Written evidence submitted by the RIBA Expert Advisory Group (Fire Safety) [BSB 325]
From: PAUL Bussey F.I.Fire E, FASFP, FIIRSM, IM & PS
Whilst at School of Architecture in Liverpool 1976-79 I witnessed a lecture from the Lancashire Fire Brigade on Summerland which had a huge impact on me. We also attended the Merseyside Fire House which gave us a greater understanding of the effects of smoke , albeit non-toxic, and evacuation methods. We subsequently did a week’s design course on design of buildings including fire considerations.
Ever since I have been the go to architect in the 5 architectural practices within which I have worked for fire issues. From small 5 man practices up to my current position at ALLFORD HALL MONAGHAN MORRIS Architects, Old Street, London, with 450 architects.
Having orchestrated the fire design with fire engineers, of many theatres, conference centres, schools, universities, offices , shopping centres and residential buildings . I have been an Institution of Fire Engineers (IFE) member and fellow for 25 years. As a result I have been using “fire engineering” methods to provide alternative solutions to all these building types , meeting the Building Regulatory functional requirements and saving clients considerable costs. Post-Grenfell I have had to seriously reconsider these “fire engineering” approaches as these have progressively diluted the UK regulations since the 1960’s. However my day job, for our clients and my directors, expect me to continue with these “industry-wide acceptable” approaches . In parallel I have been working with the RIBA Fire Expert Advisory Group to explore these conflicting demands with a view to helping society learn a lesson from the catastrophe of Grenfell Tower .
I am aware of most of the loopholes in design, contracts and regulations that allow clients and project teams to “legitimately” circumnavigate the Approved Documents B1&2.
Having Worked with RIBA Architect and legend Sam Webb’s archive and my own technical library I have researched back to the London Building Acts 1930-39 up to present day and identified many changes based upon supposed improved technology and fire science that has diluted our regulations up to Grenfell. Now there is a mood to strengthen them again I feel that we need to look to the societal issues rather than the technological drivers. How did we ever end up with vulnerable occupants of all ages in :-
• tower blocks with stay put policies,
• at the end of long dead-end mechanically vented internal corridors, exceeding length recommendations in ADB.
• inadequate fire doors, fire stopping of services and compartmentation due to poor construction and maintenance
• with no viable safe refuge areas and mechanically failed fire-fighting lifts,
• no communal fire alarm or intercom to advise of the total evacuation stage
• approaching single internal staircases with no external windows for natural vent or light
• the stairs are sized for phased evacuation rather than total evacuation, and make no allowance for fire-fighter occupation
• with no alternative means of escape ( ie second stair) except by ladders upto 11m or aerial platforms 30m but rarely practiable.
• And of course no sprinklers required ( 30m on newer blocks and now 11m but only guidance!)
• Not to mention combustible cladding which was compliant with ADB Dia. 40 when installed at Grenfell………we don’t test cladding we have to rely on the ADB recommendations & manufacturers information.
• We now hear that although the ADB used to be “one-way” to meet the regulations now it will “probably” meet the regulations?
• How can we possibly be confident to sign off buildings as Principal Designers in the future with these levels of ambiguity
The DRAFT Building Safety Bill creates the opportunity to construct a better Building Regulations systems and an improved industry culture, but so much about the new regime is as yet left undefined that it offers no guarantee that we will reach that destination, and the Bill itself doesn’t address issues of contract, the actual Building Regulations themselves and the Approved Document”.
The Bill is inter-dependent on the Regulatory Reform Fire Safety Order, the means of compliance through ADB and British Standards, together with the plethora of Guides.
(I refer to that huge list of documentation which appears in slide 10 of my attached slides, all of which is mindboggling and still leads to confusion in interpretation.
How does it change the issue of single staircase buildings and the issue of automatic sprinkler protection in existing buildings, not to mention dead end conditions, no firefighting lobbies, or natural ventilation in existing HRRB’s?
This is a multi-faceted problem – embracing regulation, competence and procurement - taking attention away from the need in particular for the much promised (and much delayed) comprehensive review of Part B and the associated Approved Document guidance. We are not convinced that Guidance, when compared with prescription, doesn’t continue to be ambiguous, and of course it is still not mandatory.
The term in the Building Regulations itself “shall Adequately resist the spread of fire”!! - is VAGUE!!
Also the term “Appropriate means for early warning of fire”!! I remain unconvinced that the public or firefighters are clear about when the ‘stay-put’ policy should be abandoned and how/when training for phased alarms and evacuation will be operating in both new and existing buildings.
I am not convinced that the Bill adequately covers disabled or non-ambulant people or that ‘refuges’ are properly understood.
The other issue is clarity on access to resident flats, which is not permitted under this Bill, but is permitted under the Housing Safety Rating System by a different group of people, in particular private rented landlords. Such access can determine internal alterations which might impact on the integrity of fire safety measures.
I strongly believe that “Red Flag” symbols on items on Documents with a “Don’t change it Mr Client or Mr Contractor” with a notice “IT IS FUNDEMENTAL TO THE STRATGEY OF THIS BUILDING”
I don’t see anywhere, PROVEN compartmentation or fire stopping on all projects mentioned, and would like to refer to the RIBA Core Principles Analysis, which provides: A storyboard of ‘non’-compliance at Lakanal and Grenfell – Tower & slab blocks HRRB’s and LPS blocks elsewhere.
I will end with the fact that Grenfell failed for many reasons:
• Fire Engineering Design and Construction Complacency
• Incomprehensible framework and deregulation
• Inappropriate materials and value engineering
• Management shortcomings
• Contractual and procurement misdirection
• Maintenance inadequacies
• Firefighter training inadequacies
• Competence issues in the context of regulatory relaxation and incomprehensibility
And that the interdependency on several pieces of regulation and guidance still leaves uncertainty over ensuring that people will continue to feel safe in their homes.