Written evidence submitted by the British Cables Association [BSB 276]

1. The British Cables Association (BCA) represents manufacturers of all types of cable, used for construction, power supply, telecommunications and many other purposes.  Cables are widely used in construction works to provide power, lighting and telecommunications services, some of which are safety critical.

2. Our comments are restricted to cables used for fixed installation within buildings, and do not address cables forming part of an electrical appliance.  These remain the responsibility of the appliance manufacturer and are outside the scope of building regulation.

3. Our evidence is limited to comments on Clause 110 and Schedule 8.

4. Most cables are standardised (made to designs and performance requirements set out in standards) and subjected to general fire performance (reaction to fire) tests.  As the reaction to fire performance for cables is not currently regulated in the UK, we do not believe that such performance should be seen as safety critical and it is adequately handled under “general safety requirements” [Schedule 8, paragraph 11].

5. Certain types of cable are used for specific life-safety purposes in buildings, for example in fire detection & alarm systems, in emergency lighting systems, and for providing power and control for fire-fighting equipment (e.g., sprinklers, smoke extraction).  The cables used for these applications are specified in standards to be fire-resistant and are subject to well-established tests to demonstrate the required periods of circuit integrity in the event of a fire.  This provides reassurance that cables should not fail due to the effects of fire during the evacuation of a building or during fire-fighting operations in support of life safety.

6. Standards for the testing of fire-resistant cables have historically developed at a national level across Europe, to suit local practices and building styles, though there have been attempts to harmonise.  Now that the UK has left the EU, we do not believe that there is any likelihood that suitable standards for fire resisting cables that meet UK requirements will be developed at European level, and hence our focus should remain on British standards.  [Schedule 8, paragraph 3].

7. BCA supports the concept of ‘safety critical products’ [Schedule 8, paragraphs 7 to 10] and considers that there is a strong case for fire-resistant cables used for the above safety-specific purposes to be included in the list of such products by the Secretary of State.  Indeed, cables provide a good example of the differentiation between products with general safety features, and safety critical products.  BCA supports the enhanced requirements for notification and recall of safety critical products in the event of non-conformity. [Schedule 8, paragraph 10].

9. While many product standards (including designs, materials and tests) for these cables are well-established, we consider that requirements for ‘safety critical products’ should preferably be performance-based rather than restricted to particular product designs.  Such an approach maintains the specified levels of safety while remaining technologically neutral, encouraging manufacturer innovation.  [Schedule 8, paragraph 4].

10. The draft Bill proposes that product standards may be designated by the Secretary of State [Schedule 8, paragraphs 2 and 3].  Many existing product standards are written as specifications, with detailed requirements for design, materials and testing.  Other standards of value in building and construction are currently written as codes of practice, which are drafted to incorporate a degree of flexibility in application, whilst offering reliable indicative benchmarks.  Some codes of practice may need to be revised to tighten the requirements and make the limits of application clearer.

11. The performance levels of cables for fire safety purposes are specified in a number of well-established British Standard Codes of Practice for the design and installation of safety systems, in particular BS 8519 (for power supplies), the BS 5839 series (for fire alarms, in particular BS 5839-1, BS 5839-8, BS 5839-9), and BS 5266-1 (for emergency lighting).  These standards are already referenced in Approved Document B of the Building Regulations in England, and in other UK legislative measures, but we consider that a stronger link between the ‘higher risk buildings’ foreseen in the Bill and the area of application of BS 8519 and similar standards should be developed.  In particular, this should ensure that adherence by designers and installers to the requirements of the relevant code of practice is monitored and enforced. This is especially important where the designer has a choice of grade of performance.

12. It is also important that requirements set by the Secretary of State for the conformity assessment of all safety critical products are clear [Schedule 8, paragraph 4(1)], including scope of testing and frequency of retesting.  As an example, the voluntary schemes which cable manufacturers currently adopt for fire-resistant cables require at least annual retesting.

13. As the draft Bill is largely a framework, detailed scrutiny of draft Statutory Instruments and associated guidance will be needed as and when this information is made available.  Industry should be encouraged to contribute its experience and expertise at the necessary juncture.

September 2020