FSF submits evidence to the Independent Review of Building Regulations and Fire Safety
20 October 2017
The FSF has submitted evidence and recommendations to the Independent Review of the Building Regulations and Fire Safety led by Dame Judith Hackitt.
The FSF response outlines 13 key recommendations as well as a discussion of the Federation’s main concerns.
Click to view the FSF reponse to the Regulatory Review Call for evidence.
The FSF’s key recommendations are listed below:
1. Introduce a greater element of building resilience into the core regulatory guidance (which at the same time will provide higher levels of protection for those who cannot easily escape).
2. Review current guidance and assess how it can better reflect the risk profile of today’s urban built environment, with the objective of developing select new guides for particular risk categories (e.g. tall residential buildings).
3. Provide better correlation between the different elements of building regulations, to ensure that the implications of developments in one functional objective do not compromise fire safety objectives. For example, between AD B and AD L (energy), and between AD B and AD M (ease of access).
4. Introduce a definition of the core competency criteria expectations as separate guidance backing the regulatory guidance for fire safety, specifically and individually for the key roles that can be identified along the design, specification, supply and construction chain through to building occupation including enforcement and risk assessment.
5. Commission a complete review of the combustibility concept and associated product and system testing, which should include a better consideration of not just ignition and surface spread of flame but also the overall ability of a material used in construction to sustain fire.
6. Introduce a formal requirement under regulatory revisions placing an obligation on those introducing design, product and building system innovations which depart significantly from current practice, to demonstrate that the development will at least not compromise fire safety and that it will meet the functional requirements of building regulations for fire.
7. Develop new guidelines and guidance on what to do on refurbishment and modernisation for those works that fall outside of AD B new build guidance. This should advise, on a practical basis, how older buildings can be better brought up-to-date with the latest best practice fire safety and property protection provisions on a suitable, sufficient and appropriate basis. Consider that upgrades and changes outside major change should cover adaption and use of buildings.
8. Provide stronger support in the regulatory guidance to the wider application of third party certification schemes for products, systems, and installation for better controls and minimum assurances on levels and consistency of fire performance, including fire resistance, reaction to fire, ability to sustain fire and load-bearing capability.
9. Introduce regulatory provisions for the better assignment of responsibility and accountability at key points in the chain through to building handover, on the basis that responsibility for risks should be better assigned to those who create the risks potentially. For example, introduce requirements for formal sign off of the design, the specification, sub-contractor completion of individual elements, the completion by the main contractor on handover to the owner (including recognition of Regulation 38).
10. Revise AD B and new guidance to remove ambiguity, ensure clarity, and improve that guidance is more user friendly given that there is now such a wide spread of different possible user groups.
11. Ensure that there is within the regulatory guidance a stronger requirement, as a regulatory obligation, for involvement of the Fire and Rescue Service in the design process through to finalisation of the design, to ensure that the planned provisions are consistent with local firefighting policies and provisions. It should be a requirement under the regulations to ensure that there is a statement of implications for firefighting actions in the completion documents for the design.
12. Define key benchmarks and standards for key fire safety concepts, including the combustibility concept and associated product and system testing; what constitutes a ‘suitable and sufficient’ fire risk assessment etc .
13. Create a National Fire Safety Agency that can address this fragmentation and take into account input from all the professionals involved in ensuring the fire safety of our built environment.