks of flats without compartmentation due to occupant characteristics.

However let’s focus on the criticality of compartmentation in stay put scenarios which are likely to be the norm.

The prevailing construction material at the time ‘stay put’ was introduced was concrete. In fire, concrete performs well – both as an engineered structure, and as a material in its own right. However, cement production generates around 2.5 billion tonnes of carbon dioxide (CO2) per year—about 8% of the global total. Widespread use of concrete is exhausting supplies of useable sand. Moreover, concrete consumes almost 10% of the world’s industrial water supplies. It is essential that we innovate with other more sustainable materials. It is of course possible to inhibit the spread of fire within a building with other more environmentally friendly forms of construction, but care must be taken during construction to ensure the specification and installation is correct, so that compartmentation is maintained.

In his report on the Grenfell Inquiry [10], Sir Martin Moore-Bick rightly pointed out that compartmentation is a critical factor. Sub-division of the building with fire-resisting construction and the installation of a suitable automatic fire suppression system are typical measures considered by those responsible for designing, constructing and maintaining high rise residential buildings with ‘stay put’ policies. Construction quality is important for all buildings but critical for stay put policy, phased, or progressive horizontal strategies which exit in other use classes.

During construction, quality control is essential. There is a need to ensure the design is realised through the construction process, that the right products are installed correctly and that they perform as intended in the event of a fire.

Hindsight is of course notably clearer, than foresight when considering how well a building has performed. Fortunately, there will be many buildings that are never tested and will not experience fire. What we do know is that the property and construction sector has been complacent regarding the criticality of compartmentation where stay put policy exists, but since the introduction of the Regulatory Reform (Fire Safety) Order 2005 [6], and for almost two decades, there has been an increasing focus on this aspect. There have been a number of developments built and handed over, only to be found with compartmentation issues and then subsequently decanted with residents put up in hotels at considerable cost to the developer, not to mention the cost and disruption caused to residents themselves. Since 2016 there has been a steady increase in demand for fire assurance services throughout the construction process which is testimony to the fact that many residential developers are now taking this aspect and indeed external wall safety, far more seriously than ever before.

A layered approach to plan A.

Amendments to the Building Regulations in 2018 concerning Regulation 7(2) [7] which states that “building work shall be carried out so that materials which become part of an external wall, or specified attachment, of a relevant building are of European Classification A2-s1,d0 or A1” are probably the most impactful change to UK fire safety so far and in fairness to the UK Government they acted quickly and decisively on this. Now all buildings over 11m in height are to be provided with sprinklers which compliment the compartmentation requirement because they control or extinguish a fire. A NFSN/CFOA report [8] in 2019 indicates the performance effectiveness of sprinkler systems was 99% across all building types. The latest BS 9251:2021 [9], adds more resilience to the design with backup power supplies and many Fire Engineers are now specifying enhanced smoke ventilation. So plan A has become even more robust and there are not many more tools in a Fire Engineers arsenal that can be used within high rise residential. Changes proposed to ensure greater competency and control, plus penalties for contraventions will all help ensure a layered approach to Plan A, continues to work as national fire statistics have proved so far.

Proof of concept – ‘Plan A’

In the words of Sir Martin Moore-Bick “Compartmentation has thus been an essential feature of the design of high-rise residential buildings for over 50 years and the “stay put” strategy, which is integral to that, has in general proved to be sound (although there have been important exceptions, such as the Lakanal House fire)”.

This accords with the guidance contained within the LGA Guide – Fire Safety in Purpose Built Blocks of Flats [11] which states “This principle is undoubtedly successful in an overwhelming number of fires in blocks of flats. In 2009-2010, of over 8,000 fires in these blocks, only 22 fires necessitated evacuation of more than five people with the assistance of the fire and rescue service”.

BS 8629 2019 – Evacuation alert systems for buildings containing flats [12] also states “The success of this strategy is well established. Every day in England, around 20 – 30 fires occur in blocks of flats, but the need for occupants of flats, other than that in which the fire occurs, to evacuate is very uncommon”.

Our National Fire Statistics [13] paint a compelling picture that accidental fires are becoming a rarer occurrence and the long-term picture shows that the total number of fires attended by FRSs year ending March 2021 was the lowest figure recorded since comparable statistics became available in year ending March 1996. It is reported in these statistics that 518,263 incidents were attended and fires accounted for 29% of this.

 

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The development of a high rise residential building with a ‘stay put’ policy should be considered the ‘norm’. However, we should remain vigilant and not place total reliability on historical data. It is possible for an outlying ‘black swan’ event to occur. The different Risk Assessment types 1-4 which have been undertaken since the publication 2011 Local Government Guide will, if carried out correctly, provide some level of assurance and legal requirements contained within Articles 9,11, 17, 21 and 22 of the Regulatory Reform (fire safety) Order 2005 all support this risk mitigation effort. An interpretation of this legislation can be found in the Enforcers Guide (2015) [14]

Common misconceptions about ‘Plan A’

There is often a misconception that should plan A (stay put) become untenable or even undesirable that this must be an indefinite strategy, maintained during a fire even when its apparent that the situation has, or may become, untenable in some parts. Of course not. It has always been the case that residents can choose to evacuate if they are able, and buildings should be suitably designed to facilitate this option.

“It has always been the case that residents can choose to evacuate if they are able”.

The LGA Guide – Fire Safety in Purpose Built Blocks of Flats [11] states “It is not implied that those not directly involved who wish to leave the building should be prevented from doing so. Nor does this preclude those evacuating a flat that is on fire from alerting their neighbours so that they can also escape if they feel threatened”.

Should a resident see or smell the products of combustion, should they hear fire or sense an impending emergency they can evacuate if they choose to. Just as a man’s home is his castle, a resident is free to exit at will.

If remote from the fire, are not in danger, and not aware of any danger then it also states: “All other residents not directly affected by the fire would be expected to ‘stay put’ and remain in their flat unless directed to leave by the fire and rescue service”. This has always been plan B and the idea of plan B is not new news. The fire service can and should intervene as necessary.

Fire Service intervention – Plan B

Fire service intervention was always the plan B. If, on rare occasions, the fire and rescue service consider that occupants of other flats do need to evacuate, they will alert these occupants simply by knocking on the doors of their flats. This is only likely to apply to a small number of flats, and so is, normally, readily manageable. On even rarer occasions there may be a need to encourage a full simultaneous evacuation of a building and an evacuation alert system can be included. So there should always have been a plan B and an evacuation alert system for fire service use. as per BS 8629: 2019,[12] may in some circumstances be useful addition to the strategy in order to instigate plan B.

BS 8629: 2019 [12] alert systems provide the fire service with the ability to evacuate a building floor by floor. This selective evacuation strategy means that only those who may be in danger can be evacuated, which minimises the problems the fire service face with occupants in the stairs, and minimises the hazard caused to occupants taking part in an evacuation. It would be rare indeed for it to be necessary to evacuate occupants on the floors below the floor of origin.

Could stay put be made safer?

As highlighted in an article entitled Fire Safety’s Misinformation problem,[15] if Grenfell Tower was a building with cladding of limited combustibility and sound compartmentation then, as has been our experience since Post-War Building Studies, the stay put evacuation strategy could have worked and the fire may not spread further than a few apartments. It is clear stay put (plan A) should not have been an indefinite strategy and there was a lost opportunity to change tactics and execute a plan B earlier. Changes are being made by Fire and Rescue Services.

Plan B is the area of focus. Sir Martin Moore-Bick concluded that “the knowledge that high-rise buildings are constructed on the basis of effective compartmentation itself created a barrier to thinking about evacuation”. He went on to make a number of recommendations. The Government, Fire and Rescue Services and Fire Industry are now considering the the practicality of these recommendations.

At the time of writing, we are informed that fire and rescue services have already begun implementing these recommendations and evacuations managed by the fire and rescue service have been performed using smoke hoods.

This article has highlighted a number reasons why a ‘stay put’ policy is still be preferable over a simultaneous evacuation within new build and existing high rise residential buildings throughout the United Kingdom, where a layered approach to passive and active fire precautions is in place, to protect people in their own homes. A layered approach to plan A is critical and there is robust, enforceable legislation and supporting guidance in-place to support this. Compartmentation is critical regardless of stay put or simultaneous within this use-class of building. Stay put is preferable when thinking about safe evacuation or rescue of mobility impaired persons. Plan B (Rescue) should be effected by the fire and rescue service as enshrined in the Fire and Rescue Services Act 2004 [16]. The ban on the use of combustible material, requirements for sprinklers above 11m, and now that the Building Safety Bill received Royal Assent and became an Act of Parliament on 28 April 2022 [17], it will usher in the biggest swathe of regulatory changes to the UK built environment in almost 40 years.

Physical fire precautions have constantly evolved and improved over many years, in response to lessons learnt from past fires and as a result of advances in technology. Thus, serious, multiple fatality fires are less likely now than at any time since the industrial resolution. Public perception of risk and risk tolerance where fire is concerned is probably at an all time low. There are a number of explanations for why the perception of risk is not based on these rational judgements. These reasons include: systematic biasing of risk information, the use of mental shortcuts, and the way that risk information can be presented.

Whilst the term ‘stay put’ policy can be misunderstood. In a well designed, constructed, managed and maintained building, stay put as a concept is safe. There are things we can do to make it safer, but one out, all out simultaneous evacuation (the alternative) is not as safe when considering high rise residential buildings and occupant characteristics one might reasonably expect.

Ben Bradford

Chief Executive for and on behalf of BB7 Group Limited

This article is not intended to tackle assisted evacuation of mobility impaired persons by family, friends, neighbours or the fire and rescue service. Nor does this article tackle, why single stair buildings can be designed, engineered and occupied safely, but how public opinion may shape national design guidance. The next two articles will tackle these important and topical conversations. This newsletter is all about the betterment, upward trajectory and evolution of building safety. We hope it stimulates professional debate.

If you would like to speak to us about any of the issues raised here then please leave your contact details here.

 

Fire safety’s misinformation problem.

At a time when many residents in high-rise accommodation do not feel safe, and thousands of people may be suffering from psychological trauma as a result of the Grenfell Tower fire, is the trauma being amplified by misinformation in the media and ‘newsjacking’ on social platforms?

In the five years post national tragedy that was Grenfell Tower, I have lost count of the number of times I have felt anger at the misinformation being propagated by journalists and so-called fire or safety experts. Misinformation is usually disseminated without harmful intent, but some of these stories promoting misinformation, often of a sensational nature, created to be widely shared or distributed for the purpose of generating revenue, or promoting or discrediting a public figure, political movement, company, etc. It is disappointing that some of the UK’s foremost experts in fire safety, in Government and the profession, who have given much of their time voluntarily in the public interest to standards making and the profession have been the subject of spurious and defamatory attacks by the national press or by populist conspiracy theorists. The Independent’s article “Anger as expert who wrote pre-Grenfell fire safety guidance handed £210,000 contract to update it” created a reaction among disability campaign groups and stir on social media platforms. There was indeed anger, but the premise of that anger was based on a misapprehension.

We have seen numerous fire related articles from Inside Housing over the years which have been erroneous and factually incorrect, but disappointingly an article in the Guardian with a headline “Tower twice Grenfell’s height planned nearby with single staircase” led to the withdrawing of projects, based on fear from planners that they will be criticised, based on ill-informed public opinion. This article disseminated vague information, not relevant or reflecting the real construction industry issues, or even the correct fire safety issues. This is probably based on a lack of fire knowledge from the journalist and/or the lack of a competent source with fire design knowledge. The conclusions drawn by the journalist could be dangerous and harm the industry, creating unnecessary panic or concern for occupants living in single stair buildings. Whilst criticism is useful, for such criticism to be valid and help the construction industry to improve, it should be based on a rational analysis of the facts backed up by suitable scientific evidence, statistics and appropriate competency / experience in the field, and should therefore come from competent people with a specialism in fire, if that is the subject matter expertise required.

A paper written almost four decades ago, by Margaret Law and Paula Beever of ARUP Fire in 1984 (See Endnote) highlighted that public opinion can drive decision making and hamper rational analysis following a fire disaster. It seems we are going on the same journey and whilst it was to be anticipated, it’s frustrating, disappointing and not in the public interest.

Misinformation in the fire safety arena is often amplified post Grenfell by those that purport to be experts, but don’t have a grasp on what they claim to be teaching. It is easy to see how journalists might be fooled into thinking their source is a genuine expert because some of those willing to speak, believe themselves to be experts and neither the journalist nor the source fully appreciate that:

  • They might not understand the system and subsequent systemic failings, or have not developed a fire strategy or worked in fire safety design, engineering or assurance and are speaking on that subject.
  • They might not understand the system and subsequent systemic failings or have not undertaken a fire risk assessment or worked in fire assurance, or fire risk management and are speaking on that subject.
  • They might be someone on the fringe of the profession with beliefs that are founded on misconceptions and out of kilter with most genuine experts in the field.

No-one should be silenced of course, and all voices should be heard. We should break down silo’s but we should also seek a rational balanced analysis of the facts, because misinformation is not in anyone’s interest. There is an expertise vacuum on social media platforms because many of those with appropriate expertise, have been sourced for expert work and must not prejudice the work they are doing elsewhere. On the subject of culture change and public trust, journalists could and should do more to check that they are speaking to someone with a strong pedigree in the subject matter, that other experts consider to be an expert. Sometimes they are speaking to someone on the fringe of the profession with questionable knowledge or experience in the subject matter. This can amplify misinformation, and when presented as fact, creates ministerial discomfort and unnecessarily alarms the public. Simple checks and balances could reduce this, vetting as if someone is applying for a job. Obvious questions like do they have a relevant qualification in fire? have they any experience doing fire work? If they have had more roles than hot dinners, have worked with other fire experts or in any of the well known professional companies in the space. These experts are not always opportunistic and morally unscrupulous individuals; they can be people that simply fail to understand the boundaries of their own competency and are confident speaking publicly on an area associated with their expertise but not an area they are expert in. The practice of ‘news-jacking’ sensational news headlines and posting on social media for their own self-promotion without a rational analysis of the story, is lazy and adds very little to the debate.

There is an expertise vacuum on social media platforms

The National Union of Journalists, code of conduct has set out the main principles of UK and Irish journalism since 1936 and the first four points resonate.

  • At all times upholds and defends the principle of media freedom, the right of freedom of expression and the right of the public to be informed.
  • Strive to ensure that information disseminated is honestly conveyed, accurate and fair.
  • Do her/his utmost to correct harmful inaccuracies.
  • Differentiate between fact and opinion.

Real experts focus on their field, not themselves and have no trouble saying: “I don’t know”. They demonstrate intellectual honesty, show intellectual curiosity and know when and how to share. Real experts cannot help but teach, because they want to explain their knowledge to the layman in plain English. They understand the two-part concept of risk, appreciate that it can never be reduced to zero and consider proportionality when developing mitigation measures. Real experts understand the public are rightly angry over the tragedy and emotions are running high. They understand that some of the issues being discussed are complex and ultimately when thinking about solutions it is the public that will pay for them in house prices, taxes and the cost of living. Those in Government must remember there is no pound easier spent, than the pound that is not their own, and therefore we must always do a cost benefit analysis to ensure we achieve the biggest safety bang for our buck. How safe is safe enough? How much safety does the public want and how much are they prepared to pay for it? Real experts act in the public interest and stick to the facts, regardless of public opinion they want to find the root cause of each systemic failing. They do not indulge in sensationalism, baseless conspiracy theory, news-jacking and scaremongering. They also acknowledge that the public trust must be re-built. The public trust is vital and we must earn it.

Real experts have empathy and are capable of seeing with the eyes of another, listening with the ears of another, and feeling with the heart of another and so they do choose their words wisely because they know their words have meaning. There is a lack of empathy in false facts, scaremongering and sensationalism created by misinformation, and it is this culture that needs to change. Of course, it is important that the public are informed, all voices are heard and that all stakeholders listen to understand, but as a fire professional its disappointing to read sensational headlines stirring up those that hold a deep suspicion for the prevailing establishment and seek to frame a national tragedy as a battle between the people and a nefarious or corrupt elite. This is nonsense, untrue and unhelpful. The counter accusation is of course that within the profession there is a tendency towards protectionism, preservation of hierarchy and the status quo. I’d take rational analysis from an expert, passionate about his or her profession, over conspiracy theory and false facts, any day.

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Systemic failures.

When multi-fatality fires occur, history has shown there has usually been multiple failings that come together with tragic consequences. Individuals are too often assumed to be at fault, when the “system” itself may be implicated in the problem. When systems fail, the public are usually fed a rotten argument: “It’s only one bad apple”. An individual acting alone presents an easy target for media scapegoating. Dame Judith Hackitt correctly identified the systemic failings from the outset and the inquiry is now thoroughly examining every aspect of the system to correctly identify each and every failing with numerous public bodies funded by the taxpayer, not-for-profit organisations and large private companies. I do not envy those that are being called to give evidence and there is no doubt in my mind that this tragedy has triggered a watershed moment and will ultimately lead to lasting change. We should remember that a criminal inquiry will likely follow the current public inquiry.

On the subject of expert opinion. Here is a selection of ten truths that are quite often being ignored in the current debate.

TEN SIMPLE TRUTH’s

1) It is clear that Grenfell Tower would not have satisfied the functional requirements of the Building Regulations applicable at the time of the refurbishment, which points towards a systemic issue within the construction process and around competency and control.

2) It is clear that both the cladding and compartmentation at Grenfell Tower were neither suitable nor sufficient and resulted in fire and smoke spread beyond the compartment of fire origin and involved multiple compartments which tragically resulted in multiple fatalities.

3) Had the refurbishment of Grenfell Tower, incorporated either limited or non-combustible insultation/cladding and been afforded sound compartmentation and an operational smoke ventilation system, fire spread beyond the compartment of fire origin would have been significantly less likely, and survivability improved.

4) If Grenfell Tower was a building with cladding of limited combustibility and sound compartmentation then, as has been our experience since Post-War Building Studies, the stay put evacuation strategy could have worked and the fire may not spread further than a few apartments. It’s clear stay put should not have been an indefinite strategy and there was a lost opportunity to change tactics.

5) Sprinklers may have extinguished the fire before it took hold, but sprinklers would not have extinguished a fire on the outside of the building and if internal, the sprinkler system would not have been able to cope with the demand from multiple compartment fires over an extended duration.

6) All occupants should have the opportunity to evacuate should they wish to do so, and that includes people with limited mobility. The question causing the most contention at present is not in contention with this. The question is how? How can that be physically and practically managed and are any reasonable adjustments that are required proportionate to the risk?

7) Had the entire façade not been ablaze due to unsuitable insultation/cladding, and compartmentation resisted the spread of smoke or fire, mobility impaired persons would have been safe in their apartments, and could have evacuated if able or assisted.

8) Residents in high rise accommodation do not feel safe but the risk to any individual of being involved in such an event is extremely small and that standard of safety is now being greatly improved nationally.

9) The public inquiry is investigating the systemic failings that have occurred, scrutinising past decisions and events. There are many lessons to be learnt.

10) Our legislation and national guidance is being improved based on lessons learnt and the number of fire fatalities in the UK is likely to continue it’s declining trend.

There is a chance that an ‘outlying’ event may occur in future should multiple failings come together simultaneously and cause tragic consequences. However the likelihood of this happening is being reduced through tightening of legislation, improvements to national guidance and a focus on competency of all stakeholders in the construction process. Risk management is not a zero sum concept; it’s a two part concept comprising of likelihood and consequence and cannot be reduced to zero. An intelligent, proportionate approach to fire safety design, engineering, assurance and risk management is very much in the public interest and for this we will need the advice of real experts and a little less misinformation and conspiracy theory, alarming the general public, drumming up fear as thousands come to terms with the psychological trauma, of an event that must never be repeated.

The survivors and bereaved families from the Grenfell Tower fire are right to demand justice and change in memory of 72 who died. We sincerely hope the Grenfell Enquiry delivers this and will continue to work tirelessly towards a safer, more secure, resilient future for all.

Ben Bradford BSc Hon’s MSc MBA CEng PPCABE FIFireE FRICS

Chief Executive for and on behalf of BB7 Group Limited.

Endnote – Written by Margaret Law and Paula Beever, ARUP Fire in 1984.

International Association on For Fire Safety Science (IAFSS) Paper 21. Magic Numbers and Golden Rules.

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NOTE: This opinion piece, has been written and reviewed by independent fire professionals passionate about the profession and the public good. We do not manufacture, install, maintain or specify products. We sell three things of value: Experience, Expertise, Efficiency. Our advice is based on a rational analysis of scientific and engineering principles combined with a knowledge of legislation, national guidance and standards.

As professionals our duty is first and foremost to the public good and we are quite clear that a ‘no’ uttered with conviction is better than a ‘yes’ uttered merely to please.

The Professional Advisory Board

The Professional Advisory Board

A national tragedy has amplified the amount of fire safety information in the public domain, There is an abundance of misinformation and it is clear that information is not knowledge. In many ways, we are drowning in information but starved of knowledge. Knowledge is like money: to be of value it must circulate, and in circulating it can increase in quantity and, hopefully, in value. The pragmatic principles of knowledge sharing from our perspective are quite simple;

  • Knowledge must be shared in the moment to be relevant
  • Knowledge sharing is a competitive advantage
  • Knowledge sharing happens when information flows throughout the organisation, cross-functionally and across locations
  • Knowledge sharing creates a culture of learning
  • Knowledge shared is Knowledge squared.

Our core idea at BB7 is “To become the ‘wisest’ player in those markets within which we choose to operate. Wise enough to be able to consider the bigger picture allowing us to improve and learn. Wise enough to challenge the way things are done”.

Therefore knowledge sharing is not a new concept. In fact with over 100+ technical experts within BB7 Group, our technical teams chat group is indeed a lively forum. Our mission is simple: “To create value for clients and our employees by being wise, and in doing so, become the leading independent specialty consulting firm in the United Kingdom and the Republic of Ireland”.

To achieve this, we must remain a practice-based business, as opposed to a business based practice. We must also ensure we capitalise on our intellectual and knowledge-based assets. There is much more to this than simply having a lively TEAMS chat. It’s a systematic approach too:

People – Our program increases the ability of individual professionals within the organisation to influence others with their knowledge.

Processes – We have established best practices and governance for the efficient and accurate identification, management and dissemination of knowledge.

Technology – The technology we are adopting will enhance our service. We are configuring tools and automation to enable knowledge management.

Structure – Our organisational structures facilitate and encourage cross-discipline awareness and expertise which crosses borders and boundaries in the geographies we operate in.

Culture – We have established and are cultivating a knowledge-sharing, knowledge-driven culture for long-term success.

Our Professional Advisory Board

Our Professional Advisory Board is a formal committee within our management structure and has a decision-making role. Its role is to advise members of the Board on technical matters. Made up of a collective of minds of the different services within our portfolio, the Board meets regularly to discuss technical matters and encourage an expertise-sharing environment. Its overall purpose is to ensure we regularly consider four lines of sight i.e. foresight, insight, oversight, and hindsight, and to ensure we remain at the forefront of the profession. We also invite external stakeholders such as clients, insurers, academics and subject matter experts as appropriate.

We have been fortunate to have had input from Government bodies, Academia, Manufacturers, Technology partners, and other Fire professionals internationally.

Chaired by our Director of Quality and Chartered Engineer, Dave Quinn, the PAB will push the boundaries, challenge the accepted wisdom to ensure that we create safer spaces for future generations. Promoting our profession and becoming ambassadors not only for BB7 but also the wider engineering community.

The PAB provides direction to a number of Technical Networks to bring together those within BB7 who have the expertise and knowledge to discuss, debate, and deliver technical excellence within their field. These Technical Networks include a Fire and Smoke Modelling Group, A Structures Group, an External Walls Group, a Passive Fire Protection Group and much more. They provide opportunities for all of us to enhance our individual and collective knowledge together in each of these areas. By working collectively across England, Wales, Scotland, Northern Ireland and The Republic of Ireland these Technical Networks the team can ensure that efforts are coordinated and focused on the areas that will have the most impact on day-to-day project delivery, both today and in the future.

The work driven by the PAB, and supported by the Technical Networks will challenge the status quo, and ensure that we remain at the forefront of our profession. It compliments our BB7 Learning Lounge initiative which ensures our professionals are provided with an abundance of high quality Continuing Professional Development (CPD) to satisfy their competency obligations with Professional Institutions. The PAB continually refreshes and re-vitalises our service portfolio, and standard scopes to ensure they remain relevant to our clients needs, and it provides overarching governance and control to our fantastic Graduate Development Programme which is there to help grow and inspire our apprentices and graduates who will benefit from our systematic approach to knowledge sharing, our learning culture and our lazer like focus on quality.

‘As engineers we have an obligation to society. The PAB and its Technical Networks help us focus and coordinate our efforts to maximise our impact on improving the safety of our built environments whilst at the same time helping to make them great places to live, work and play.‘
We are creators of safe spaces, where people, business, and communities thrive.

Discovering Work-Life Integration

We are all tired of hearing about work-life balance and failing to understand what this truly means. We are now in a working world where the two are not separate anymore, they are integrated. Spaces in our homes that used to host a plant, or play area for the children are now our new office spaces, and collecting children from school or fitting in appointments has become so much easier!

So what next for employers and People Management teams?

We, as employers and people management teams, are responsible for making this new approach work. This begins with the basics:

  • Changing the mindsets of line managers.
  • Communication – at its best!
  • Understanding, and willingness to change and seek improvement.
  • Remaining current, and fluid.

Fluid is a word I use often with my team and the wider company. We need to understand that life is not a clearly defined black & white structure, it’s grey and full of surprises, and we can use this to our advantage to nurture the engagement levels of our teams. Who said that working 9 – 5 was the most productive use of time for every employee? We are all different, and that should be celebrated, and respected.

Research

Vast amounts of research on work-life integration have still had relatively little impact on workplace practice, and work-family conflict remains a regular hot topic on engagement survey results. I have read many articles, many explaining that work and home life should now complement each other, without losing aspects of one or the other, but instead creating synergies to achieve the best outcome. Professor Friedman’s solution proposes thinking about your work and personal lives as two parts of a whole. With this theory in mind, it is clear that both employees and employers must adapt to achieve work-life integration.

work and home life should

complement each other

Although interesting, I cannot find any tangible research that offers direction, so that is what I have set out to do.

 

Direction to a successful work-life integration

We have mentioned earlier in this article that we do have to start at the basics, and although they are basic tasks, they do not have basic goals. Changing mindsets is very challenging, we must appreciate that different generations in our workforces have been exposed to different working conditions and there is no magic switch to change the way people see work-life. Line managers will need time to fully understand, digest, and implement this new way of working and thinking, they may even demand evidence to prove the success before fully buying in so be prepared! This of course is always difficult in a people management discipline, but running targeted ‘work-life’ pulse surveys on engagement is a good start (roughly every three months). The information gathered in these exercises is extremely valuable to line managers offering them insight into their team’s views, opinions, and voice.

Next, it’s about remaining current. Work-life is changing so quickly, week-to-week sometimes. People management teams need to ensure they are seeking knowledge expansion in this area at every opportunity and communicate this back to key stakeholders and line managers to encourage buy in and fluid thinking. Understanding the changing mindsets of employees is critical. I learned recently that everyone has a different expectation in this area – I asked my team if they would like to trial flexible working, and perhaps a 4-day week, but a week later I had feedback to say they like the way they work currently and it works with home commitments. Although at first I was surprised I could fully appreciate this feedback and it made me change direction. This is not about finding a ‘one size fits all’ approach, which in fact is fairly lazy management, this is about understanding people are individuals, in different stages of their lives, with different home life commitments and demands. What works for one – will NOT work for another.

Then lastly we need to consider policies and the issue that policies are not fluid. Here at BB7 we have implemented a hybrid working guide, and it is simply that. It is a guide to offer insight into company expectations which align to a more flexible approach to work. Our industry is demanding, and our clients expect a high-quality service, and we want to give them that – but we do know we can still provide that high-quality service with some flexible and fluid working arrangements. Doing the school pick-up, or attending an appointment will not have an effect on our delivery for many reasons:

  1. We set clear expectations and role definition to ensure our team knows what their output should achieve.
  2. We expect line managers to manage resources effectively via exceptional communication – that is what they are paid to do!
  3. We have a ‘one team’ approach – we help each other and step in to support, guide and help when it is needed.
  4. We have to adapt to find a new way to connect. At BB7 we have started small, but we have changed our Teams icons to our photos so we can familiarise ourselves with all colleagues, and we run photo competitions where our pets often make guest appearances, closely followed by our children!

Employers and people management teams are taking exciting steps in a journey of discovery and implementation to encourage and embrace work-life integration, but we do need to continue to harness the value of face-to-face (person-to-person) collaboration and communication; but also hold an appreciation for our office spaces which home bonds, relationships, friendships, and organic learning. Having a designated workspace away from your personal life and duties, not only creates a physical barrier, but a mental and social one as well, so let’s aim for the best of both worlds.

Discovering work-life integration, and fully understanding the concept, has been an exciting journey for my team and I. I have personally found it fascinating how many people are ‘creatures of comfort’ and enjoy routine, and this is absolutely fine if that works for them. I have moved away from trying to find a solution for all, and instead focus my efforts on finding solutions for individuals. I know this will take time, but I also know the overall outcome will be worthwhile!

Being Wise – Our Core Idea Explained

Our core idea is:

“To become the ‘wisest’ player in those markets within which we choose to operate. Wise enough to be able to consider the bigger picture allowing us to improve and learn. Wise enough to challenge the way things are done”.

This sets out our core ideology, and in this article, I will set out in more detail what this means and how it forms the basis of our mission. Our mission is simple:

“To create value for clients and our employees by being wise, and in doing so, become the leading independent specialty consulting firm in the United Kingdom and Republic of Ireland”.

 

 

Core Idea

To become the ‘ wisest’ player in those markets within which we choose to operate. Wise enough to be able to consider the bigger picture allowing us to improve and get better. Wise enough to challenge the way things are done.

Our Mission

To create value for clients and our employees by being wise , and in doing so , become the leading independent speciality consulting firm in the United Kingdom and Republic of Ireland.

Professionals

At BB7 we focus on the issues our professionals need to solve and become experts within , to offer clients a safe marketplace , inspire confidence and maintain the reputation of our profession. A professional is a member of a profession or any person who earns their living from a specified professional activity. The term also describes the standards of education and training that prepare members of the profession with the required knowledge and skills necessary to enable them to preform their specific role within that profession. To most people , acting like a professional means working and behaving in such a way that others think of them as competent , reliable , and respectful. Professionals are a credit not only to themselves , but also to others and the following seven characteristics are pre-requisites:

  • Competency
  • Reliability and Accountability
  • Honesty and Integrity
  • Self- Control
  • Flexibility
  • Respect of others
  • Professional Image

Leading not largest!

Its not about being the largest. Its about leading. Its about influencing national policy; its about being consulted by our peers for advice and opinion; its about being recognised for proving the highest quality service. It’s about making a significant contribution to the public good, employing the most experienced and talented people; providing the best service to meet client needs and expectations , being efficient and cost effective.

We are independent practice based business. However, its not enough just to practice , we contribute to the betterment of the professions in which we operate. It is worth recognising that BB7 is a ‘Professional Service Firm’ , and those three words mean something. First and foremost , we are professionals , who are members of a profession which are regulated by the Professional Bodies that govern them. Secondly , we offer a service which is the action of aiding or completing work for people who need it. And thirdly , we are a firm. we are a practice-based business, not a business based practice.

Professional Service Firm

We are a professional service firm , a trusted independent advisory firm operating throughout the United Kingdom and the Republic of Ireland , and we focus on fire , security risk and resilience. We offer strategic advice, innovative design , construction oversight and risk management services throughout the entire building lifecycle. We are trusted advisors , and our primary objective is to deliver outstanding client service , providing fulfilling careers and professional satisfaction for our people , in order to achieve financial success to enable us to reward ourselves and grow. Our clients seek out advisors for their specificality expertise , experience and efficiency. They want to work with professionals and place their trust in a professional service firm. We are quite clear that trust is a precious commodity here at BB7 and that we must maintain and uphold that trusts at all costs.

Professions

Professionals hold professional qualifications and are members of Professions. Professions are controlled by governing bodies. Our technical staff are members of bodies such as Engineering Council (EC), Royal Institution of Chartered Surveyors (RICS), Institution of Fire Engineers (IFE) and Chartered Association of Building Engineers ( CABE). Our support staff and those within Corporate Services are members of bodies such as Association of Charted Certified Accountants ( ACCA), Chartered Institute of Management Accountant ( CIMA) ,Chartered Institute of Personnel Development or the Chartered Institute of Marketing ( CIM).

Professional bodies adopt a membership criteria for the standard of education and experience required for each grade of membership and they also have a requirement for continued commitment to lifelong learning for all members. This is a good thing. Moreover , the importance of upholding not only the highest professional standards , but also ethical standards is critical for professionals. We should uphold professional standards higher than those established by the general law , and act in the interest of the public we serve.

Increasingly , professional bodies are strengthening their governance and regulation processes and will take disciplinary action. should the member disobey the rules and standards the professional bodies have set out , or should a member be found guilty of unsatisfactory or poor professional work, they may be faced with expulsion from their membership , and we must be mindful that the threat of this happening, is very real. We support the notion that professional Bodies should raise the bar overtime and continue to strengthen their Governance processes , because public trust and protection is critical. Professional bodies and the advancement of an individual’s professional Qualification is something we have always supported here at BB7. Everyone in a technical role , or at management level must be a professional and a member of a professional body, because we are a professional service firm.

Quality And Innovation

We hold the view and aspiration that a Professional Engineer/ Surveyor is someone who is a yardstick for quality. At BB7, we are nurturing an environment where excellence is expected. If we are going to achieve consistent quality and enhance our reputation for excellence it must become a habit. Excellence is not an exception; it is a prevailing attitude. Excellence is being able to preform at a high level continuously, over and over again. This bolsters trust and confidence in us as a business and will give us a competitive edge in the market, as as our clients know they can count on us to provide an excellent experience, time and time again.

‘Excellence is doing ordinary things , extraordinarily well’ – John W. Gardner

It is essential we maintain a positive reputation for reliability and consistency by ensuring that we uphold a level of consistent quality within our services in order to:

  • Achieve greater consistency in the activities involved in providing our services
  • Reduce expensive mistakes
  • Increase efficiency by improving use of time and resources
  • Improve client satisfaction
  • Market ourselves on the basis of quality
  • Manage growth more effectively by making it easier to integrate new people into the company
  • Constantly improve our service offering , processes and systems.

Our internal auditing function is carried out by our Commercial Team. They provide independent, objective assurance to our Director of Quality and Innovation in order to add value to and improve our internal processes and procedures or operations. They are central to our Core idea of ‘Being Wise’ and our mission and values. Being Wise is essentially a key component of our strategy. Our strategy has and will always be governed by two essential criteria’s. In fact, we will not participate  within any strategy initiative unless it is clear it does one of the following things:

  1. It creates value for our people
  2. It creates value for our clients

Professional Advisory Board

We are an independent practice-based business. Putting ‘Practice’ at the heart of our business is important, but we will not just ‘practice’. We strive to make a contribution to the professions in which we operate and in doing so , contribute to the public good. This is our purpose, and it is inextricably linked to our core idea of being wise. Being wise is about superior professionalism, remaining a practice – based business and at the heart of it, is our Professional Advisory Board which plays a very important role. It forms our standards setting mechanism, ensuring our service portfolio is current and setting competency criteria. Our Professional Advisory Board is a formal committee within our management structure and adopts a decision making role. Its role is to advise members of the board on technical matters, and its decision are presented to our main board for approval. The attended for each meetings are chosen from around the business, based on technical expertise and their interest in the subject matter of the meeting. We also invite external stakeholders such as clients, insurers, academics,  and subject matter experts where we deem this to be appropriate. Professions can fall into the trap of only speaking to themselves and not the wider stakeholders they serve, which can cause them to become very narrow minded and vision-less to the bigger picture.

Our Professional Advisory Board (PAB) exists to support and provide expert knowledge and experience to ensure we remain at the forefront of the profession and that we recognise our vision and mission to become the wisest player in the markets we choose to operate within. Our PAB included setting standards for competency internally within BB7. They maintain our Career Pathway Guide , Competency Matrix, Policy and Procedures on Internal Peer Review Process and liaise with HR on Performance Management issues or with the Commercial team on Risk Management, Audit and Continuous Improvement/Corrective actions. If talent is a firms life blood, an effective service portfolio strategy represents the arteries through which that talent is channelled, and innovation keeps the whole system healthy and energised. service innovation can enhance brand, add value to clients, and create valuable new revenue streams, so our Professional advisory Board plays a very important role.

 

BB7 Now Backed By BGF

We are delighted to announce that BGF now backs BB7 and our vision to become the leading fire and security advisory firm. The investment will accelerate our growth. We will also increase the depth and breadth of risk and resilience advisory services we offer our clients. For our people it will provide an opportunity to come on the journey and grow and develop with the company.

About BGF

BGF is the most active growth investor in the world. They are the UK and Ireland’s most active investor in growing businesses. An established and independent company, it has £2.5bn in funds to support growing companies across every region and sector of the economy.

Since it was set up in 2011, BGF has invested £1.9bn in more than 275 companies and has 14 local offices across the UK and Ireland. BGF is also the first investment company to be awarded a Queen’s Award for Enterprise in Innovation.

BGF provides long-term, patient capital that management teams use to execute their strategic plans. It is also able to provide significant further funding as the company continues to grow, helping to build the large businesses of tomorrow. Its investment activities are deeply rooted in its mission to help ambitious businesses reach their potential and it has successfully cultivated a culture built on trust, patience and partnership.

About BB7

“We are a trusted independent advisory firm that manages risk through the provision of strategic advice and innovative design, construction and management solutions. We specialise in fire and security to help our clients protect people, prosperity and our planet.

It is with great excitement that we welcome BGF as our equity partner as this will bring huge opportunities for our people and help us deliver an enhanced level of service to our clients.”

  

Our Client Relationships Going Forward

As a result of this investment, BB7 will become even better placed to serve our clients; both in terms of our service portfolio but also with regards to servicing even more locations across the UK and Ireland. Ahead of this multi-million pound investment, BB7 were put under the microscope and have proven ourselves to be a sound, financially resilient business. BGF will help take BB7 to new heights both nationally and internationally at a time when world class fire and security design, construction, and risk management advisory services are a much needed.

Rahul Satsangi, an investor at BGF said:

“Ben and BB7 are very well-regarded as industry-leading experts in fire and security, thanks to their deep understanding of the complex regulatory environment and quality of service. We’re delighted to back the team at such an exciting stage of growth

BGF was set up in 2011 and has invested more than £1.9bn in over 275 companies, making it the most active investor in the UK and globally by number of transactions. On average, BGF invested in one company per week throughout 2018.

BGF has £2.5bn to invest in UK SMEs and in Ireland, and an additional €250m to support Irish businesses. Earlier this year, Canada launched its equivalent – the Canadian Business Growth Fund – based on BGF’s funding model, and Australia is now actively exploring the approach as well.

BGF is a minority, non-controlling equity partner with a patient outlook on investments, based on shared long-term goals with the management teams it backs.

 

Designing Fire Risk Management Into Buildings

Fire Strategies can sometimes fail to afford the attention to management that management deserves!

The risk posed by the threat of fire, to people, property, mission continuity and the environment is often governed more by the quality of management within a premises than the level of fire protection, and thus Management must be considered as of equal importance to fire protection measures.

Whilst the formal responsibilities of the designer, building control body and fire engineering consultant largely end when a building is completed and occupied their design liability begins. Much of the fire strategy will rely on management assumptions and hence it is imperative that Building Control Bodies take a much more proactive approach to enforcing Regulation 38 (Fire Safety Information) just as the Scottish Government has done. Fire Strategies can sometimes fail to afford the attention to management that management deserves and there is often a lack of appreciation among design teams of the fire safety manager’s role and the implications of the Regulatory Reform (Fire Safety) Order 2005 and equivalent legislation in Scotland and Northern Ireland. This legislation is rigorously enforced and punishments can be severe.

It is a fundamental assumption that the measures set out within national guidance documents such as Approved Document B or BS9999:2008 will require management and maintenance throughout the life of the building. The key management issues relating to a new project should be identified at the earliest possible stage and ‘where possible’ taken into account when drafting the buildings fire strategy. Most non-domestic multi-fatality fires have management failings as their root cause and there are numerous examples that support this view.

The fatal incident inquiry held after the deaths of fourteen elderly residents at Rose Park Care Home, concluded that “The management of fire safety at Rosepark was systematically and seriously defective” and went on to say that “The deficiencies in the management of fire safety at Rosepark contributed to the deaths in that a number of key circumstances would have been quite different if there had been an adequate system of fire safety management”.

So what is an adequate system of fire safety management?

The ‘general approach’ to prescriptive fire safety solutions offered within Approved Document B (and equivalent guidance in Scotland and Northern Ireland) assumes an adequate level of fire safety management; neither an unrealistic level of excellence nor a complete disregard for the minimum legislative requirements of the Regulatory Reform (Fire Safety) Order 2005 (and equivalent legislation in Scotland and Northern Ireland). The guidance assumes the level of fire safety management to be something of an ‘acceptable norm’.

The ‘Advanced approach’ to prescriptive fire safety solutions offered within BS9999:2008 refers to the standard or quality of management system as the management system level. There are three management levels, with level 1 giving the highest level of management, level 2 giving a normally accepted level of management, and level 3 giving a very basic level of management. Despite the definition of three management levels, readers of BS 9999:2008 may be surprised to find that the adoption of a management level does not lead to design flexibility further in the document, despite the aspirations alluded to regarding variation of the guidance in section 4.2. Furthermore, there is a widely held view within the fire safety profession that management level 1 is unachievable. The guidance goes on to say that irrespective of the guidance, an enforcing body might be of the view that a level 3 management system will not meet the legislative requirements placed on occupiers, owners or other responsible persons.

A building with first rate fire protection measures yet poor management, may pose a greater risk than a building with limited fire protection measures and good management.

Without guidance on minimum fire risk management system requirements how can we determine the management system level?

Acknowledging the difficulties of evaluating fire safety management without a formalised system, British Standards Institution has published PAS 7: 2013 – Fire Risk Management System Specification, which clearly establishes management system requirements in line with International Standards Organisation guidance. The standard works in harmony with other internationally accepted management system standards for Business Continuity and Health and Safety.

Health Technical Memorandum 05-01: Managing healthcare fire safety states in section 5.20 “A specification for fire risk management systems is available in PAS 7 – ‘Fire Risk Management System Specification’ (2013 edition) and this Health Technical Memorandum can be considered as healthcare-specific guidance supporting such a specification to identify the basic requirements of a fire safety management system”.PAS 79 stated “Fire Safety Management must be regarded as of equal importance to fire protection measures” but more than this, a building with first rate fire protection measures yet poor management, may pose a greater risk than a building with limited fire protection measures and good management.

So what is an enhanced management system?

In order to demonstrate that an enhanced level of Fire Safety Management will reduce risk, we need a credible means of measuring Fire Risk Management. An organisation that has formalised its fire risk management policy, strategy, objectives, and procedures, and then implemented a program of audit and management review is an organisation that is proactively assessing its management on a regular basis and this will ensure that the standard or quality of management does not fall below the assumed ‘acceptable norm’. Moreover an organisation that chooses to make a declaration of compliance with PAS 7 and be externally audited and certificated in accordance with PAS 7 will ensure that an ‘enhanced’ standard of management can be sustained both practically and economically over time and this will offer a greater level of confidence when designing and approving solutions reliant on a management component.

A large number of projects now include some element of deviation from prescriptive, code-based solutions, and the ‘Fire Safety Engineering approach’ offered within the BS 7974 series may on occasions be the only practical way to achieve a satisfactory standard of fire safety in some large and complex buildings.

Fire Engineered solutions that rely on the maintenance of a fire risk management system in lieu of physical fire precautions are much more robust if that system is independently audited and subject to third party certification. PD 7974 acknowledges this when referring to a management system level M1 when stating that ‘the system and procedures are subject to independent certification, including regular audit’. Health Technical Memorandum 05-01: Managing healthcare fire safety states in section 5.21 “Users of this Health Technical Memorandum are advised to consider the benefit of third-party certification of conformity with PAS 7 (2013). Appropriate conformity attestation arrangements are described in BS EN ISO/IEC 17021”.

A Fire engineered solution that utilises enhanced management as a component of the solution in order to satisfy legislation may require a management solution tailored specifically to the design of a building. Thus if management is to be used as a means of mitigating risk then a credible means of measuring management can be achieved by implementing a PAS 7:2013 Fire Risk Management System and adopting the management risk mitigation component into the organisations system procedures to be maintained, audited, and ‘where possible’ continually improved over time.

It is important that those involved in either designing or approving a package of fire safety measures appreciate what constitutes an adequate or enhanced management system and the differences between them. The management system level can of course fluctuate from time to time dependent on the organisation’s management system and an enhanced management system cannot provide a 100% guarantee of compliance with legislation in perpetuity. Certification is not in itself a panacea, however it is a giant leap forward for the fire risk management of our built environment. An organisation may during the risk assessment programme identify a risk that requires risk treatment within a specific period of time or risk acceptance and subsequently risk communication. In this instance an organisation with a robust fire risk management may chose to mitigate the identified risk on the grounds of an independently verified, enhanced management system.

Fire Risk Management system certification schemes will place no emphasis on management system levels because their focus will be solely on satisfying the requirements of the standard. In satisfying the requirements of the standard, the organisation will need to adopt a system appropriate to the context of the organisation and the hazards and risks they are managing and therefore it is effectively a self-levelling process.

Formalising a fire risk management system and being regularly audited is in itself a fairly robust process beyond the acceptable norm. When considering a ‘fire engineered’ solution with a management component comprising of enhanced management, an approving authority may consider a management system accredited by a third party certification body to be the only true means of ensuring a robust solution compliant with legislation.

There exists a real opportunity to improve BS 9999 and realize the aspirations of those who drafted the 1st edition in 2008, if we review sections 4 and 9 of this document in light of past two years of work undertaken on PAS 7.I am optimistic that the BSI committee, FSH 14 will grasp this opportunity when the document comes under review.

Where Fire Is Concerned, Honesty Is The Best Policy

”The trite saying that honesty is the best policy has met with the just criticism that honesty is not policy. The real honest man is honest from conviction of what is right, not from policy.”
Robert E Lee, famous American Civil War commander

What amounts to fire policy, fire risk management strategy and procedure is not well understood and so many fire safety professionals struggle to get it right.

Fire safety managers and consultants often confuse and blend policy, strategy and procedure and end up drafting a so-called ‘policy’ document that could make the Yellow Pages look like a memo. The vast majority of fire policy documents we see are full of good intentions that do not result in meaningful guidance, robust strategy or effective procedure.

The law states “The responsible person must take general fire precautions as will ensure, so far as is reasonably practicable, the safety of any of his employees and in relation to relevant persons, take such general fire precautions as may reasonably be required in the circumstances of the case to ensure that the premises are safe.”[1]

It goes on to talk about fire safety arrangement: “The responsible person must make and give effect to such arrangements as are appropriate, having regard to the size of his undertaking and the nature of its activities, for the effective planning, organisation, control, monitoring and review of the preventative and protective measures.”[2]  Crucially he must record the arrangements where he employs more than five persons or he is responsible for licensed premises, or he is the subject of an alterations notice issued by a fire authority.

The term ‘fire policy’ is defined as: “The intentions and direction of an organisation, in respect of fire safety, as formally expressed by its top management.”[3]

Can you combine fire with health and safety?

It is possible to combine fire with a health and safety policy statement but organisations must acknowledge that Health and Safety and Fire Risk Management, whilst both being risk-based disciplines, are uniquely different, with differing compliance drivers, and impacting upon duty holders within their organisations to differing extents dependent on roles.It is useful to think of policy as a ‘What and Why’ statement of intent.  Here are seven key points to look for in an organisation’s fire policy:

  • It should be appropriate to the purpose of the organisation;
  • It should provide a framework for setting objectives;
  • It should include a commitment to satisfying applicable requirements;
  • t should include a commitment to continual improvement;
  • It should be available as documented information.
  • The organisation should review it at planned intervals
  • A person authorised by top management should sign and authorise the fire safety policy.

The term ‘Fire Risk Management Strategy’ is “A document which defines an organisations fire risk management system and method of implementing the overarching policy”[4].  I like to think of this as the “How, Who and When” document.A well written Fire Risk Management Strategy will (as a minimum) address the following seven factors of Strategic Fire Risk Management:

  • Fire Risk Assessment
  • Resources and Authority
  • Fire Safety Training
  • Control of work onsite
  • Maintenance and testing
  • Communication
  • Emergency planning

Context, needs and expectations

The strategy should also convey the context of the organisation and the needs and expectations of interested parties. These may include employees, tenants, leaseholders, insurance companies, contractors, enforcing authorities etc.The strategy will set out roles, responsibilities and accountabilities within the organisation. It will take into account the capabilities and necessary competencies required.  Finally it should describe the organisation’s approach to monitoring, measurement, analysis and evaluation.

Ultimately the organisation’s Fire Risk Management Strategy will be reviewed with a view to continually improving the suitability, adequacy and effectiveness of its Fire Risk Management System.

The term ‘Procedure’ is defined as a “specified way to carry out an activity or a process” and in turn a ‘Process’ is defined as a “set of interrelated or interacting activities which transforms inputs into outputs”.Winston Churchill once said: “However beautiful the strategy you should occasionally look at the results”.

When auditing fire risk management systems, it has been a privilege to review the fire policies and procedures of many high profile organisations and some of the world’s most recognised brands.  However, too many organisations have policies and procedures which do not represent what actually happens on the ground.

Unmitigated liabilities

Many organisations have realised that to undertake a fire risk assessment programme, yet not to tackle the outcomes of those fire risk assessments, may leave them with a shelf, or file full, of potential liabilities, in that they have identified risks and failed to mitigate them.

On the same basis having policies and procedures that do not reflect what an organisation actually does, also presents a huge risk of liability to an organisation in the event of prosecution.  As mentioned above the law states the responsible person must do what is reasonably practicable, and if an organisation establishes policy and procedures then it is very difficult to argue that its own policies and procedures were not reasonably practicable following an incident.

The prosecution’s case may simply be:  “you felt this reasonably practicable at the time they were drafted”. Ultimately, to have policies and procedures and not follow them, regardless of whether they are still appropriate for the organisation, will leave an organisation exposed to potentially unlimited liability if they were to be found negligent.

In summary, if you have something that purports to be a policy, strategy, or procedure, make sure it is accurate, appropriate, and sufficient, and if it says you will do something to mitigate fire risk, make sure you do it.

[1] Article 8, The Regulatory Reform (Fire Safety) Order 2005

[2] Article 11, The Regulatory Reform (Fire Safety) Order 2005

[3] PAS 7: 2013 – Fire Risk Management System Specification

[4] PAS 7: 2013 – Fire Risk Management System Specification

The Seven Steps To A Successful Fire Risk Management Audit

Following two recent articles on fire policy and developing fire risk management strategy, Ben Bradford offers 7 steps to a successful fire risk management audit.

In an ever changing world, there’s an increasing focus on the total contribution from businesses to their customers, people, suppliers, community and the wider economy. These stakeholders can demand a high level of confidence that the organisation is capable of operating in a way that is defined, consistent, under control, effective and efficient. Put simply, the leadership, management and wider stakeholders want assurance.

There is of course a legal requirement contained within Article 11 of the Regulatory Reform (Fire Safety) Order 2005 that imposes a responsibility on the Responsible Person (usually the body corporate) to make and give effect to such arrangements as are appropriate, having regard to the size of his undertaking and the nature of its activities, for the effective planning, organisation, control, monitoring and review of the preventive and protective fire safety measures.

Interestingly that’s never the primary reason we are commissioned to undertake an audit. There are usually a number of reasons beyond minimum compliance with legislation that spur an organisation to commission a fire risk management audit. Providing evidence and confirmation for enhanced confidence and increased assurance is the primary positive role for auditing. This is achieved by looking for evidence to the contrary, for weaknesses, faults and failures in order to prove confidence.

However, we need to understand more clearly what is meant by the term ‘audit’. The term audit is defined in PAS 7: 2013 as a ‘systematic, independent and documented process for obtaining evidence and evaluating it objectively to determine the extent to which the specified criteria are fulfilled’. The specified criteria would be the PAS 7: 2013 – fire risk management system specification standard from the British Standards Institution.

On appointment, the auditor will prepare an audit plan with dates, times and locations for the following seven steps to take place. This will be discussed and agreed with the client to ensure it is mutually convenient. The following seven steps provide a methodology with which to approach a fire risk management audit:

Step One

This process will start with a desk top review of the organisations documented information. In an ideal world this will be the organisations fire risk management policy, strategy and procedures. However there may be other fire safety information that is required to be controlled and maintained by an organisation. This could be information at an organisational or strategic level or premises specific. We recently published a BB7 White paper entitled ‘A Guide to fire safety information for occupiers and end users of premises’ which provides further clarification on the different forms of fire safety information.

Step Two

The audit team will conduct interviews with key staff (duty holders). A duty holder is a person on whom there is a duty to comply with fire safety legislation. A selection of key duty holders can be identified from a review of organisational charts obtained in step one. However, it is prudent to begin gathering information on key people as early as possible and usually during initial meetings with the client.

In our experience, within a large organisation there are usually 10–15 key stakeholders linked to the fire risk management system across departments. It is useful for the organisation to identify the key individuals by title and schedule appointments. This way you are less likely to get to the end of the audit and someone to come forward and ask “Why did you not speak to me?”

Fire safety is not like health and safety and it rarely sits neatly in one department. The fire risk management function often straddles a number of departments but the role of the fire safety manager often creates a misconception among other functions within an organisation that fire safety is nothing to do with them. On occasions we find that the expectations on the fire safety manager are unrealistic.

Examples of this can be when they are leaned on for fire safety design and engineering advice during a refurbishment or new build project. Alternatively, they may be responsible for the governance of fire risk but also be contracted to look after health, safety and environment issues or security. In this scenario organisations can sometimes expect them to be a technical expert in all these disciplines. This is an unrealistic expectation.

Step Three

It is important to review the premises lists of those premises that require fire risk assessments and perform a desk top audit of a random sample of fire risk assessments. Following this initial desk top review the auditor can undertake site visits on a smaller sample in order to assess the standard of fire risk assessment review being undertaken.

BB7 have developed and documented a methodology specifically for desk top review and site based inspection of fire risk assessments and this is essential in ensuring consistency among auditors about what is deemed suitable and sufficient and what is not and also in providing constructive feedback to those who prepared the fire risk assessments.

Step Four

The auditor will then need to prepare a documented report in order to communicate the results of a fire risk management audit. This is, in itself, fire safety information however it is worth recognising that the words ‘information’ and ‘communication’ are used interchangeably but there is a difference. Information is giving out and communication is imparting the information and knowledge. A good auditor will use both written and verbal communication to communicate the results of the audit.

When drafting the fire risk management audit report the auditor will need to separate recommendations and key messages. Recommendations are areas where the organisation will need to complete some improvements much like an action plan in a fire risk assessment. Key messages are significant findings that might be found throughout the entirety of the report but not necessarily require the organisation to act upon them.

Step Five

The auditor may provide a close-out presentation if required, articulating and summarising the information contained in the report. This presentation is usually to senior management within the organisation, and is an opportunity to communicate the information verbally and answer any questions they may have on the content of the report. If a close out presentation is not required by the client the key stakeholders of the organisation will review the report in house before discussing with the auditor any questions they may have.

Step Six

Once the report has been discussed with the auditee in step five the auditor will then review the report in light of comments received and may alter or make changes before the final report is issued.

Step Seven

The auditor will revise and re-issue the final fire risk management audit report.

Summary

An auditor is defined as a ‘person with the demonstrated personal attributes and competence to conduct a fire risk management system audit’. Competence is a key word in the definition and relates to one’s ability to apply knowledge and skills to achieve intended results. The value of an audit is dependent on the competency of those auditing. It requires an in-depth knowledge of fire risk management and also management systems awareness.

Fire safety has been in the news a lot recently and for all the wrong reasons. Organisations need assurance. A fire risk management audit is a systematic and structured assessment of the set of interrelated or interacting elements of an organisation to establish policies and objectives and processes to achieve those objectives and manage fire risk.

BB7 are offering a free GAP analysis against PAS 7 to any medium / large organisation considering formalising their fire risk management system organisation wide.

The Mystery Of Missing Fire Strategies

Ben Bradford highlights the importance of fire safety information and asks where do fire strategies go?

However it is a complete mystery as to where fire strategies go, is it the same place odd socks go? Or is there a Bermuda Triangle for strategies? Or, perhaps they will turn up with Lord Lucan?

Our firm (BB7) assists architects and developers alike with independent fire engineering advice during the design and construction of new buildings, but we also undertake thousands of fire risk assessments. Rarely are we so fortuitous as to be furnished with a bespoke building fire strategy prior to undertaking an assessment, let alone an ‘as built’ fire strategy. A large proportion of the buildings we undertake fire risk assessments on, are complex buildings and many of these have been built in the last decade or two and more than likely have had strategy documents prepared as part of the design process.

It is a legal requirement of the Building Regulations 2010, Regulation 38, that “The person carrying out the work shall give fire safety information to the responsible person not later than the date of completion of the work, or the date of occupation of the building or extension, whichever is the earlier.” For those not familiar with the term ‘Responsible person’ the meaning of ‘Responsible Person’ is detailed in Article (3) of the Regulatory Reform (fire safety) Order 2005.

Searching for answers

When seeking answers to the question of the missing fire strategies we can draw two hypotheses:

1) Either, the ‘Responsible Person’ or duty holder has not been at all responsible and has either misplaced the information;
2) Or the current approach to enforcement of this legal requirement is at best haphazard and inconsistent or at worst simply not being enforced.

The first of these is entirely plausible and symptomatic of a management failing which may be taken into consideration when undertaking the fire risk assessment as required under Article (9) of the FSO.

However many fire engineers can provide a fair amount of anecdotal evidence to suggest the latter is a major part of the problem. This problem may stem from the building control process and it would appear that Building Control Bodies are simply not enforcing this aspect of the regulations consistently. There have been a few pointed articles in fire safety journals and industry publications that identify this problem, but in fairness to our friends within the Building Control Profession we should acknowledge that the requirement actually says “The person carrying out the work shall give fire safety information to the responsible person’ as opposed to “The person carrying out the work shall give fire safety information to the Building Control Body”.

But there is another issue to be resolved.

It has become apparent that there is a lack of clarity regarding exactly when a fire strategy is required and a lack of appreciation of the benefits that an ‘as-built’ fire strategy can provide to the end user in years to come when considering alterations to buildings in the form of refurbishment or even general maintenance, it is often invaluable to have access to the original design assumptions with regard to fire safety.

Invaluable Information

With the increase in performance-based design, most new schemes now contain an element of fire engineering. Fire engineered buildings may require an increased level of management over and above a code compliant building, but it should be remembered that even code compliant buildings can require a high degree of management. Take for example a code-compliant atrium building, hospital, or even a residential block of flats with smoke control via mechanical shafts.

The fire safety manager or some other duty-holder within the relevant organisation will be tasked with ensuring that the fire safety measures provided when the building is handed over are then managed and maintained, to ensure that they remain operating in the manner that was intended throughout the buildings lifecycle.

In most situations, the fire safety manager is rarely a competent fire engineer with a crystal ball that enables them to look into the past and determine exactly what the original design principles were at the time of construction. In years to come the fire safety manager may find they are looking at the glazing in atria and trying to determine if it is fire-resisting, or simply laminated. They may be asked whether the long throw sprinkler system that has been installed is essential to the strategy because the replacement or reinstatement of this system presents a five-figure reinstatement cost, and without the original strategy how are they supposed to know?

It has become apparent that there is a lack of clarity regarding exactly when a fire strategy is required.

Now imagine a fire-engineered building where the fire time of the building has been reduced from 120 minutes to 90 minutes, and there are extended travel distances on the floor plates which were agreed on the basis of a compensatory feature such as sprinklers. If the fire safety manager is faced with a refurbishment of two floors within such a building the manager needs to understand what risk is posed by the isolation of the sprinkler system. If the fire strategy has been lost in the mists of time, or simply does not exist then it could be a case of trying to look into that crystal ball.

So when is a fire strategy required?

Appendix G within the current national guidance offers a basic insight as to the level of detail required with regard to fire safety information and Regulation 38. The legal requirement clearly states the term “relevant building” and that is a building to which the Regulatory Reform (Fire Safety) Order 2005 applies, or will apply after the completion of building work. For clarity the appendix breaks this down into ‘simple buildings’ and ‘complex buildings’ both of which may fall within the scope of the FSO.

What exactly constitutes a simple building?

A simple building cannot be defined easily as it is not just the case that a simple building is a ‘code compliant’ building, for example, a shopping mall, hospital, or airport terminal could be code compliant but would not necessarily result in a building that is simple in terms of fire safety design or the resultant management obligations.

Even a small residential block of flats may not be as simple as one first imagines. For example, imagine a residential building complying with the small single-stair building criteria. It has two apartments per floor and an open plan common staircase, that is, there isn’t lobby protection between the apartment entrance door and the common stairs and therefore requires an internal protected hallway separating the accommodation from the stair. It may be compliant in terms of internal layout but we must remember that there is a legal obligation on the ‘Responsible Person’ or their nominated duty-holder in accordance with the FSO to undertake fire risk assessments periodically within the common parts.

Now in accordance with the guidance contained within the fire safety in purpose-built blocks of flats guide, this fire risk assessment may be either a type 1,2,3 or 4 assessment and it would indeed be very useful for the fire risk assessor to understand the original design basis. They will need to sample the front entrance doors to the flats and gain access to a sample of flats. What if the resident has made alterations internally and removed fire safety measures that were necessary for compliance with the Building Regulations and essential for compliance with the FSO.

It would indeed be prudent to have a documented fire strategy in order to aid the responsible person or their duty holder in meeting their legal obligations. Commendably the national guidance suggests ‘as built’ fire strategy drawings for simple buildings, yet these rarely exist in practice and it would seem even this aspect is rarely complied with. Moreover, there will be occasions when an ‘as built’ fire strategy would be a very useful document for a so-called ‘simple building’.

If a building follows the ‘general approach’ to fire safety design and strictly conforms to Approved Document B it may be a simple building, but as mentioned above simply being ‘code compliant’ does not mean all ‘code compliant’ buildings are simple in terms of fire strategy. It follows that a building that adopts the ‘advanced approach’ or a ‘fire-engineered’ approach will not be a simple building.

What is a complex building?

As suggested in trying to define a simple building, complex buildings can include both ‘code compliant’ buildings and non-code-compliant buildings. The national guidance suggests these buildings require a detailed record of the fire safety strategy and procedures for operating and maintaining any fire protection measures in order to satisfy the requirements of Regulation 38. In fact, relatively few building types can now be considered simple buildings with regard to fire safety design and best practice would suggest a fire strategy should be submitted as part of the Building Regulations approval process.

Fire Safety Information (Strategy) and Building Regulation Approval

Our friends in Scotland have already acknowledged this problem and made sensible amendments at the government level to ensure that buildings are not issued completion certificates without the necessary fire safety information being handed over. It is our considered opinion that Building Control Bodies in England and Wales would do well to issue a standard guidance note for applicants on receipt of plans as part of a building regulation approval submission, informing them of the requirement of Regulation 38 and the benefits of ‘as built’ fire strategies and/or fire strategy drawings.

We also need to provide further guidance on what constitutes a ‘simple building’ and what constitutes a ‘complex building’. Furthermore, it would be very helpful to those responsible for managing occupied buildings if appropriate fire safety information in the form of an ‘as built’ fire strategy and/or fire strategy drawings was submitted to the Building Control Body prior to issuance of a completion certificate. This way at least during the conveyancing process a new owner may be afforded an insight into the original design intent. Perhaps it is the legislation that needs amending?

It is intended that this subject will be raised with the Royal Institution of Chartered Surveyors (RICS) Professional Group Board for Building Control. This issue presents an opportunity for both the Fire Engineering profession and the Building Control profession to work collaboratively for the betterment of fire safety in England and Wales.