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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Bill G on June 26, 2007, 03:12:38 PM
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Can I pick your collective experience.
I have a fire authority that are insisting upon the provision of lobbies to a single staircase , 4 storey hotel.The hotel is provided with a L2 fire alarm system. The hotel concerned had a fire certificate issued by the FA within the last two years. When it was issued they applied a single door and smoke solution to the hotel.
We would like to provide the lobbies but structurally it is impossible (without damaging the usability of the hotel). What I am seeking is advice on what you would consider to be a reasonable alternative to a lobby ( and not a second staircase !) ie automatic ventilation to the top of the stair, pressurisation to the stair case, etc
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You may want to look at installing a sprinkler or high pressure water mist system. We worked on a project for a large bank where they had issues such as this. The fire authorities in Scotland accepted the installation of a water mist system in conjunction with a smoke detection system.
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This is outrageousely over the top - tell them to wind their necks in.
Pressurisation in an existing stair is usually a nightmare. A auto vent at the head of the stair, will probably make things worse.
Maybe a manual vent. but they need to understand that we can't rebuild every building in the country.
Maybe go for a Determination under Art 36
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Many thanks -
I take your point about over the top - what they (the FA) are saying is that although the sleeping risk guide is published as a guide they are interpreting it as a "standard" and within the preface of the guide it makes the point that as a guide it is not prescriptive - but that as long as we can demonstrate that we can provide an equilivant standard then that would be acceptable. Hence I am trying to seek an equilivant standard.
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Trying to visualise the current arrangements- is it the case that all rooms open directly into a large open stairwell?
Is there a single door from all rooms- including high risk rooms such as kitchens open into the staircase as well?
No corridors serving rooms?
What are the doors like?
What type of smoke detection do you have in the stair - any detection at intermediate levels? (that at the head of the stair would be very high for a point detector and something a little more sensitive may help)
Are there any furnishings or other risk items in the stair?
Is there a night porter or other similar risk control measure in place?
Is it an historic or listed building?
Sorry for so many questions- but need a clear mental picture of the situation.
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The FRS are enforcers/policing the law they are not the exponents of the Fire Safety Duties in articles 8 to 22 of the Fire Safety Order. Undertake your Fire Risk Assessment and within that assess the risks to the relevant persons from not having a lobby. In sleeping risks premises the corridors and doors to the bedrooms are fire resistant anyway and that is the first door of the lobby protection. The door to the staircase is the second door. Therefore you have already provided the criteria for 2 door protection to the risk area ie the bedrooms. What they are asking for is 3 door protection which will then hamper the escape routes as 3 doors have to be opened to then escape into the staircase and then presumably a 4th or even 5th door to exit the premises. The guide is not prescritive and the FRS can not make it so, read the article in the FSE magazine by Rosemary Everton a top legl advisor on fire law.
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We need to get some of these issues put to determination. If we don't these over zealous enforcement officers will put the nation out of business.
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Steady guys, you need the full facts as requested by Kurnal, before you should start slagging off enforcement officers. If you are going to make statements then ensure they are informed statements.
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Many thanks so far !
In answer to "Kurnal"
The hotel is a 4 storey terraced hotel bulit at the turn of the century with a single staircase. Ground floor consists of the ancillary accommodation ie dining room, lounge and kitchen all of which are directly off the staircase with a single door. The upper floors are all sleeping accommodation , with the bedroom doors directly onto the staircase enclosure. At the top floor their are two rooms which are accesed of the staircase by a very short corridor ( 1.5metres- these two are lobbied !)). The alarm system is a BS 5839 L2 system ( in all the places etc you would expect).The doors to the rooms are a bit of a mixture of 30 min doors without smoke seals and other doors that have been made up ( again without smoke seals ) The doors need to be replaced or upgraded to the current standard ( their is no problem regarding this , it is just the provision of the lobbies!
There are no furnishings in the staricase and the owner has some private accommodation in the lower ground floor ( which is seperated from the ground floor as you would expect) and as such are their 25/7. And no the building is not listed etc.
Regarding "jokar's" comment about the status of the guide - I am being advised that the FA are being instructed to regard the guide as a "standard" and that it is for the risk assessor to justify in their risk assesment as to why they have not met the suggested standard in the guide. This is where I am finding it hard to justify any good reason as to why the lobbies are not needed , or what I can provide as an equilivant to a lobby.
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OK maybe I flew off the handle a bit (getting old and tetchy)
Jokar is right though, if you have FR room doors and FR stair doors then you have your lobby.
Job done.
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Possibly I am not explianing it well enough - There is only "one" door between the rooms and the staircase ( for all rooms with the exception of the top floor) ie the room door.
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Yeah that's quite bad really. But some of these old places don't have the room to get the doors in.
If you really can't get them in then I'd go for L1 detection (smokes in the rooms) and upgrade the room doors to FD30s.
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Another possibility would be to have L1 with smoke or Carbon Monoxide detectors in the bedrooms and have 60 minutes doors. Include a link, if it is not already there to a call centre for instant response.
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I am pretty certain your premises almost met the old prescriptive code, to be certain I would need to know the floor area, also a fire certificate was issued. In these days of risk assessment and flexibility I am very suprised if it does not continue the meet the standards of the current guides. I have included below the relevant Paragraph from the old guide, sorry its so long winded.
STAGE 3 — Travel within stairways and to final exits Number of stairways
Building with a single stairway
13.34. It will normally be necessary for a building to be provided with two or more stairways, but a single stairway of suitable capacity for the number of persons using the route may be considered satisfactory in the following circumstances:-
(a) the floor area of any upper floor of the building does not exceed 200m2, and distances of travel conform to those given in Table D of paragraph 13.7.
(b) the building has no more than 4 floors, or no upper floor is at a height of more than 11 metres;
(c) the stairway conforms with one of the arrangements described in paragraph 13.35; and
(d) in a building more than 2 floors in height access to the stairway from any room (other than a toilet containing no fire risk) is through two sets of fire doors. Exceptionally, where it is impracticable to achieve this, in premises of not more than 3 floors in height, access to the stairway from any room may be from a single fire door, subject to an automatic fire detection system being installed to the type L1 system in accordance with British Standard 5839: Part 1.
Para 13.7. Table D is the travel distances for escape in on direction only.
Para 13.35 lays down the conditions for the final exit.
I think wb has hit the nail on the head.
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Many thanks - you are right the old Lilac standard had been applied to this building (in a fashion!) but it should be noted that the dispensation for the two doors was restricted to a 3 story building. Therefore even in the old Lilac standard if you had a 4th floor you would have needed to have fitted lobbies. In the new guides it has made a few subtile changes ie for a three storey building the suggested standard is an L2 system together with single door protection ( which in effect is a downgrading of standard when compared to the Lilac) . A 4 storey has a suggested standard of L2 and lobbies - with no form of dispensation .(se figures 50 &51 of the sleeping guide).
Regarding the idea of a L1 system - I feel a bit uncomfortabel with this - Are we not just playing with words here. For an average property of this type the difference between an L2 and L1 system is negligable ,possibly a detector in the roof space !. The provision of an L1 system does not compensate for the non-provision of for example a lobby at ground floor level . My understanding is that the lobbies are there to provide a protected route for the most vulnerable people namley those on the top floor with the furthest travel distance. My gut feeling is that in order to find an equilivant I should be seeking something that deals with smoke penatration from the room into the staircase. Hence the idea thought of the AOV.
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I would agree that an L1 system would not be good compensation for the lack of lobbies. The real risk of fire is from the bedrooms or kitchen/lounge, and they have detection already.
Smoke extraction/venting only deals with smoke. It does not hold a fire at bay like 2 30 minute doors will.
So, looking at Jokars suggestion of 60 minute doors. The only issue there is smoke can still affect the escape route for the time the door is open during escape or firefighting. So to offer a more onerous solution in true FRS style, 60 minute doors backed up with smoke extraction (Not venting) would acheive a similar (Or better) level of protection as lobbies. (Extraction would be extremely costly, but I think venting does not keep smoke from entering the escape route, it may help to keep conditions more tenable though.)
BUT a risk assessment may show that the building would be evacuated before any firefighting took place, and anyone escaping from the room of origin would be escaping while the fire was reasonably small so not much smoke would be entering the escape route. So 60 minute doors may suffice.
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And also anyone drunk and NOT escaping is behind a nice 60 minute door. :)
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This is a difficult one and there is not an easy answer to it.
We need to carefully anlayse exactly what benefit the lobby gives us and then try and provide this benefit in a different way. I hate lobbies but they do a job in a simple and effective way.
The other thing is that in these type of cases the duty on the assessor is far more than on the Responsible person.
The responsible person only has to do what is reasonably practicable. And in this case it is to follow competent advice.
The assessor has to provide the solution and personally underwrite it, and unless you cover yourself by fully consulting with the fire authority, if we step too far outside the comfort zone of the guidance there is no hiding place or refuge for the assessor between writing the report and the witness box.
To get anywhere with this we need ask : What does a lobby provide in these situations? The answer is two fold- it keeps any appreciable fire loading well away from the critical door to the staircase and it provides a tiny buffer zone which may just about prevent a bit of smoke from entering the stair as the occupants leave- but this is pretty tenuous. Once the occupants have left it provides two sets of fire door seals between the room and the stair.
We talk of the lilac guide and the red one before that. Let us also remember that when the lobby approach was first proposed as a design solution in these cases there was no such thing as an L3 system and if we were lucky there may have been a detector in the stair. Furniture safety regs were unheard of and fire door seals not invented. So todays lobby with L2 alarm, fire door seals and modern furnishings represents a far safer solution - the standard has increased greatly over the years.
What can we do about it?
Eliminate risk in the staircase and especially no furnishings.
Control the fire risk in all rooms control of ignition sources and combustible materials especially kitchen and lounge
Keep all fire load as far from the doors as possible.
Particularly focus on the ground floor rooms - kitchen and dining room. Can we eliminate the door between kitchen and stair and give direct access from kitchen to dining room without coming through the stair- that door would take some hammer. If there is alternative escape from the ground floor rooms you could provide the equivalent to a lobby with a drop down curtain behind the door.
If replacing doors make sure we replace the complete doorsets and an hour door would be a better bet, installed, hung and maintained to the highest standard with a full range of intumescents in all areas- hinges, locks etc.
Provide an L1 alarm and detection system- ie all spaces and all rooms not just those opening onto escape routess
Select a multi fuction detector such as Gent SQuad and set the response criteria as sensitive as possible.
Management and supervision 24/7. Careful selection/ vetting of clients- ie a fairly high standard hotel not an HMO. All these to be maintained in the long term with a good management system in place and every element carefully inspected, tested and recorded on a weekly basis.
This may be enough to achieve an equivalent level of safety to a design compliant solution without the additional management controls in place.
The are some other alternative approaches worth considering eg water mist system in rooms or smoke exhaust system in rooms- there are some pretty interesting powered extract systems on the market that only require 600mm extract ducting .
Hope this is some help and good luck - please let us know the outcome.
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But does not the upgrqading to an L1 system still only cover up to 3 floors? Is it posible to lobby the rooms from inside?
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Good idea with the lobbies if it is workable. I still don't see the benefit of an L1 system. The existing L2 should have detection in all rooms off the escape route anyway, any smaller cupboards opening onto the escape route could simply have combustibles and ignition sources taken out of them.
An upgrade to L1 does not replace the actual function of the lobbies. Protection of the escape route is paramount. Early warning is nice but it doesn't stop the smoke/fire.
Kurnal, with regards lowering the risk in all rooms: Surely that should be done anyway to comply with the fire safety order. (ALARP) ;)
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Standard Hotel alarm sytem is heat detectors in the rooms smokes in the corridors - I would suggest smokes in the rooms - this would buy a little more time. You will need more time because the staircase will be lost earlier than with a modern design.
Changing from FD30 to FD60 is pointless but if it keeps people happy then why not.
As for smoke extraction, this is completely unworkable. You could use pressurisation but it steel seams like a sledgehammer to crack a nut to me.
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I find it quite amazing how on this site people lambast Fa for being so prescriptive and then say well it met the old guide so it must be OK. '
I think Bill G says it all
'This is where I am finding it hard to justify any good reason as to why the lobbies are not needed , or what I can provide as an equilivant to a lobby.
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The bottom line is that you cant make a silk purse out of a pigs ear.
It's one thing to have standards for new buildings, but with existing buildings you have to do what is reasonably practical.
If you cant get a building to meet the standard you need to consider what the implications are. If you cant fit the lobbies in and any other solution is either unworkable or stupidly expensive then you will have to do without.
Redcuce the risk to "As Low As Reasonably Practicable" is not the same as reduce the risk to zero.
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Changing from FD30 to FD60 is pointless but if it keeps people happy then why not.
I suppose you could look at it from the point of view that by the time a 30min door has been breached people should be out of the building anyway and any firefighting operations would necessitate that door being open so it is not protecting anyone.
So, while it looks good on paper, the actual benefit of it is minimal.
This is all assuming that a 30 minute door will last 30 minutes in a true fire scenario, which tends not to be the case as the test conditions under BS476 are not really the same as the destructive power of a fully involved room.
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I would like to thank you all for your commets so far - but it is at this point that I should point out.
I am a FA enforcemnt officer and at the moment our local focus is upon hotels. Our policy is to serve enforcment notices upon premises that do not meet the current "standard/guide" in relation to lobbies and detection.
My concern is that over the years we have issued certificates on premises when in the light of day we possibly should have said were not fit for purpose. I appreciate that when dealing with existing buildings they will never up to the standard that can now be achieved in a new building (we should try and achieve as close to the 100% as is possible - just because it is existing should not be an excuse to lower standards to far) . I have no desire to close buildings down but I am concerned that as an enforcment officer I am obliged to serve notice upon this type of premies fully aware that it is almost impossible for the occupier to reach the standard . I am due to go out to several premises of this type in the next week - of which I will end up serving notice on every one of them and I will not have any realistic idea of how to achive a reasonable solution. It may or may not surprise you that we have not recieved any guidance (from our HQ's) as to a reasonable solution that may be aceptable to this type of problem( the head is firmly in the sand).
My ultimate dilemma - am I just serving notice on places that will never achieve a standard and thus close down, in favour of the "lodge" type premises that are being opened up all over the place. It make me wonder who were the stakeholders consulted of the new guide?
(I should point out that all of the comments above are mine and in no way reflect service policy !)
I note that the majority of respondants to my request have been private consultants and I thank you for your comments - it would be useful if any servivng FSO have had similar problems and what guidance have they rcieved form their HQ's.
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My authority are also intent on enforcing the guide rather than the order. So as to avoid a perscriptive and often unachievable approach I have started to ignore part 2 of the guide and concentrate on part 1, which puts the onus on the occupier to come up with a solution.
In this case the fire risk assessment need only demonstrate that 'if there is a fire, heat and smoke will not spread uncontrolled through the building to the extent that people are unable to use the escape routes'. I can't see why an L2 alarm and single line fire resistance cannot achieve this in this case. The half-hour standard often quoted is to achieve additional protection to the buidling to firefighters, which does not have to be considered by the occupier with regard to the FRA.
My thoughts only.
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Bill,you know what they say,'if you stick your head in the sand,all everyone will see is an arse'
I understand your dilema as an enforcement officer,and the lack of guidance from either HQ or the government .What has your line manager said?By serving the notice,you may force some hands.i.e. the hotel may appeal,and the service will have to decide on a policy.It is not your fault,as an I.O. that you are in this position.Or pass the file up to a senior officer,as you cannot deal with it due to a lack of service guidance.rest assured,if you don't cover yourself,they will look to blame you. :-(
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BillG
I have been following this topic with great interest, however I must say at this stage your identity is rather ingenuous, and you should have been honest and upfront at the outset, which makes me wonder what type of IO you really are.........could Joe public trust you?..I have my doubts because of your actions so far. I was an FPO, when the world was real......and would never have tried to pull the wool over anyone's eyes. I agree with Tully.s analysis of this real or ficticious situation, unless I can be persauaded otherwise.
Conqueror.
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Bill, as a current serving officer I would offer the following advice. In the witness box you will be asked to justify actions based on knowledge and experience. The guides offer helpful advice to assist in establishing a consistency of standards where possible... but as with all guides are open to interpretation, discussion and variation. Where experience and knowledge come in is helping to determine which variations are acceptable or suitable and which are ill founded or dangerous.
Whether a serving officer or a serving risk assessor, we are all seeking to help in determining those fine lines, offering alternatives, and most helpfully discussing the foundations on which the guides were built on in the first place.
Explaining to a defence barrister that you were simply following service policy might leave you in an uncomfortable position. You do need to apply yourself to service policy... whilst taking some of the comments provided on threads such as this to assist in shaping policy from here on in.
Good luck with that,
Paul
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Bill G would you accept an engineered solution?
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Just to add to and clarify a few points earlier.
The lobbies that I hate are those created by taking a piece out of a room to create a lobby on each room and totally destroying a lovely old building - and achieving nothing but compliance on paper with the guidance.
I aggree with Wee B and CivvyFSO re there being little benefit in a 1 hour door except that it makes a positive statement of intent otherwise someone could offer to upgrade a 25mm door using intumescent products and you probably could not argue with that- but for the hour it has to be a new doorset, it has to be a good fit and in my experience the average chippy takes a bit more care installing these.
Civvy FSO yes you're right that the risk should be reduced in all hotel rooms ALARP, but remember that the official definition of this includes consideration of difficulty, disruption and cost- and so where the passive protection falls short it is reasonable to take additional time, trouble and expense to compensate. Things like Care home standard bedding and furnishings, RCD on all the electrics, TVs that cannot be left on standby, no trouser presses, boil dry safe kettles,
And as for conq.s comments- whatever happened to the Bull**** and Persuasion Act 1854? The old timers were experts on that one.
Should brigades have policy on this sort of thing- I dont necessarily think so .That takes us back to the days of prescription. I would say if it falls below guidance standard the FSO is empowered to make a judgement based on the risk assessment which will be different in every case. If you dont like it serve a notice, the RP can appeal and each case will be properly heard on its merits.
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This is all assuming that a 30 minute door will last 30 minutes in a true fire scenario, which tends not to be the case as the test conditions under BS476 are not really the same as the destructive power of a fully involved room.
Youve been watching too many training films mate - If you can get a hotel bedroom to burn like a Furnace i'd like to see it!
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The old ceilings will be through in 20 min way before the doors give out. But anyway this opens up a real can of worms once you start attacking building defiances. This country is packed full of +100 year old buildings from National Trust, Heritage, Hotels, including boarding Schools, colleges and universities that have dorms that open out to single staircase with no lobbies. Over the years I think many of these places have done a good job and spent fortunes upgrading fire alarms systems from the old gent bell to modern L1/2 systems. I know I done quite a few myself that have a myriad of stuff including beam detectors, laser aspiration in ducts and ceilings, IR/UV flame detectors and touch wood none of them had suffered any ill fate. They are pretty much on the ball with risk assessments. These places just won’t upgrade and fit lobbies I think National Trust and the like would take it to the European courts first rather then destroy the building fabric!
In the meantime they are still hundreds of places that still do nothing towards the RRO, are fairly modern could comply but don’t want to/don’t care and will sit it out and wait for someone to go round first. I’m sure you could pop into any ropey looking flats in our cities over 3 stories and find plenty to find fault with them instead would be a good start. Even the local councils have barely got to grips with HMO's and various reports show it will take many more years just to bring these into line.
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To follow up on a couple of points made -
From Kurnal "Should brigades have policy on this sort of thing- I dont necessarily think so .That takes us back to the days of prescription. I would say if it falls below guidance standard the FSO is empowered to make a judgement based on the risk assessment which will be different in every case".
I would agree that it is difficult for FA's to give definitive guidance and this does lead by default to perscription. But I would argue that it would be reasonable for guidance to given on a range of equilivant solutions that would be acceptable to a FA. For a FA to offer absolutly no guidance other that do what we say and it you dont like it appeal is not satisfactory in my opinion. At some stage either the occupier, possibly via an appeal or a consultant will come back to us and offer some solutions and we will have to make a judgemnt then.All we are doing is delaying the discussion or hoping that they blindly put in the lobbies into the rooms ( and thereby rendering the rooms unusable)
Perhaps what I am seeking is a discussion document on the various alternatives as to what would be a resaonable alternative to a lobby.
Regarding twsutton - yes I would consider an engineer solution
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I think a lot of this relates back to a fundamental flaw in the RRO guides. They dont really help you through the Risk Assessment process.
Most of the guidance on means of escape is just a repeat of what was in the building regs/BS standard of a few years back. It doesn't help with the realities of FRA in exisitng buildings. Consideration of difficulty, disruption and cost is a fact of life and the guides completely miss this very important point.
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I am trying to understand the modern concept of fire risk assessment so please bear with me.
It appears that double door protection and AFD is acceptable but a one hour door with AFD is not or at least there seems to be some doubt about it.
a) In both solutions it will take one hour for a fire to penetrate into the staircase enclosure. No difference.
b) Products of combustion entering the staircase enclosure.
Two points to note, the first all rooms have a smoke reservoir from the top of the door to the ceiling level. The second point is the AFD will initiate the evacuation in the early stages of a fire.
With the first solution, assuming the lobby is large enough, it could act as an air lock with little or no smoke will entering the staircase enclosure.
With the second solution considering the smoke reservoir, the fire being in its initial stages and in most situations two people being allocated a room, no more than 10 seconds to pass through the door, then I would think only a small amount of smoke would enter the staircase enclosure and certainly not enough to make it impassable.
The ground floor could be a problem, but would it be necessary for the occupants to pass through the staircase enclosure to reach a place of ultimate safety?
I believe this could be backed up with calculations but I am not certain.
My question why cannot the second solution be acceptable to most?
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With the second solution considering the smoke reservoir, the fire being in its initial stages and in most situations two people being allocated a room, no more than 10 seconds to pass through the door, then I would think only a small amount of smoke would enter the staircase enclosure and certainly not enough to make it impassable.
The ground floor could be a problem, but would it be necessary for the occupants to pass through the staircase enclosure to reach a place of ultimate safety?
I believe this could be backed up with calculations but I am not certain.
My question why cannot the second solution be acceptable to most?
You have got it in one TW. Do the calcs and if they support the argument - problem solved. No one can argue with that. The guides are just for people who dont want to use other techniques to prove the building is safe.
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Its not risk assessment you dont understand - its the laws of physics captain.
1 - Periods of fire resistance are not the same as real time.
2 - Lobbies do more than just act as an "air lock". To be honest this has never been properly investigated. But the principle is that two doors provide a break in the pressure distribution. this reduces the risk of smoke penetrating the stair enclosure.
3 - If doubling the fire resistance was the same as providing a lobby we would have done away with lobbies years ago.
In this case there is only one door and not enough space to fit the next one in having identified this "deficiency" in the premises we must consider what impact this has on fire risk. In my view the impact is that the stair will fill with smoke a bit quicker than it would do if we had a lobby. Its almost impossible to work out how quickly. Some people will offer a CFD model but they are not very good at modelling closed doors.
In my view upgrading from heat detectors in the bedrooms to smoke detectors would give earlier warning which would adress the shorter available egress time.
Kurnal suggests that we could also go the extra mile in reducing ignition/fuel sources in the rooms. This isnt a bad idea.
You could go for pressurisation but this would be a nightmare and, in my view, an unreasonably onerous solution given the small increase in risk
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Regarding the smoke reservoir - I presume we are talking about two specifc areas - ie the height of the room of origin , in many old turn of the centuary houses the depth of the ceiling can be up to 1 metre. Secondly the reservoir created by the staircase enclose itself. In this situation the reservoir would as expected be at the top level(4th floor). The level where the occupants are at most risk. In order to relive this reserviour would it not be reasonable to provide an openable vent at this level ( connected to the FA). I must also say that I am develping a bit of a bee in my bonnet that AOV's can play a part in the solution or is venting a red herring.
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If you open a vent at the head of the stair you will drop the air pressure in the stair thus drawing more smoke into it. This is a bad thing.
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If the hotel with single door and AFD was "Certified" by FRS then why are they asking for an upgrade? A Fire Certificate if issued is not renewable unless there has been a change of condition which effects the existing means of escape.
Was an actual Fire Certificate issued in respect of the premises?
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Its not risk assessment you dont understand - its the laws of physics captain.
1 - Periods of fire resistance are not the same as real time.
2 - Lobbies do more than just act as an "air lock". To be honest this has never been properly investigated. But the principle is that two doors provide a break in the pressure distribution. this reduces the risk of smoke penetrating the stair enclosure.
3 - If doubling the fire resistance was the same as providing a lobby we would have done away with lobbies years ago.
I agree with you wb I do not understand either fully.
1. I agree, in my experience it is likely to be longer. But the fire resistance did not concern me I would have said half hour would be satisfactory.
2. As you said "To be honest this has never been properly investigated" that’s the problem.
3. When doubled door protection was first introduced for small buildings we did not require AFD. When active measures became more acceptable and AFD started to be installed maybe we should have done away with it.
As I asked, do you think the staircase would become impassable in the second solution trapping occupants.
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If the hotel with single door and AFD was "Certified" by FRS then why are they asking for an upgrade? A Fire Certificate if issued is not renewable unless there has been a change of condition which effects the existing means of escape.
Was an actual Fire Certificate issued in respect of the premises?
But the RRO as part of its working has made any past certification irrelevant by removal of the FP Act & everything under it. So the FRS must look at a premises in the current light of day and assess if, using current standards, a reasonably practical solution is being used to give adequate MoE, warning, etc where neccessary.
Obviously in their opinion the FRS feel the use of a solution under old codes does not afford the neccessary level of safety to meet the requirements of the order, hence the need to look again - what went before doesn't have much bearing if it isn't effective
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But the hotel was certified within the last two years. Has quidance changed significantly since then? Unless there has been a significant change to guidance since issue of the fire cert then the only extra area which should be looked at for a risk assessment would be the fire safety measures due to the processes taking place in the hotel. eg kitchen. Has anything happened to render the MOE, certificed within the last two years as adequate, inadequate?
If a risk assessment of the means of escape is made using the same guidance as was used for the MOE Certificate then surely they will be the same or very similar, depending on interpretation?
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The differnec is the FRS don't deal with risk and do not understand it. They have no Fire Safety Duties under RR(FS)O and therefore have resorted to bullying tactics to make decisions based on guidance which they claim is prescriptive. Existing premises cannot meet modern building standards in a number of cases and therefore the risk in the building has to be assessed against the guidance documents standards. The CLG documents are not design guides and therefore are open to interpretation. The law is not open to interpretation but a number of FRS are attempting to do this and hopefully they will fail.
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Straight for the jugular
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From a FA point of view the "policy" that has been adopted is that the standard applied in order to issue a fire certificate is not relevant . On 1st October new guidance document's were issued and the standards suggested in the guides are the ones we are to enforce. In the majority of cases this does not pose a problem as the standards are very similar if not the same as before . Unfortunatley there are a cupple of minor changes . But these minor changes have profound implications upon the occupier concerned.
Regarding the type of building talked about there is a subtile change - an upgrading of the standard ie L2 protection + lobbies. The previous standard gave an element of disgression on the lobbies - this has been removed. In the past the FSO made the proffesional judgement regarding the interpretation into the standard actually applied. Today the onus is upon the RP (either with or without their advisor) to come up with the proffesional judgment / justifiacation as to why they have deviated from the suggested standard , it is not the job of the FA to do it for them. So we end up with the situation of the FA of being (or appearing ) to be over the top.
As a FSO all we are seeking from the RP is a rational justification of why lobbies are not relevant in this type of building or an equilivant if required. This is where I asked the first question - call me old fashioned but although I am a FSO I am uncomfortable of appliying a particular standard to which I am unclear as to what would constitue a reasonable package as a alternative (or combinations of packages) .
In order to summerise so far would it be reasonable to assume that the majority would see that an upgrade to an L1 together with "proper" FD30(s) doors and frames , this together with the statement made by kurnal back at item 18.
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Double door protection in a single staiway building has always been the subject of healthy debate. If a single set of doors provides 1/2 hr protection then double doors will provide 1 hr and, theoretically, a smoke lock.
What this effectively meant that in a multi occupancy building you could have people working on the 4th floor totally unaware that on the unoccupied first floor a fire is burning merrily away and the first time those on the know about it is when, after an hour, it breaks through into the stairway up the stairs and after another hour into the 4th floor, in theory anyway. That of course if it does not show itself through the floors between the accommodation first.
To think that people could still be in a building in the dead of night totaly unaware that the building has been on fire for over an hour is totally unacceptable.
This is all very theoretical of course but I can tell you that in the Fire Service theories can become an event.
Any Firefighter will tell you that early detection is the key to safety.
Someone made the point on this site that the FRS do not understand risk. We do but people do not believe us.
Remember that Fire & Rescue Services do not write the guides.
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Yes they started out with firefighters writing the guides but it was such a cock up that they got somebody else to do it.
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Don't get nasty Brian. Doesn't fit the character of a professional, if you are one.
Can't ever remember firefighters writing guides though.
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Sorry mate but you started going down the "firefighters know best cos we fight fires etc. etc" line. I was just heading you off at the pass.
The ODPM did set up a team to draft the guides made up of seconded fire service people. It all took too long and in the ned the job was taken away from them. To be fair, it wasnt all their fault.
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I understand your dilema as an enforcement officer,and the lack of guidance from either HQ or the government .What has your line manager said? :-(
The government has given guidance, eleven volumes of it. That is the government position, carefully written, endlessly re-written, checked word for word by a team of professional stakeholders including the CBI, HSE, CFOA, HMI, FSB, someone representing Sainsburys (can't remember that abbreviation), FBU, and ultimately, as WB says, a team of fire consultants, (most of whom have sensibly buggared off to Australia now) and of course, the BRE who actually did write the sleeping guide. After all that they were finally signed off by the ODPM and the last standing HMI, Geoff Bowles who dedicated his last two years to trying to get them right.
They were painfully aware that old buildings could never achieve modern standard compliance and consequently gave advice on other ways of improving the fire safety in premises such as this one, which seem pretty unsafe to me!
Upgrade the doors and retro fit sprinklers. (Or water mist, or as I saw in a garage once, copper piping with nail holes punched at suitable intervals).
Alternately we could wash our hands, adopt the 'crash dummy' test and put an appropriate number of little fire engine signs in the entrance porch and let the public decide if they really want to pay money to sleep in a one-fire engine hotel rather than a five-fire engine hotel.
Lots of states in the good 'ol USA prompted sprinkler fitting in hotels by refusing to let federal employees sleep anywhere else.
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Sorry mate but you started going down the "firefighters know best cos we fight fires etc. etc" line. I was just heading you off at the pass.
Sorry brian not this old chestnut it harks back to the seventies with Colin Todd using the same old line unfortunately using the same presentation as you and some others do. If you wish to put the FRS or anybody else down for that matter, then use reasoned argument, nor sarcastic comment and snide remarks.
Colin would have achieved a lot more if his presentation had been a lot more reasonable which would have improved the fire safety profession no end.
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I understand your dilema as an enforcement officer,and the lack of guidance from either HQ or the government .What has your line manager said? :-(
The government has given guidance, eleven volumes of it. That is the government position, carefully written, endlessly re-written, checked word for word by a team of professional stakeholders including the CBI, HSE, CFOA, HMI, FSB, someone representing Sainsburys (can't remember that abbreviation), FBU, and ultimately, as WB says, a team of fire consultants, (most of whom have sensibly buggared off to Australia now) and of course, the BRE who actually did write the sleeping guide. After all that they were finally signed off by the ODPM and the last standing HMI, Geoff Bowles who dedicated his last two years to trying to get them right.
They were painfully aware that old buildings could never achieve modern standard compliance and consequently gave advice on other ways of improving the fire safety in premises such as this one, which seem pretty unsafe to me!
Upgrade the doors and retro fit sprinklers. (Or water mist, or as I saw in a garage once, copper piping with nail holes punched at suitable intervals).
Alternately we could wash our hands, adopt the 'crash dummy' test and put an appropriate number of little fire engine signs in the entrance porch and let the public decide if they really want to pay money to sleep in a one-fire engine hotel rather than a five-fire engine hotel.
Lots of states in the good 'ol USA prompted sprinkler fitting in hotels by refusing to let federal employees sleep anywhere else.
Yes the guides have been a good start, but it is those at the sharp end who have to deliver,and fill in the gaps.Otherwise my brigade would not need any policy/proceedures at all if the guides were that good.Unfortunately,when so called guidance is given without any supporting background e.g. suggesting the use of ordinary lifts for evacuation, we have to apply that.(As the authors obviously have a benchmark standard in mind to apply,perhaps they would like to share it with those involved in the year long study into this being carried out at the University of Shanghai.might save some time and money.) we will get the same old complaints of'inconsistency' from inspecting officers-but the nature of the business means that that is something Risk assessors and industry will have to live with.
'firefighters' have not written guides,I know some ex Fire Safety Officers wrote some of the guides.let the courts decide.