Written evidence submitted by the Business Sprinkler Alliance [BSB 084]

The BSA is a coalition of leading fire industry organisations and experts who aim to ensure that more of the UK’s industrial and commercial buildings (ICBs) are protected from fire with automatic fire sprinkler systems. The BSA members are: the National Fire Chiefs Council, the National Fire Sprinkler Network, the European Fire Sprinkler Network, the British Automatic Fire Sprinkler Association, the Fire Protection Association and commercial insurer FM Global.

Summary

The draft Building Safety Bill will implement significant reform, but largely for buildings in scope. In the first instance buildings in scope are expected to be limited to high-rise residential buildings. This limitation is appropriate as the new regime will be stringent and is designed primarily to address the failings of the Fire Safety Building Regulations (FSBR) highlighted by the Grenfell Tower tragedy.

However, this also means that the bulk of buildings to be constructed in the coming decade will not be impacted by the draft Bill’s provisions and so will be designed and built under the current FSBR which can be described as: design “to ensure evacuation before collapse”. An outcome under the current system is a “success” if all occupants evacuate safely even if the building is then destroyed by the fire - this is because the locus of the FSBR is limited to life safety. A number of recent large fire events (see below) where buildings have been destroyed have highlighted this incongruity and understandably have left the public questioning how regulation can allow these outcomes to occur.

The solution is to broaden the scope of the FSBR (with amendments to the Building Act and the Building Regulations – see below). This will allow buildings of all types – residential, institutional, industrial/commercial – to be designed to be resilient so that in the event of a fire both the occupants and the property are protected with the result that there will be fewer large, dangerous and costly fires. This measure will ensure that the future built environment will be safe and sustainable and so will also reduce cost of fire which is primarily borne by the public purse.

How well does the Bill, as drafted, meet the Government’s own policy intentions?

The draft Bill will broadly meet the Government’s policy intentions as detailed in the explanatory memorandum to the draft Bill, albeit with some caveats outlined in this submission.

However, the Government has also been keen to make clear that the regulation proposed will implement the “biggest reforms to the building safety regime in nearly 40 years”. The Bill’s proposed provisions will implement significant reform, but will primarily do so only for those buildings in scope. Buildings in scope are defined as higher-risk buildings and which in the first instance are expected to be limited to multi-occupied residential buildings – and these will constitute only small proportion of the buildings to constructed in the coming decades. Most of the draft Bill’s provisions will therefore not impact on the majority of the built environment. This will leave open the possibility of another fire tragedy in a building type out of scope. And it will do little to reduce the £9 billion annual cost of fire[1].

The Government can very easily ensure that it truly implements the “biggest reforms to the building safety regime in nearly 40 years”. This can be done by making a proportionate consideration of property protection a requirement of the Fire Safety Building Regulations (FSBR) in parallel to the measures proposed for buildings in scope:

-          The scope/locus of the FSBR is currently limited to life safety. The draft Bill does not propose to change this locus. While life safety is clearly key, this locus allows (dictates almost) the construction of disposable buildings because fire safety design is focussed on ensuring the safe evacuation of occupants in the event of a fire. Hence there is little consideration about the survival of the building itself once occupants have evacuated safely. Consequently, buildings are often destroyed by fire.

-          The effect of the FSBR can therefore be described as “design to ensure evacuation before collapse” – and an outcome under the current system is therefore a “success” if all occupants evacuate safely even if the building is then destroyed by the fire. This is a wrong-headed approach because homes, institutions and places of work are lost and need to be replaced when fire destroys living and working spaces.

-          In the past year alone there have been numerous incidents where multiple-residence buildings, institutions and industrial/commercial buildings have been destroyed by fire. These include: the Barking flats fire, the Worcester Park fire, the Bolton Cube fire, the Beechmere residential care home fire, the Walsall Holiday Inn fire, the Bristol Premier Inn fire, the Moorfield Hotel fire and an extensive list of fires in industrial and commercial buildings (ICB). Thankfully, there were no serious injuries in any of these fires, but fire damage left the buildings unusable. The consequences of this wrong-headed approach are therefore that:

-          If a home is left unusable by fire, residents need to be rehoused and property needs to be rebuilt often at a cost to the public purse. By way of example, MHCLG has calculated the cost (other than life safety costs) of the Grenfell Tower fire to be within the range £650 million-£950 million.

-          If a care home, hospital or school is left unusable by fire – alternative provision has to be found for the residents, patients and pupils often to the detriment of their care or education and commonly at a cost to the public purse.

-          If an industrial/commercial building is left unusable by fire, the business concerned must quickly find alternative work premises often with the business and the associated jobs at risk in the process. If the business survives, insurance will cover the direct costs to a business but invariably will not cover many indirect costs borne by the business itself, by other businesses in the area, by their supply chains, by the wider local area, and by the local economy and ultimately the public purse. If the business fails and jobs are lost, the cost is borne by the public purse.

-          If significant buildings are disposable to fire we are not acting sustainably - with so much of the embodied carbon being tied up in the original construction of the building it is wrong-headed to accept the notion of buildings that are disposable in the face of fire.  The total reconstruction of a building will itself consume more energy whatever new green credential they may come with.

Making a proportionate consideration of property protection a requirement of the FSBR would mean that future reviews of the FSBR fire safety Guidance as detailed in Approved Document B (ADB) would consider property protection as well as life safety. The result would be that buildings would be designed with appropriate provisions to better withstand a fire so that the majority of the building should be able to continue to be used for their intended purpose after the fire event. This would also ensure that as innovative modern methods of construction and sustainable materials are considered, it is done with a view to continued operation and not solely with a limited view of escape before collapse. Moreover, a building which is designed to be resilient to fire will be safer for its occupants. Buildings which are resilient to fire are therefore safe, sustainable, and benefit the public purse.

A Government consultation[2] and a Fire Sector Federation survey[3] have shown that the majority of the fire sector want the scope of the FSBR to be broadened to include property protection. The measure can be enacted with amendments to the 1984 Building Act and the 2010 Building Regulations:

Changes to the Building Act 1984 (proposed amendments in red italics):

  1. Power to make building regulations.

(1)    The Secretary of State may, for any of the purposes of—

(a)    securing the health, safety, welfare and convenience of persons in or about buildings and of others who may be affected by buildings or matters connected with buildings,

(b)    furthering the conservation of fuel and power,

(c)     preventing waste, undue consumption, misuse or contamination of water,

(d)    furthering the protection of property

(e)    facilitating sustainable development

(f)     furthering the protection or enhancement of the environment,

(g)    furthering the prevention or detection of crime,]

make regulations with respect to the [matters mentioned in subsection (1A) below]…

Schedule 1, 8 (5A): The provision that may be made by building regulations includes provision imposing on a person carrying out work of any type in relation to a building (whenever erected), or in relation to any service, fitting or equipment provided in or in connection with a building (whenever erected), a requirement to do things for the purpose mentioned in section 1(1)(a), (d) and (e) of this Act in so far as it relates to the resistance or resilience of buildings in respect of flooding and fire.

Change to the Building Regulations 2010

Limitation on requirements

8 (1) Delete reference to “Part B”

8 (2) Part B of Schedule 1 shall not require anything to be done except for the purpose of securing reasonable standards of health and safety for persons in or about buildings (and any others who may be affected by buildings, or matters connected with buildings and in particular firefighters), for the purposes of furthering the protection of property, for facilitating sustainable development and for furthering the protection or enhancement of the environment to protect against disproportionate damage.

 

Without this action the Government will not meet its policy intentions because it will not implement “the biggest reforms to the building safety regime in nearly 40 years” and it will leave open the possibility of another fire tragedy in a building type out of scope and will do little to reduce the high economic, social and environmental costs of fire.

Does the draft Bill establish an appropriate scope for the new regulatory system?

The range of buildings covered by the scope is appropriate – the new regime will be stringent and at this stage, limiting the scope to higher-risk buildings – which in the first instance are expected to be higher-risk multi-occupied buildings - is a proportionate decision. The scope can be broadened at a future date if evidence shows further action is appropriate.

However, as noted above, this limited scope does mean that the vast majority of buildings will not be covered by the new regulatory system. The solution is not to broaden the scope of the new regulatory system, but to take the parallel action of broadening the scope of the FSBRs to include a proportionate consideration of property protection. As detailed above, the resultant changes to the ADB Guidance will ensure that all buildings are designed and constructed to be resilient to fire so they will be safer for occupants and better able to survive fire events. This higher design bar will protect against future tragedies across the built environment whilst also reducing the cost of fire. Concerning enforcement for buildings out of scope, we have seen that the ban on combustible construction has demonstrated that the construction sector will move when there is strong direction and defined enforcement. In parallel, activities have moved to active verification of construction materials to ensure compliance. These developments, together with effective implementation of Clauses 6 and Clause 10 of the draft Bill, should result in improvements in design, construction and enforcement of buildings out of scope. However, it is necessary to note that there remains in the industry a culture which still regards the guidance within ADB as a maximum, which can be ‘value engineered’ down, rather than as a bare minimum (see section below on sprinklers in ICBs) and the lack of guidance is often read as a permission. We note the powers provided to the Building Safety Regulator and the Committee on Industry Competence and also hope that they will be used to address this concern.

Does the Bill present an opportunity to address other building safety issues, such as requirements for sprinkler systems?

Yes, it does. However, it is not making the most of that opportunity. Again, as noted above, it is the common view across the fire sector that the scope of the FSBRs should include a proportionate consideration of property protection. If enacted, future reviews of the ADB fire safety Guidance will ensure that all buildings are designed and constructed with appropriate measures to better survive fire events and this will in part be delivered by an increased use of sprinkler systems.

Sprinkler systems prevent large fires by controlling, containing and sometimes even extinguishing fires at source and before the Fire and Rescue Service (FRS) arrive. Sprinklers systems have a proven global track record as the most efficient and effective fire safety tool for preventing large fires – they are therefore the most efficient and effective at protecting life as well as property. This means they are also the most efficient and effective tool to use to reduce the cost of fire. All the FRSs have stated they want sprinklers in more buildings because they know that sprinklers save lives, buildings and businesses and because sprinklers make their job safer, easier and cheaper. A study of UK fire incidents highlighted that sprinklers have an operational reliability of 94% and are 99% effective in controlling fire incidents[4], there has never been multiple fatalities in a building with operating sprinklers, and incidents of sprinklers failing to control or extinguish a fire at source are extremely rare.

As sprinklers are the most effective fire safety systems at protecting lives and property, ADB Guidance under a locus of life safety and a proportionate consideration of property protection would be expected to require sprinklers in more buildings than is currently the case. A likely consequence would be that sprinklers would be installed in new buildings where consequences of fire are acute:

      Life safety - where there is the possibility of large loss of life and where firefighter safety is likely to be compromised; and:

      Property protection - where loss of a building would impose significant negative impacts and costs on a local community and/or on the public purse because of the loss of a public service facility, the loss of a workplace or because of significant loss of residential accommodation.

From November of this year, all new blocks of flats with a storey higher than 11m will have to be fitted with a sprinkler system (both the Barking flats and the Worcester Park flats were taller than 11m). Alongside these buildings, a proportionate consideration of property protection would likely result in sprinkler installation requirements for:

      medium to large schools

      a range of healthcare facilities including care homes

      hotels and student accommodation with a story higher than 11m

      Industrial and Commercial Buildings larger than 2,000m2 - as per the BRE cost benefit analysis[5] referenced in the MHCLG Final Work Stream Report (BD 2887) Compartment sizes, resistance to fire and fire safety project - Work stream 2 – Maximum fire compartment sizes published for the 2019 Approved Document B.

      Complex buildings, requiring bespoke fire engineered solutions such as large timber frame structures, automated logistics buildings and hybrid buildings housing multiple occupancy types.

Sprinklers in industrial and commercial buildings

The work of the BSA focusses on ICBs. These buildings have not been a focus of the recent debate about fire safety. This is a mistake as fires in ICBs are the cause of significant economic, social and environmental costs, most of which is borne by the public purse[6].

In the financial year 2018/19 there were 7,727 fires attended by FRSs in ICBs in England. Of these fires, 2,114 were in industrial premises of which 176 resulted in the whole building being destroyed.[7] Financially, fire and explosion insurance claims arising from ICBs[8] in the UK during 2018 totalled £940 million. These figures represent the claims incurred by the Association of British Insurers (ABI) members in that year but do not include the business interruption impacts of those claims. Similarly, this does not reflect the amount of self-insurance taken by business, government schemes or other insurers who are not members of the ABI operating in the UK. The full claims figure is therefore most definitely greater than £1 billion.

One item that is notable within the English national fire statistics is the scale of the area damaged by fire: in 2018/19 there were 105 fires in “buildings other than dwellings” which caused fire damage to a building area of more than 1,000m2. These 105 fires alone were the cause of 60% of the overall fire damage experienced in England in that period to fires in “Other Building” types. This is an area of damage significantly larger than that experienced in all dwelling fires.[9]

Annexed to this submission is a list offering a snapshot of fires in 2019/20 (with news weblinks) where there were no fatalities but where there was significant or total damage to the property to the extent that it was no longer able to be used for its intended purpose as a result of the fire. As such, each of the fires in the list are deemed a “success” under the current system of FSBR.

Until 2012, the Local Acts gave Local Authorities the power to require sprinklers in warehouses larger than 7000m3. These powers were used by Local Authorities until they were withdrawn by the Government on the grounds that they were the cause of inconsistencies and unnecessary regulatory burdens relating to the fire protection requirements and offered the potential for anti-competitive behaviour between local authorities and private sector approved inspectors. Sprinklers are not commonly used in ICBs and the following facts, alongside the revocation of the Local Acts, explain both why they are not used and why Government action is needed to increase their use:

  1. The ADB Guidance on sprinkler provision is wholly inadequate for ICBs:
  1. The fire risk of ICBs is changing:
  1. Dame Judith Hackitt Report noted in her Independent Report loopholes which need to be closed to improve fire safety in the high-rise residential sector. But loopholes in the system are also allowing large warehouses which should be protected with sprinklers (as per ADB Guidance) to be built without them[10]:
  1. A combination of factors precludes against sprinklers being installed in ICBs which are outside of the remit of the ADB Guidance:
  1. Insurance does not cover the entire cost of fire: The de-regulatory agenda has aided the view that “the installation of sprinklers is a matter for a business and its insurer”. This view was reflected in the 2019 Approved Document B Call to Evidence document which noted that “…For non-domestic buildings, there is a view that businesses should be making their own decisions on commercial property protection in conjunction with their insurers…”. This over-simplifies the situation and does not take into consideration the wider societal and economic impact of ICB fires:

Hence, we return to the need for a proportionate consideration of property protection for the FSBR. Enacting this change alongside the proposed provisions of the draft Bill will implement change right across the built environment – it will: 

  1. Enhance occupant and firefighter safety - life safety and property protection are inter-related as the safest buildings are those designed to withstand a fire
  2. Create a resilient and sustainable built environment as new buildings will be effectively and proportionately protected against fire.
  3. Ensure that as innovative modern methods of construction and sustainable materials are considered, it is done with a view to continued operation and not solely with a limited view of escape before collapse.
  4. Make the task of the Fire and Rescue Service much safer, easier and cheaper
  5. Close loopholes which are exploited under the current regulatory system
  6. Save the Treasury billions of pounds annually as economic, social and environmental costs of fire will be minimised when buildings are designed to avoid disproportionate damage in the event of a fire. When buildings survive fires, they can continue to be used for their intended purpose: residents do not lose homes, pupils do not have to be schooled in temporary accommodation, businesses continue with no loss of productivity or jobs.

Will the Bill provide for a robust – and realistic – system of accountability for those responsible for building safety?

Ensuring that those responsible for making decisions on fire safety design, products and works are held accountable is essential to ensure that the system does not degrade over time.  Appropriate, independent monitoring and enforcement is required.  The proposals address these issues, but much will depend on how the system is set up managed and resourced.

Will the Bill provide strong mechanisms to ensure residents are listened to when they have concerns about their building’s safety?

NA

Is the Government right to propose a new Building Safety Charge? Does the bill introduce sufficient protections to ensure that leaseholders do not face excessive charges and that their funds are properly managed?

NA

Does the Bill improve the product testing regime in a way that will command the full confidence of the sector?

Regarding automatic fire sprinkler systems: the sprinkler industry has a long history of testing, product approval and third-party accreditation through the delivery chain. This is a reason for the high levels of reliability and effectiveness[15] for such systems that continued to be delivered. Product testing is welcome but there is a need to combine this with clear understanding from designers, installers and maintainers as to their use and continued performance.

Therefore, changes to broaden the same thinking across the wider set of building safety products is welcome.  The strengthening of verification processes and the competence of those involved in this area is necessary to ensure that this works successfully - particularly as new products are brought to market or innovations are offered as equivalent to existing systems for the purpose of compliance.

Is it right that the new Building Safety Regulator be established under the Health and Safety Executive, and how should it be funded? 

Whilst there are advantages to establishing the Building Safety Regulator within the HSE, the inter-relationship between the Regulator, building control and FRS fire safety enforcement needs to be clear, well understood, and robust.  An expansion of the existing procedural guidance[16] document between FRSs and Building Control would be beneficial in establishing an effective operating system.  Funding needs to flow from the developer/builder, as placing further burden on already stretched public bodies is unlikely to result in the necessarily robust enforcement regime.

 

September 2020

 

APPENDIX - FIRES

Listing of notable fires

13 August 2020: 2000m2 truck and van conversion business factory in east Suffolk destroyed by fire. https://www.eadt.co.uk/news/parham-airfield-fire-drone-images-1-6791738

10 August 2020: 100 FRS unable to save a large recycling plant in Tyseley, Birmingham. https://www.bbc.co.uk/news/uk-england-birmingham-53723433

8 August 2020: 80 FRS unable to save a large industrial warehouse in Newhaven, Sussex. https://www.bbc.co.uk/news/uk-england-sussex-53706519

27 July 2020: 100 bed Moorfield Hotel in Shetland providing accommodation for off-shore workers is destroyed by fire:  https://www.bbc.co.uk/news/uk-scotland-north-east-orkney-shetland-53551122

23 July 2020: 80 FRS unable to save a large industrial bakery in west London. https://www.lbc.co.uk/news/park-royal-fire/

5 July 2020: Sheffield warehouse destroyed by fire. https://www.thestar.co.uk/news/dramatic-pictures-show-major-sheffield-warehouse-fire-close-more-details-emerge-2904030

2 July 2020: 100 FRS are unable to save a series of single storey industrial units destroyed by fire in Acton, North London. https://www.mirror.co.uk/news/uk-news/acton-fire-100-firefighters-battling-22287781

21 June 2020: community supermarket with post office in Holt Norfolk destroyed by a fire. https://www.bbc.co.uk/news/uk-england-norfolk-53126763

12 June 2020: individuals, including key workers, lose possessions in Bolton self storage warehouse fire. https://www.theboltonnews.co.uk/news/18511869.self-storage-units-lost-industrial-estate-blaze/

30 May 2020: 60 FRS are unable to save the Corkers Crisp factory near Ely. https://www.cambridge-news.co.uk/news/cambridge-news/gallery/corkers-crisp-factory-damage-pictures-18340558

29 May 2020: 125 FRS unable to save a furniture warehouse in Park Royal, North London. https://www.standard.co.uk/news/london/park-royal-fire-industrial-warehouse-london-firefighters-a4454876.html

28 May 2020: Harrington Junior School in Long Eaton, Derbyshire destroyed by fire.  https://www.derbytelegraph.co.uk/news/local-news/derbyshire-school-destroyed-fire-rebuilt-4301519

16 May 2020: 125 FRS unable to save a large warehouse in Barking, London. https://www.bbc.co.uk/news/uk-england-london-52683146

30 April 2020: fire destroys top floors of a block of flats in Wood Green london. https://www.bbc.co.uk/news/uk-england-london-52481518

1 April 2020: fire destroys storage warehouse of Chorley-based manufacturer Carrington Textiles which was housing fabrics being stored prior to being manufactured into NHS and healthcare workwear. https://www.manchestereveningnews.co.uk/news/greater-manchester-news/materials-urgently-needed-nhs-blaze-18029382

17 March 2020: large Dorset industrial unit destroyed. https://www.somersetlive.co.uk/news/local-news/stalbridge-henstridge-gibbs-marsh-fire-3953860

1 February 2020: destruction of a large Wakefield bakery causes sever disruption. https://www.bbc.co.uk/news/uk-england-leeds-51340258

28 November 2019: Bolton Cube student accommodation fire. https://www.bbc.co.uk/news/uk-england-manchester-50457593

2 November 2019: 60 FRS fail to save a large industrial building, housing polystyrene and a storage business. https://www.bbc.co.uk/news/uk-england-beds-bucks-herts-50273637 https://www.bbc.co.uk/news/uk-england-beds-bucks-herts-50375809

24 October 2019: Worcester Park residential block, SW London, destroyed by a fire. https://www.bbc.co.uk/news/uk-england-london-49630496

10 October 2019: 80 FRS fail to save large warehouse in West London. https://www.bbc.co.uk/news/uk-england-london-49997174

28 September 2019: 80 FRS at a warehouse fire in White Hart Lane. https://www.mirror.co.uk/news/uk-news/breaking-tottenham-fire-80-firefighters-20320412

2 August 2019: Holiday Inn in Walsall destroyed by fire. https://www.bbc.co.uk/news/uk-england-birmingham-49207859

22 July 2019: Walthamstow Mall badly damaged by fire. https://www.theguardian.com/uk-news/2019/jul/22/walthamstow-fire-blaze-engulfs-shopping-centre-east-london

18 July 2019: fire destroys Premier Inn, Cribbs Causeway Bristol. https://www.bbc.co.uk/news/uk-england-bristol-49028337

7 July 2019: large fire Wednesbury estate. https://www.birminghammail.co.uk/black-country/fire-rips-through-wednesbury-factory-16541892

6 July 2019: 75 FRS fight fire at Bridport industrial estate – one unit lost one badly damaged. https://www.bbc.co.uk/news/uk-england-dorset-48893429

6 July 2019: Wellingborough recycling plant destroyed by fire. https://www.northantstelegraph.co.uk/news/burnt-out-wellingborough-factory-and-vehicle-shells-revealed-in-post-fire-pictures-1-8988849

9 June 2019: Barking flats fire. https://www.bbc.co.uk/news/uk-england-london-48574044

7 May 2019: 15 crews fail to save large warehouse used by commercial refrigerator business Liebherr destroyed. https://www.bbc.co.uk/news/uk-england-northamptonshire-48187497

14 April 2019: 10 crews fail to save warehouse in Smiddybrae Works on Skene Road, Aberdeen housing a number of small businesses. https://www.bbc.co.uk/news/uk-scotland-north-east-orkney-shetland-47921758, https://www.pressandjournal.co.uk/fp/news/aberdeen/1724179/businesses-left-counting-cost-after-huge-fire-at-north-east-industrial-estate/

2 April 2019: Mason’s Gin distillery destroyed – Richmond Yorkshire. Significant local disruption. https://www.bbc.co.uk/news/uk-england-york-north-yorkshire-47784459

18 March 2019: 100 FRS fail to save a large furniture warehouse in Tyseley Birmingham. https://www.bbc.co.uk/news/uk-england-birmingham-47608656

6 March 2019: 40 FRS fail to save a bed factory employing 80 staff on the Winchester Avenue Estate in Blaby. Also destroyed were neighbouring businesses: New Air Technical Services Ltd; Willoughby Book Club and Utilities Made Simple, https://www.leicestermercury.co.uk/news/leicester-news/area-evacuated-emergency-services-fire-2615513 , https://www.leicestermercury.co.uk/news/leicester-news/weve-lost-everything-firms-count-2619732 

28 February 2019: 100 FRS fail to save a tyre dealership in Tyseley Birmingham. https://www.birminghammail.co.uk/news/midlands-news/100-firefighters-huge-3am-blaze-15898780

5 February 2019: Ocado warehouse – sprinklers activated and controlled the fire, but the system was then turned off by staff thinking the fire was extinguished. The fire took hold again and eventually (2 days later) destroyed the building. https://www.bbc.co.uk/news/uk-england-hampshire-49738355

3 February 2019: more than 100 FRS fail to save a warehouse in Chorley, Lancashire. https://www.bbc.co.uk/news/uk-england-lancashire-47113799

31 December 2018: 75 FRS fight a fire which destroyed 2 warehouses in Planetary Road  Wednesfield in EDM (data management). https://www.bbc.co.uk/news/uk-england-birmingham-46728465

31 December 2018: 120 FRS at a self-storage warehouse fire in Croydon which destroyed the building. Individuals and businesses lost all property, and there was severe transport disruption – especially the tram lines. https://insidecroydon.com/2019/01/05/self-storage-warehouse-was-croydons-worst-fire-since-riots/

 

August 2020

 


[1] Why does Approved Document B (the FSBR Guidance) need to be reviewed? – Fire Sector Federation - 2017

[2] Technical Review of Approved Document B of the Building Regulations - Analysis of responses to the Call for Evidence, September 2019

[3] NBS research for the Fire Sector Federation – Reviewing Approved Document B (Fire Safety), 2017

[4] Efficiency and Effectiveness of Sprinkler Systems in the UK: An Analysis from Fire Service Data – Optimal Economics – May 2017

[5] BRE Global Limited: An Environmental Impact and Cost Benefit Analysis for Fire Sprinklers in Warehouse Buildings, 19 December 2013

[6] A 2014 report by the Cebr found that the direct financial loss to business as a consequence of warehouse fires is £230.2 million/year; the wider economic impact within the economy (hampered supply chains, decreased demand, reduced household income due to employment) is £190 million and 996 job losses per annum. Warehouse fire property damage claims represent only 15% of overall UK commercial losses. The remainder fall on other commercial facilities, predominantly manufacturing: the economic gross value added of manufacturing is 8 times greater than the GVA of the warehousing sector and staffing densities are higher in the manufacturing sector; the financial and employment impacts to the economy of fire events within manufacturing buildings are therefore far higher than those calculated by the Cebr for warehousing.

[7] Home Office IRS reporting figures. Table FIRE 0304 – The figures from the table covering Agricultural premises, Education premises, Communal Living, Private non-residential and Other Public Buildings have been excluded to determine the figure of 7,727 fires.

[8] Association British Insurers - https://www.abi.org.uk/news/speeches/2019/speech-by-james-dalton-at-the-abi-property-insurance-conference/

[9] Home Office IRS reporting figures. Other Building Fires Dataset, FIRE0304, FIRE0305 - Average fire damage for “Other Buildings” Fires is reported as 73.0m2 for all such fires and 28.3m2 for all such fires excluding those with damage over 1000m2. Considering 15,005 fire incidents in “Other Buildings” in this period with 105 creating damage greater than 1000m2, by calculation these 105 fires are responsible for 60% of the total fire area damaged in this class in this time period. The average area of fire damage in a dwelling in the same period was 16.2m2 with 29,570 fire incidents.

[10] By way of example: in 2017 a 40,000m2 warehouse was built in Daventry. It was occupied at the end of 2017 by Gardman Suppliers. The building did not have a sprinkler system even though it was twice the ADB Guidance threshold size for sprinkler installation; it did though have a top BREEAM rating. In March 2018 a fire started – all the occupants evacuated safely but the building was completely destroyed.  The £53 million insurance pay-out was not sufficient to save the business which was put up for sale by the administrators. It was subsequently bought by another horticulture business for £4 million in October 2018.

[11] By way of example: a large Sony warehouse in North London was destroyed by a fire in 2011 – it was not fitted with sprinklers. A court ruling of March 2020 against Sony and in favour of claimants whose goods were stored in the warehouse noted: that walkways should have been included in the floor-area calculation; and noted confusion as to when a building is multi-storey when mezzanines and walkways are used – both are relevant to whether sprinklers should have been fitted. It also noted that sprinklers would have reduced the loss caused by the fire. Of concern is the fact that the replacement warehouse, which has a larger footprint with use of mezzanines, is also not protected by a sprinkler system. 

[12] By way of example: a fire at the four-storey Shurgard unit in Croydon on 31 December 2018 resulted in the complete destruction of the self-storage facility. The building did not have a sprinkler system installed. The building footprint was approximately 2,400m2. It had been divided in two compartments on each floor to comply with FSBR. When faced with questions from the clients who believed that their property was protected whilst in storage of the facility the response from Shurgard was to note that they complied with the Building Regulations.

[13] By way of example: on 1 February 2020 the Speedibake factory in Wakefield was destroyed by fire. ABF’s Interim Report has noted that: “In February 2020, our Speedibake Wakefield factory was significantly damaged by fire, following which we announced that the factory would permanently close. This resulted in an exceptional charge of £25m in the period, comprising £18m impairment of non-current assets, £1m of inventory write-off and £6m of closure costs. We have comprehensive insurance and have made significant progress with our insurers regarding receipt of compensation for the entire effects of the fire.”

[14] Wakefield Council has since offered employment skills and training advice to those affected by the closure of the Speedibake factory - http://www.wakefield.gov.uk/Pages/News/pr-9320.aspx

[15] Efficiency and Effectiveness of Sprinkler Systems in the UK: An Analysis from Fire Service Data – Optimal Economics – May 2017

[16] https://www.labc.co.uk/sites/default/files/2020-07/LABC.Building-Regulations-and-Fire-Safety-Procedural-GuidanceV2.150720.pdf