FIRE SAFETY > Fire Risk Assessments

RA advises replacing fire alarm system in 2003 conversion. Is he right?

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DawnF:
It?s a building that we converted ourselves during 2003 and an enormous amount of work was done regarding fire protection to comply with the regulations at the time.  The communal hallways/means of escape was completely lined to achieve 1 hour protection and each flat was horizontally protected to an hour.  Each flat has an internal hallway with all doors, those to the communal hallway and those in the flat, having new doors and frames to FS30s.

There are 3 flats with 4 floors above ground level and the top flat comprises 2 of the floors with a protected hallway inside the flat to the top floor.

The building inspector specified mains operated detectors interconnected and wired to a separate fused circuit, which I believe is LD3 D1 along with emergency lighting.  So each flat has multiple smoke and heat detectors, with backup batteries.

I must admit this is the first time I've had a company do an assessment, as I believed I was doing everything properly already, but what with up and coming changes in legislation it would be a good idea.   I was extremely surprised that this was his advice and I requested clarification from him, but he's not been very helpful.  His assessment states this system is recommended by LACORS Guidance, which I pointed out applies to pre 1992 conversions.  (I did tell him it was converted in 2003) He just keeps saying building regs have changes since 2003 and it doesn't comply with them and this is his advice.

Try telling that to a leaseholder who would be expected to contribute approx ?1000!

I was always under the impression that building regulations are not retrospective.  

I don't know what to do and obviously am extremely reluctant to go to a lot of expense when it was clearly considered suitable for that building when it was converted.

Any thoughts will be greatly appreciated!  Thank you in advance for your time.

Dawn 

Dinnertime Dave:
Hi Dawn,

I assume you have the original certification for the conversion?

Based on the information you have provided the assessor is wrong. If it was converted post June 1992. It should be suitable for stay put and no common alarm.

May I ask what the fire action notices say. If they imply full evacuation, he may have based the recommendation on that. Cheaper to change the FAN than provide an alarm.

Or, you might just have found a fire risk assessor who doesn't assess risk.

AnthonyB:
Based on the information given it appears the conversion was done to the edition of Approved Document B (Building Regulations Guidance) applicable at the time which would indicate no communal fire alarm (only detectors with no sounders linked to automatic vents) and a stay put policy.

None of the Building Regulations changes that have occurred since 2003 would have significantly changed anything even if you were doing the conversion now rather than back then.

Building Regulations have a statutory bar meaning they aren't retrospective, but the fire safety legislation doesn't any more so just because something was OK a long time ago doesn't mean it can automatically be accepted now - the FRA would determine whether the legacy standards in place still safeguard the relevant persons in the building or whether they need changing - it's not an automatic requirement to modernise either though, often some or all legacy provisions remain suitable.

Was the assessor registered/accredited? 

DawnF:
Hello Dave!  Thank you so much for your reply!  Very much appreciated.

We do have the original certificate for the conversion.

I don't know what you mean by the fire action notice, but I have the construction notes saying that we should provide mains operated detectors interconnected and wired to a separately fused circuit.  I also have the plans showing where he wanted the sd's to go.  In fact we put in more.

Today I  managed to get a further response from the assessor to my further questions that he had refused to answer. 

I obviously asked if the building regulations are supposed to be retrospective and he said that if they were not retrospectively applied every building in Brighton would look like it did in the Victorian times.  One of the purposes of a risk assessment is to bring older buildings up to modern standards in a practicable fashion.

He quotes sections 3.26 to 3.28 of the Approved Document B 2019 and says that irrespective of internal compartmentation there is no circumstance where a 5 story building with a single escape route without lobby protection does not necessitate a Grade A system.  (this is 4 above ground).

He has already said he doesn't think it would satisfy a stay put policy as each flat would have to be lobbied, there would need to be auto opening vents and the detection system would be non-sounding and emotely monitored.

I'm sorry, I don't know what you mean by FAN.

It certainly does feel that he's not just looking at the actual risk.  However, it certainly does feel that the occupants would have plenty of warning of a fire, but I don't really understand yet the additional benefits of a Grade A system.

Thanks again!

Dawn

DawnF:
Hello Anthony  You posted as I was posting!

I do believe the assessor is register/accredited.

He says even if he came across a building that was constructed yesterday and found this he would recommend a Grade A system.

Does my reply to Dave alter your response?

Thanks again!

Dawn

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