In the light of recent high profile fires and the relentless increase in fire losses, you can be forgiven for wondering whether fire safety in the UK is going backwards rather than forwards. Mike Wood examines our risk based approach and considers whether it is fit for purpose.
Recent events will surely lead to calls for fresh analysis of fire safety in Britain's buildings, old as well as new. The Lakanal House fire in Camberwell, London is the most high profile example. While the interim report on Lakanal provides several welcome pointers, the full, responsible debate on specific events must await further detail and recommendations from the complete official investigation. That incident was followed swiftly by a major fire in Soho, central London, which caused major disruption, and this year has also seen a spate of warehouse fires. This when insured fire losses in buildings are at an all-time high, despite the fact that the number of fires continue to fall, and is against the background of ongoing concerns about the levels of competency required to do an appropriate and sufficient risk assessment.
It is surely appropriate for the fire safety community as a united group to take stock, especially when minds are already turning to the future for the next review round of building regulations. A wider view will be needed. Is fire safety going in the right direction? What's the destination? And what adjustments to the travel plan may be needed along the way?
The risk-based approach
The transition towards risk-based fire protection, fire safety and emergency response has been in tune with the spirit of the times, indicative of a preferred and practical modern approach to regulation. Certainly, the risk-based approach to design and regulation offers the promise of more focused fire safety, with the appropriate designs and measures in place tailored to suit individual building characteristics – that is, predominantly, the building's function, use, occupancy and applicable risk profile. Such an approach reflects the complexity of today's built environment.
For firefighters the issues are, however, ones of uncertainty, as each building in effect sets unknown and individual challenges. A risk assessment of the design, and its communication to the responsible person, is then equally as important as a risk assessment of the building when it is occupied. Hopefully there should be a link between the two. For occupants and those responsible for the building and its risk assessment, the issue becomes one of being properly informed on the individual fire safety concept, the intended operation of the fire safety measures that are in place, and the applicable fire safety management processes. For designers, specifiers, manufacturers, testers, suppliers and installers alike, the principle of responsibility introduced by the Fire Safety Order is equally appropriate as it is for the responsible person and competent person. For risk assessors, technical knowledge on systems, material and products is vital.
In theory, if carried out sensibly, thoroughly and on the basis of rigorous evidence and sophisticated understanding, the risk-based approach offers the potential to deliver a high level of fire safety across our built environment. But this approach depends on diligence and integrity across the board, backed up by knowledge, skill, commitment and key competency, allied with effective communication. Widespread awareness of these implications, with appropriate action to implement them, is important.
Risks
The UK model has become increasingly less prescriptive and more dependent on ‘expert judgment'. The complexity of the built environment and of national and community objectives would suggest that it is the right way to go. There is nothing wrong with this approach, so long as there is the education, skills development, commitment and enforcement to ensure that appropriate levels of fire protection are used. Without these appropriate controls and checks it is questionable whether the risk-based approach can, in the medium to long term, function properly and effectively as intended and required. There is the possibility that fire safety could stumble, by default, into self-regulation and self-compliance. This risks putting fire safety at the whim of individual, subjective judgement in what could become a predominantly cost cutting ‘what we can get away with?' culture of minimalist fire safety design and installation. Nobody in fire safety wants to end up at that destination.
On top of this comes the current economic condition which, by a tightening of the purse strings, can lead too easily to a temptation to cut corners. This can erode safety margins by dispensing with, or diluting, fire protection measures under the veneer of technical progress. In some cases, however, economic reasons can simply be employed as a rationale to justify and reinforce an existing corner-cutting tendency.
Other drivers of the built environment seemingly motor on with a growing momentum that threatens to steamroller legitimate aspects of public interest, such as fire safety. The high profile of the energy sustainability agenda, for example, is understandable given the social, political and economic implications of climate change. These considerations are influencing building design and construction far more than concerns about fire safety, yet they bring new implications for it through developments such as new insulation materials, modular constructions and energy efficient designs.
Fire losses
Official statistics tell us that the overall number of fires is at its lowest in more than 20 years, so why are fire losses increasing? Insured losses in commercial property rose 15% to £865m in 2008, plus £408m in domestic premises (up 17%), and £33m in school fires. The total insured loss per year is reported to have reached £1.3bn in 2008, and is on a rising trend since 1994. First quarter figures for 2009 show a further rise in insured losses of the order of 17%. There is also a significant growth in large loss incidents above £500,000. Pile on top of that uninsured fire losses, variously cited as several times the level of insured losses, plus public funding of fire and rescue service response, and the direct cost of fires is evidently huge.
The reasons for these developments are not yet sufficiently clear though undoubtedly there are a number of dimensions. The risk is that we do not take a wide enough view and rather look at each aspect in isolation. For example, changes to fire cover under integrated risk management planning (IRMP) should not be progressed without paying attention to fundamental trends in buildings, such as those related to architecture, design, construction, occupancy and patterns of use. In short, is the built environment becoming more vulnerable to fire, and what are the overall implications for IRMP?
In thinking about the application and enforcement of risk-based regulation we also need to consider the materials and methods now being used in building development. Many new products and techniques coming onto the market to assist primarily with reducing a structure's environmental impact are not being evaluated for their performance in fire. Yet we know that in some cases their properties are not sufficiently flame retardant, nor robustly fire resistant. That suggests the need for a review of how we evaluate materials and structures for their performance in fire. Our housing could be developing in a way which makes it more sensitive and vulnerable to fire. The question will not arise, however, if the building regulations are applied, as the provisions within the guidance look at individual elements and areas and not the whole structure of the building. We evaluate materials, products and product systems by fire testing where fire performance claims are required by the regulatory guidance, but not the overall performance of structures and combinations of different elements.
There are concerns that the standard process of product testing is not sufficiently robust. All that is required in the UK is a test report and maybe an assessment. But there is scope for products to be tested repeatedly until they pass on just one occasion – without taking into account the reasons for previous failures. It is also possible to install products and systems that are not representative of the tested product, and even to submit test evidence that does not fit the application. The core guidance is that the installation should be treated as a designed and tested system, but there are instances of installations being put together on a mix and match basis using components from separate sources – without reference to test evidence. That is why the industry strongly advances third party certification schemes – both for product and installation – to underpin basic supplier responsibility, as an enhanced level of assurance. Fitness for purpose (i.e. practical resilience in fire) needs to be the new focus, not simply fitness under test.
Compartmentation
Robust compartmentation is fundamental to the construction of buildings, providing the basis for fire protection and forming a foundation for the application and integration of other types of fire protection. The intention of compartmentation is to provide the essence of fire control, protected access and escape by limiting the fire in size to its place of origin and placing a brake on the speed of fire spread. It lowers the chance of fires becoming large to the point where they could overwhelm other measures and reduces the possibilities of catastrophic collapse. To contain fire as much as possible to one defined area is clearly a great benefit in minimising fire damage.
Building without compartmentation is as unthinkable as a body without its skeleton, and it is natural to see it used in conjunction with other systems, in particular means of suppression. And the principle of control can be maximised by a judicious sizing of compartments, perhaps in combination with fire-resistant glazing to maintain openness, security, energy efficiency and acoustic insulation. But more and more we are seeing a tendency to suggest larger compartment sizes in cases without compensatory features. This will affect firefighting and fire safety in a diverse built environment populated by buildings old and new, built to different specifications and many potentially containing a fire load substantially altered from the original expectation. Guidance from the various documents – Approved Document B, BS 9999, and the new Fire Protection Association's guide to Approved Document B with enhanced property protection – provide a potentially bewildering number of compartment size options for various building types (from 2000m2 upwards, including 4000m2, 7000m2, 8000m2 and 14,000m2 depending on the circumstances). In the latter cases this suggests that occupants will evolve into Olympic class sprint athletes, ever alert with super tuned hearing and a particularly sensitive sense of smell to pick up the faintest whiff of smoke!
A key question is how large the compartment limits should be and how to determine a safe size. But here the technical guidance can sometimes be conflicting, and out of kilter with the smaller maximum sizes permitted elsewhere in Europe. Warehouse fires can be seen as a specific problem and as an illustration of more general fire issue. Certainly, severe examples of fires in large warehouses continue to hit the news – and not just in rural areas, but in urban centres too. Recent guidance for insurance purposes issued by the RISC Authority, however, provides for recommended compartment sizes closer to those of the continental norm.
Looking to the future
Approved Document B 2007 (ADB), and its equivalents in Scotland and Northern Ireland, remains our guide, linking to the basic ‘functional' requirements of the Building Act and the Building Regulations. It is the central guidance on how to satisfy basic levels and requirements of fire safety in new and refurbished properties, effectively combining functional objectives with a role as a primer on fire safety design. But we know ADB intentionally focuses on life safety, provides minimum guidance, and covers only the most common of building situations. Property protection may require additional or enhanced measures, such as longer fire resistance, or insulation performance replacing integrity only. We also know ADB is rooted in history and cannot be perhaps as forward looking in anticipation of changes in buildings as might be desirable.
Bringing buildings from previous decades up to date with the latest ADB guidance may not be that easy, without changes that are unrealistically expensive or disruptive. A different set of guidance may be needed for such modernisation tasks, or in its absence, at least the specialist and focused guidance of appropriate fire safety professionals.
We know how to build buildings that are robust against fire. The essential elements should be:
- good quality fit-for-purpose materials, products and systems
- integrated fire protection, combining and optimising different technologies
- appropriate risk-based design, founded fundamentally on the principles of compartmentation
- fit-for-purpose system and product testing and approval processes, including third party certification
- design and installation according to the defined system specifications, by accredited installers without last-minute changes or adjustments
The central issue is not about whether or not the means are available to advance fire safety. It is rather one of making sure that those means are properly and adequately applied, in effect providing an appropriate architecture to ensure that the risk-based approach operates effectively.
It is a task for everybody in the fire protection community to spread the holistic, integrated fire protection message, founded on the principles of best practice. It is time not only to take stock but also to export the arguments as a unified message. The fire safety community is good at discussing within its own boundaries but now it is opportune to take that passion and enthusiasm to other constituencies, in particular to engage with those who shape the built environment and have a major influence on what goes on within it.
Mike Wood is chairman of the Fire Safety Development Group and global consultant, Fire Protection & Glass Design at Pilkington Group
