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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: timandfi on February 11, 2008, 07:03:54 PM

Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 11, 2008, 07:03:54 PM
Hi
We are in the process of renovating an old Victorian 3 storey house into a B&B and have hit issues with complying to part b building regs (means of warning and escape). Our local building control have changed their requirement 3 times, initially being AFD system and fire doors but are now insisting on lobbies to ground and first floor rooms given only one open stairway. We do not want to compromise safety but do want to retain integrity of the building. Due to layout we cannot do the lobby appaoch so initially looked at a sprinkler system as a compensatory feature but have run into problems with this due to water flow and pressure plus high ongoing costs and lack of companies willing to quote. We have now instructed a Fire Protection specialist (30 yrs service in brigade) who has suggested a access panel in the roof which looks a bit like a velux window and opens automatically if a smoke alarm goes off. This will mean us taking down the roof on the second floor landing and making a sort of shaft to the roof space, but may well be the best option. We will also be installing a fully addressable L2 (or L1 if required as a compensatory feature) AFD system and fire doors.

To you experts out there - does the above seem an acceptable solution for a 6 bedroom B&B and do you think Building regs and a consutling fire officer would accept? Can anyone else think of any other compensatory measures for not having lobbies or any reasoning which suggests the property will be just as safe without lobbies which is what the Building Regs people say they must have if we do not fit lobbies?
Other info potentially of use:
1. Ground, 1st and second floors. No basement.
2. Total height to 2nd floor (floorboards) from ground outside door is 7.3 m
3. According to my survey when we bought the house floorspace is 213.88 m sq
4. travelling is via a staircase (but think it is classed as unprotected as it is the original Victorain mahogony staircase?) all the doors onto the staircase are firedoors with the exception of a cupboard) Bottom of staircase exists to the final exit (front door) via an entrance vestibule (about 4 feet in depth)

Thanks
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 11, 2008, 08:07:43 PM
Timandfi
I have read and re-read your posting and cannot make sense of why lobbies are being required and the proposed consultants solution. There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas. I can only assume there is something unusual about the layout such as long dead end corridors or inner rooms or open plan staircase or something?  
Have the building control given any justification for requiring lobbies?  

Did your consultant have experience in a fire safety enforcement department or was he just an operational chap?

Have you downloaded the Fire Safety Order guidance documents from the http://www.communities.gov.uk/publications/fire/firesafetyrisk4
 website  and the building Regulations approved document B from the planning portal site?

Take a look at this thread which may be relevant to your quey:

http://www.fire.org.uk/punbb/upload/viewtopic.php?id=2493
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 11, 2008, 09:03:59 PM
Hi Kurnal

Yes staicase is the original mahogony staircase but is as I understand it now protected as all doors onto it are firedoors and deposits to the final exit with 4 feet of the base of the staircase. Building regs just quote and quote para 4.34 of approved document B, the provision of lobbies as it is a 3 storey building. They say as we will not (we cannot) put in lobbies we need compensatory measures or justification to prove it will be as safe as if it had lobbies - any ideas?
Building regs say the clause comes into effect because we will be applying for change of use to a B&B which they view as a material change hence the application of part B.
I'm confident we can meet all the RRO requirements just part B which is the problem.

I've got a pdf of the floor layout and a photo of the stircase if you want to see?

Fire safety chap did hold a post in a large hotel chain as their fire safety officer hence industry experience and was on the inspection side (sorry can't recall proper name for it) in the brigade.

thanks
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: wee brian on February 11, 2008, 09:06:07 PM
Sounds like your consultant is a bit of a plumb. As kurnal is (politely) suggesting 30 years in the brigade doesnt make you a design expert.

As for building control changing their minds - Its you or your design team who have to work out what is necessary and then get the design approved. If you ask an enforcement officer what he wants he will ask for gold plated door handles.

Try and get a full plans approval before you spend too much, once the plan is approved the BCO can't change his mind.

To be honest this aint hard. A professional building surveyor or architect should be able to sort this out without needing a fire safety consultant (oops that's me out of a job).
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 11, 2008, 09:09:38 PM
We have got a full plans conditional approval but only if we install a sprinkler system (this was on building regs advise, I know what you mean now about gold taps!) but we then encounted the problems with installing this and are now looking for alternative solutions.
Building regs will not budge and as I said just quote part b clause 4.34.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 11, 2008, 10:15:29 PM
4.34 is all very well as a goal  when starting with a blank sheet of paper for a new building (and still nearly everyone ignores it because it can be so disproportionate) but in an existing building conversion of only three floors it cannot be reasonable or achieved in most cases. Why is it local authority and goverment officials are always so good at finding imaginative ways to spend somebody elses money?

Yes email the plans across would be interested in taking a look- but am away for a couple of days so may be Thursday before I get to see them.
How entrenched has this issue become and I presume the application for approval has been made which would prevent you from going down the approved inspector route?

In this case if it has become entrenched you will have to construct an argument back from basics, identify and analyse the possible benefits a lobby may provide (Note nowhere is the size of a lobby defined!) and then work the argument back from there. I think thats another angle that has been aired on this forum in the past.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 11, 2008, 11:27:14 PM
Thanks for the  email - had a quick look, see the problems making lobby approach impossible, certainly on the first floor, would be interested to see a photo of the ground floor  looking towards the kitchen from the front door.

Also theres a difficult little cupboard on first floor level on the plan without fire door?

I misread your first posting about the ventilation solution and misunderstood where he was coming from. Trouble is creating a negative pressure in the staircase will not do much to protect the persons trying to escape as it is likely to draw smoke from a room on fire into the stair just as persons are needing to escape. Ventilation of stairs is ok for firefighters when it is already full of smoke as they arrive  but the need in this case is to keep it clear of smoke for long enough for the fire to be detected, the people to be awaken and to respond, and to travel from their room to a place of safety. This is the role of the fire detection system and the fire door in the design of the building- the remit of the building inspector- and the way the building is furnished and used- the remit of the fire authority.

If its not too late I would go back to  a written fire strategy document to include an analysis of the benefits of a lobby, what it does and how it does it,  and explore how much contribution this makes to the available time for safe evacuation of the building, what limitations it creates, what can go wrong with it, what are the other costs in terms of use of the building and spoiling of the character. Now if you can get the inspector to recognise weaknesses of these improvised lobbies in an existing building then you can start to get him to perhaps start to take cognisance of the role of management strategies.

Sprinklers were a great idea- they bring benefits far beyond compensation for the lack of lobbies. The benefits are out of proportion - and so are the costs. They are a great solution but not on a like for like level playing field comparison.

Have you been down the path of offering a full BS5839 part 1 detection and alarm system with multi sensor detection, heat, dual chamber oprical smoke and CO which should ensure the earliest detection of most types of fire together with self closers and the highest standard of fire  doors and smoke seals?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 12, 2008, 08:50:12 AM
Thanks for all your help.

Why would having a plan already approved prevent us using an approved inspector? Could we not submit a new plan from scratch, obviously paying a new fee? Relations with the authority are not good although think using the FPE has helped but no real proof of that until things move along. We feel they have backed themselves into a corner insisting on the lobbies and do not now want to loose credibility by deviating.
I have suggested an L1 system as a compensatory measure, offered to put in 60 minute fire doors, use fireproof paint etc but can't say anyone has been too interested.
How would we go about getting a written fire strategy document, not something I would feel comfortable doing myself and think the local authority would ignore it if it did not come from a professional as they have already indicated this. What sort of cost are we looking at for this tye of thing? I guess I am thinking if we could submit a new full plans proposal to an approved inspector with a fire strategy document then this could be a better way forward than the velux smoke extraction. I guess my idea would be a consultant who could project manage the whole thing interms of putting the plan and fire strategy document together, submitting it to an approved inspector and running with it through to approval stage.

Putting a firedoor on the cupboard on the first floor would not be an issue at all. Will try and get a photo from bottom of staircase to kitchen door and mail to you.
Probably does not help but forgot to mention earlier that the property was a B&B until 1996, hence why it already has soe fire doors and an old AFD system (we never intending using this). It was taken out of business rates in 1996 and whilst there is no planning permission converting it back to a residential dwelling it seems the council have no record of a it ever being a B&B hence why we need change of use consent.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Big A on February 12, 2008, 03:39:16 PM
Quote from: timandfi
Thanks for all your help.

Probably does not help but forgot to mention earlier that the property was a B&B until 1996, hence why it already has soe fire doors and an old AFD system (we never intending using this). It was taken out of business rates in 1996 and whilst there is no planning permission converting it back to a residential dwelling it seems the council have no record of a it ever being a B&B hence why we need change of use consent.
If you could find proof that your premises had been a B&B previously, would that help to side-step the council?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 12, 2008, 04:11:53 PM
I guess I have had proof in terms of the Valuation Office have confirmed to me that the premises were registered for business rates as a B&B until 1996 (they told me the rateable value) and then transfered back to residential council tax, the BCO also new it was a B&B until 1996, not sure how?
I'm not sure that it would help though as is there not some sort of 10 year rule in terms of planning? So as it has been a nome from 1996 to 2007 it is over 10 years?  
It would be a fantastic outcome if that was the case as I guess it would mean that we did not need pp for change of use and as such BC would not be involved in the same way. But I don't think it is going to happen!

I have manged to find out that we could put in another full plans application, maybe using an approved inspector, so maybe it is worth spending or funds on what Kurnal suggested in terms of justification and additional measures eg upgraded AFD rather than the ventilation approach previously suggested to us. Is there a common view on how acceptable this maybe? As a novice to this who all along has wanted to do things above board but reasonably, fairly and sympathetically to the building it is all a bit overwhelming and confusing with the differing views and advise.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Midland Retty on February 12, 2008, 04:47:30 PM
I can see why you are confused!!

To be perfectly honest I would have thought an L1 system with 30 minute fire doors would have been the way forward in these premises. I dont even think 60 minute doors are required, for a start are the walls 60 minute rated cos if not there's no point.

Clearly I haven't seen the property and there maybe reasons why the Build. Control Off has asked for additional measures. But I can't see why on the info you have posted.

Any chance you can contact the BCO again and ask him why he has asked for lobbies or similar solutions? and then post his reply here so we can all scrutinise it further...

What is for sure is that the smoke control /ventilation system proposed is of no benefit and as Kurnal said just wouldn't really work.

Im just totaly mistified why the BCO wants these extra bits and pieces ... it just doesn't scan...
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Dragonmaster on February 12, 2008, 05:09:24 PM
Far be it from me to cast nasturtiums on the knowledge of BCO's, but perhaps this one is actually looking at smoke ingress into the escape route, which is the main reason for asking for lobbies.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 12, 2008, 05:32:55 PM
Hi Midland Retty

Yes we have challenged the BCO (head of) who is backing up his team, here is an extract from reply to our challenge, I have XXX anything which may shown anyones name..let me know your what you think to the logic:.......(I should also point out at the stage previous to this we had be advised by one of the BCO's to submit a letter asking for a relaxation of the regulation, no mention of any compensatory features required and in our ignorance we did this and you guessed it, it was rejected.) also happy to email anyone floorplans and a picture of the staircase if you are interested.

Letter as follows:

You are correct in stating that Approved Document B allows suitable alternative solutions to those contained in the document.  The difficulty that arises when an alternative solution is proposed is concerned with assessing the alternative proposal.  Approved Documents set out details of how the mandatory requirements of the regulations can be met.  Anyone wishing to offer alternative solutions should set out how and why the alternative is capable of meeting the mandatory requirement.

It is not permissible to merely omit part of the Approved Document requirements without there being clear evidence that to do so would not reduce the standard of safety in the building.  Where people wish to deviate by omitting a feature there is an implicit requirement that some compensatory measures will be applied that results in an equivalent degree of safety.  

An alternative approach to following approved document requirements is to provide an engineered solution that takes into account all of the factors that influence safety, quantifies these factors and demonstrates an appropriate solution.  Such an approach will involve engaging an appropriately qualified fire engineer.

In the case of your development, AD B1 para 4.34 clearly requires that, where there is only one escape stairway serving a building with more than one storey above the ground storey, the added protection of a protected lobby or corridor is required.  In addition to this appropriate means of warning of fire is required.  BS 5839 -1:2002 indicates an L1 or L2 system is appropriate.  The difference between the two is that L2 systems are fitted in defined parts of the building whereas L1 systems are fitted throughout.  In practice it is recognised in the British Standard that, because of the need to specify most rooms in small premises such as this one, the code effectively requires L1 in most situations.  Escape lighting is required in all escape routes.

The above paragraph sets out the basic Approved Document requirements.  Your proposal, if lobbies are omitted, provides no significant additional compensatory measures.  Neither does it provide any quantified and reasoned argument to demonstrate the building would be less safe than is required if the lobbies were omitted.  To permit the development to proceed without the lobbies would, therefore, in the absence of compensatory measures or justification in the form of an engineered solution, be to simply ignore the guidance.  As I have indicated, the design can be based on a fire engineering solution in which protection is provided to compensate for departure for some departure from normal guidance.  The omission of the lobbies must be justified.

Insofar as your comments about an nearby authority are concerned if you provide me with the details I will explain the requirements and the only acceptable approach to the individual concerned.

Finally I would point out that on receipt of your previous letter the matter was again raised with a Fire Officer (not Mr XXXX) and he confirmed the Fire Authorities opposition to approval of the scheme without the provision of lobbies or a suitable engineered solution or justification.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 12, 2008, 06:04:16 PM
Quote from: timandfi
Hi Midland Retty

Yes we have challenged the BCO (head of) who is backing up his team, here is an extract from reply to our challenge, I have XXX anything which may shown anyones name..let me know your what you think to the logic:.......(I should also point out at the stage previous to this we had be advised by one of the BCO's to submit a letter asking for a relaxation of the regulation, no mention of any compensatory features required and in our ignorance we did this and you guessed it, it was rejected.) also happy to email anyone floorplans and a picture of the staircase if you are interested.

Letter as follows:

You are correct in stating that Approved Document B allows suitable alternative solutions to those contained in the document.  The difficulty that arises when an alternative solution is proposed is concerned with assessing the alternative proposal.  Approved Documents set out details of how the mandatory requirements of the regulations can be met.  Anyone wishing to offer alternative solutions should set out how and why the alternative is capable of meeting the mandatory requirement.

It is not permissible to merely omit part of the Approved Document requirements without there being clear evidence that to do so would not reduce the standard of safety in the building.  Where people wish to deviate by omitting a feature there is an implicit requirement that some compensatory measures will be applied that results in an equivalent degree of safety.  

An alternative approach to following approved document requirements is to provide an engineered solution that takes into account all of the factors that influence safety, quantifies these factors and demonstrates an appropriate solution.  Such an approach will involve engaging an appropriately qualified fire engineer.

In the case of your development, AD B1 para 4.34 clearly requires that, where there is only one escape stairway serving a building with more than one storey above the ground storey, the added protection of a protected lobby or corridor is required.  In addition to this appropriate means of warning of fire is required.  BS 5839 -1:2002 indicates an L1 or L2 system is appropriate.  The difference between the two is that L2 systems are fitted in defined parts of the building whereas L1 systems are fitted throughout.  In practice it is recognised in the British Standard that, because of the need to specify most rooms in small premises such as this one, the code effectively requires L1 in most situations.  Escape lighting is required in all escape routes.

The above paragraph sets out the basic Approved Document requirements.  Your proposal, if lobbies are omitted, provides no significant additional compensatory measures.  Neither does it provide any quantified and reasoned argument to demonstrate the building would be less safe than is required if the lobbies were omitted.  To permit the development to proceed without the lobbies would, therefore, in the absence of compensatory measures or justification in the form of an engineered solution, be to simply ignore the guidance.  As I have indicated, the design can be based on a fire engineering solution in which protection is provided to compensate for departure for some departure from normal guidance.  The omission of the lobbies must be justified.

Insofar as your comments about an nearby authority are concerned if you provide me with the details I will explain the requirements and the only acceptable approach to the individual concerned.

Finally I would point out that on receipt of your previous letter the matter was again raised with a Fire Officer (not Mr XXXX) and he confirmed the Fire Authorities opposition to approval of the scheme without the provision of lobbies or a suitable engineered solution or justification.
I think one of your problems is that AFD does not provide adequate protection to the stairway from smoke. Lobby protection gives improved smoke protection in single stairway conditions. Because of the sleeping risk would there not be a AFD system installed anyway?
A resolution may be a pressurised system for the stairway or an alternative MOE from the upper floor levels.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 12, 2008, 06:20:31 PM
So what makes you think the ADF is not sufficient, we will have smoke detectors, emergency lighting, signage to all the escape route. The AFD was passed on the full plans sunmission at L2 level (but also then with a sprinkler system to the escape route as BCO had requested, see first post). No possibility of an alternative MOE (method of escape?) to second floor, the house is not that big! Beleive the travel distant is actually within that of a small premises scope, but obviously we do not fit that criteria as have the second floor.
All along we have said would be happy to go to L1 if it helps but no one seems interested.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: TickityBoo on February 12, 2008, 08:26:13 PM
Even the CLG guides suggest 3 storey premises are unlikely to need lobbies (it is not until the premises comprises 4 storeys that a lobby is indicated as a requirement for smoke control purposes, according to their diagrams).
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 12, 2008, 08:57:27 PM
Sorry but can you expalin what a CLG guide is please? I can then look it up and use this with the BCO. Thanks
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: messy on February 12, 2008, 11:38:45 PM
It's the Govt guidance offered to help compile a fire risk assessment

Have a look here for the sleeping risk guide

http://www.communities.gov.uk/documents/fire/pdf/151339


Messy
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 13, 2008, 07:53:13 AM
Quote from: timandfi
So what makes you think the ADF is not sufficient, we will have smoke detectors, emergency lighting, signage to all the escape route. The AFD was passed on the full plans sunmission at L2 level (but also then with a sprinkler system to the escape route as BCO had requested, see first post). No possibility of an alternative MOE (method of escape?) to second floor, the house is not that big! Beleive the travel distant is actually within that of a small premises scope, but obviously we do not fit that criteria as have the second floor.
All along we have said would be happy to go to L1 if it helps but no one seems interested.
Because in small premises L2 would probably end up to L1 standard anyway.
All the provisions you state are nothing new that would go towards a compensatory factor.
Your only hope, I think, is to get a FRA carried out and present it to with your submission. It may be that BC would be happier if someone else to took ownership of the risk.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: CivvyFSO on February 13, 2008, 10:21:28 AM
One (Simplistic) way of looking at the L1/L2 issue is: Upgrading to an L1 system only gives any benefit if a fire starts in a cupboard so it is no replacement for lobbies. Lobbies are there to keep smoke out of the escape route, the only other way to do this is to physically remove the smoke, i.e. Smoke control as ADB suggests.

For what it's worth, the BCO won't be interested in the CLG guidance, and MOE is "means of escape".
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Midland Retty on February 13, 2008, 01:11:20 PM
Quote from: Dragonmaster
Far be it from me to cast nasturtiums on the knowledge of BCO's, but perhaps this one is actually looking at smoke ingress into the escape route, which is the main reason for asking for lobbies.
I don't doubt for one minute that he is.

But I think its a bit OTT personally. But thats just me.

The more i think about this then the only other thing I can now suggest is looking into smoke control system that ADB and CivvyFSO suggest.

This might be a ball ache though, i just don't see how it could work effectively in that type of premises for the reasons Kurnal suggested earlier in this topic, and you will need to get the experts in to ascertain just how easy this would be to achieve.

I wish there was a simplistic solution for you, but alas Building Control are the lead authority in this case and what they require will differ from the requirements the fire authority would ask for.

I'd be happy with single line of FR and an L1 system in that type of premises, if lobby or corridor approach cant be achieved.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 13, 2008, 04:02:37 PM
Back from my travels- lots of new postings since I last looked at this most interesting of cases. Heres my view on it so far for what its worth

1- Change of use from residential 1b to residential 2b does represent a material change of use and to keep within the law it is right to submit an application.Many dont bother- but if you dont you are in breach of the Building Regulations and this could be enforced within 12 months of the change taking effect, you could be served with a notice equiring changes to be made.

2- As far as the Building Regs is concerned, they would normally just look at the present use and work from this rather than what happened 10 years ago

3- Once you have made an application with a building control authority, either local government or approved inspector their protocols do not allow you to switch horses halfway through the race, this is to prevent people trying one after the other till they find someone prepared to accept their scheme.

4- The building inspector does not have to work to ADB- its usually down to the applicant to identify the design strategy adopted. ADB annex does list other documents references as well, the DCLG guidance has no status as far as the buiding Regs is concerned but it would be very interesting in an existing building to take diagram 50 of the Sleeping guide as the design strategy - after all building Regulations B1- B5 are Functional requirements and the sleeping accommodation guidance is being taken as best practice in enforcement cases!

5- Avoid at all costs any determination or appeal to the Secretary of State, these arguments are always  decided on purely technical argument and nearly always find against the apellant.  Does ADB recommend a lobby in this case? Yes. Have you provided one? No Have you provided an alternative system using  pressure differentials to protect the stairs ? No. Appeal dismissed. The secretary of state wont be in the least interested whether lobbies would in this case have any benefit whatsoever, just whether they are there or not.

6- In practical terms you need to resume dialogue with the inspector. Present an alternative offer to him as I suggested in an earlier posting and give him space to ask for a little more. I would speak to the senior fire safety officer for the area- ask him for advice, get him on board and show him your proposals and compare it to the DCLG guide. Despite what the building inspector says the fire officer cannot reasonably turn down a proposal that fully conformes to the Govermnent guide.

7-I would suggest multi sensor detection to an L1 standard to give the earliest warning of any type of fire. And all fire doors to the stair to a pucker standard with (if necessary) new frames. FD30S doorsets. If he still holds out for a lobby I would then offer swing free self closers. Would you prefer two doors likely to be wedged open or one pucker dink fire door you can rely on?

8- You were looking at sprinklers but were unable to find an installer or had a problem with the mains I believe. Before burying this as a solution I would get a quote from someone like aqua mist of Wakefield, which is a low pressure water mist system. Heres their web site http://www.aqua-mist.co.uk/
you could also try one of the many sprinkler suppliers listed here http://www.bafsa.org.uk/mission.php  

Hope this helps and keep us in touch with progress
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 14, 2008, 07:51:07 AM
Quote from: kurnal
Timandfi
I have read and re-read your posting and cannot make sense of why lobbies are being required and the proposed consultants solution. There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas. I can only assume there is something unusual about the layout such as long dead end corridors or inner rooms or open plan staircase or something?  
Have the building control given any justification for requiring lobbies?  

Did your consultant have experience in a fire safety enforcement department or was he just an operational chap?

Have you downloaded the Fire Safety Order guidance documents from the http://www.communities.gov.uk/publications/fire/firesafetyrisk4
 website  and the building Regulations approved document B from the planning portal site?

Take a look at this thread which may be relevant to your quey:

http://www.fire.org.uk/punbb/upload/viewtopic.php?id=2493
Kurnal
There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas.
They may be operating for some time and are out of the control of BC. They may be unaproved conversions operating on a wing and a prayer.
Unfortunately, new or converted buildings are not assessed under old standards.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 14, 2008, 08:30:10 AM
Yes nearlythere but are these "smallish 3 storey hotels with a single protected staircase and full detection in all areas" not fit for purpose?

Does it really make any contribtion to the safety of an existing building if we make these people put in a telephone kiosk type lobby at the entrance to every room in the buiding creating dead space, incredible ugliness and inevitable abuse by wedges? For what benefit? Many of these lobbies are so small that to pass through them both doors have to be opened at once in order to pass through. And if we dont is the building not fit for purpose?

I am proud to say that in my career as an enforcement officer I was never responsible for imposing this monstrous idea on any of my clients though it often happened in the early days under the original Fire Precautions Act red guide for hotels.  In the early days it was easier to justify full detection in lieu because many fire authorities would ask for detection in staircases only for these buildings - later detection to L3 and L2 came along and it was no longer considered to be a trade up to detection in lieu of lobbies. From then on it got a little more difficult to win.

I think that the goal in ADB for lobby protection of a single staircase is a good one for new buildings where it can be incorporated in a sensible way. But in an existing building it is unreasonable and impractical if it means taking a bite out of the corner of every room. If I could see any benefit to it I would go along with it. But nobody has ever been able to convince me what this benefit is and how it works- when the rule was first contrived there was little or no detection, no fire or smoke seals, no swing free self closers available on the market.

HM Goverment guide to fire safety in sleeping accommodation  published in 2006 diagram 50 shows a 3 storey building with single door protection and full detection and in the courts this document is being held up as best practice.

HM Government approved document B published in 2006 says lobbies are required in these circumstances.

Both are different, both are enforced by Government staff- which is the right standard in this case?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 14, 2008, 08:41:37 AM
Thank you so much to all for your help and advise, wher to start as a novice is this is overwhelming to say the least but I am sure once we get started the points you have all made will be invalueable.

An interesting point on the last posting by Kurnal you say the sleeping accommodation document is being held up as best practice in the courts, is there any information freely available on any such cases? May be useful to cross reference in any justification we submit to BCO.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on February 14, 2008, 10:16:10 AM
It appears most of you are approaching this problem from a FRA angle as far as I am aware BCO`s enforce the ADB using a prescriptive approach. If it conforms to ADB it is approved, if it cannot then you need to consider compensatory means.

In this case I would suggest lobbies are needed to control smoke therefore you need to provide means of controlling smoke.

1.   AFD will not control smoke and I believe this is why they will not accept an upgrade.
2.   Sprinklers will extinguish a fire in its initial stages therefore limiting the amount of smoke produced
3.   Pressurisation of the escape route would control the smoke
4.   Automatic ventilation would not control the smoke but would keep the escape route passable.

I would think the last three suggestions would be acceptable to BC. Failing that the last option would be an engineered solution with lots of calculations or a well argued solution, or maybe the both.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: jokar on February 14, 2008, 12:47:29 PM
TWSutton,  I agrre with the pressurisation example, the doors are already there, they will have existing leakage paths and therefore may be the most sensible solution to an entrenched problem.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Midland Retty on February 14, 2008, 12:57:20 PM
Quote from: nearlythere
Quote from: kurnal
Timandfi
I have read and re-read your posting and cannot make sense of why lobbies are being required and the proposed consultants solution. There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas. I can only assume there is something unusual about the layout such as long dead end corridors or inner rooms or open plan staircase or something?  
Have the building control given any justification for requiring lobbies?  

Did your consultant have experience in a fire safety enforcement department or was he just an operational chap?

Have you downloaded the Fire Safety Order guidance documents from the http://www.communities.gov.uk/publications/fire/firesafetyrisk4
 website  and the building Regulations approved document B from the planning portal site?

Take a look at this thread which may be relevant to your quey:

http://www.fire.org.uk/punbb/upload/viewtopic.php?id=2493
Kurnal
There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas.
They may be operating for some time and are out of the control of BC. They may be unaproved conversions operating on a wing and a prayer.
Unfortunately, new or converted buildings are not assessed under old standards.
Nope - Id except single stair case condition with L1, 30 min fire doors. As does the sleeping accomodation guide
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 14, 2008, 01:09:55 PM
Don't understand the comments from Jokar, can you expand further please?

Also picking up on one of Kurnals points, whats the best approach to get the brigade on side? The BCO has not told me who they have consulted only that it is not the main point of contact at our local station. Should I ask BCO or just approach the brigade and is so who / what position are they likely to hold? Just thinking that given the points made that they do not have grounds to object looking at fig 50, pg 98 of the sleeping accom document may be good to explore their opposition first before putting a new proposal to BCO. That is of course assuming BCO have really discussed with them!
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: jokar on February 14, 2008, 01:17:35 PM
You can have a pressuried staircase in some staircases in lieu of lobby approach as the purpose of both is to not allow the opportunity for the ingress of smoke into a staircase.  Normal fire doors can have intumescent strips and cold smoke seals around them, these have to be removed in the case of pressurisation to allow for a leakage path at each floor level for the air.

You can ask advice from the local FRS, just telephone the number given for the headquarters, they are tasked to give advice on fire prevention, means of escape and restricting the spread of fire under the ACT that they work under.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: wee brian on February 14, 2008, 01:29:39 PM
Pressurisation is a nightmare in existing buildings - it will cost a packet.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 14, 2008, 01:47:15 PM
Thanks wee brian

I can confirm I do not have a packet to spend! As I have said previously we are not looking to compromise safety but are seeking and hoping for a solution that is sympathetic to a building built in 1895 and one which is practical for its size and level of occupation at a max of 12 persons including the owners.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 14, 2008, 06:40:12 PM
Quote from: kurnal
Yes nearlythere but are these "smallish 3 storey hotels with a single protected staircase and full detection in all areas" not fit for purpose?

Does it really make any contribtion to the safety of an existing building if we make these people put in a telephone kiosk type lobby at the entrance to every room in the buiding creating dead space, incredible ugliness and inevitable abuse by wedges? For what benefit? Many of these lobbies are so small that to pass through them both doors have to be opened at once in order to pass through. And if we dont is the building not fit for purpose?

I am proud to say that in my career as an enforcement officer I was never responsible for imposing this monstrous idea on any of my clients though it often happened in the early days under the original Fire Precautions Act red guide for hotels.  In the early days it was easier to justify full detection in lieu because many fire authorities would ask for detection in staircases only for these buildings - later detection to L3 and L2 came along and it was no longer considered to be a trade up to detection in lieu of lobbies. From then on it got a little more difficult to win.

I think that the goal in ADB for lobby protection of a single staircase is a good one for new buildings where it can be incorporated in a sensible way. But in an existing building it is unreasonable and impractical if it means taking a bite out of the corner of every room. If I could see any benefit to it I would go along with it. But nobody has ever been able to convince me what this benefit is and how it works- when the rule was first contrived there was little or no detection, no fire or smoke seals, no swing free self closers available on the market.

HM Goverment guide to fire safety in sleeping accommodation  published in 2006 diagram 50 shows a 3 storey building with single door protection and full detection and in the courts this document is being held up as best practice.

HM Government approved document B published in 2006 says lobbies are required in these circumstances.

Both are different, both are enforced by Government staff- which is the right standard in this case?
I agree with you entirely Kurnal and I can recall yonks ago that double door protection in single staircase conditions over 2 storeys was the norm. This was relaxed in many cases with the introduction of new technology in the form of AFD which seemed to cure all ills.
Everybody in this site would agree that full AFD in small premises could be a reasonable compensatory factor under the circumstances but unfortunately the enforcement authority does not.
We have to remember that the technical guides are exactly that, guides. But with this BC it is the law.
I have no doubt that a good lawyer advised by a good Risk Assessor could convince a court that the place is fine but the cost would be prohibitive.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on February 14, 2008, 08:14:06 PM
Quote from: nearlythere
I agree with you entirely Kurnal and I can recall yonks ago that double door protection in single staircase conditions over 2 storeys was the norm. This was relaxed in many cases with the introduction of new technology in the form of AFD which seemed to cure all ills.
What do you consider the reasons for double door protection I believe it is to control the movement of smoke and if that is correct then AFD by itself will not be a satisfactory solution? AFD combined with automatic ventilation yes.

What is your rationale with regards to AFD being satisfactory by itself?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 14, 2008, 08:39:48 PM
Conversely TW for this particular scenario- building in a silly little lobby into the corner of each room in an existing building- how does this help anybody?

Remember the many buildings ruined in this way in the early days of the FP Act guides, in those days smoke detection was unusual and if it was installed usually covered the staircase only, in the days of screwing asbestos sheets to the back of panel doors and glueing and screwing one inch rebates to existing frames. We had furniture made of dangerous polyuerthane foam and widespread use of coal fires and smoking was the norm. Electrical equipment was protected by wired fuses and RCDs were rare - and then with 80mA tripping current. No rules on PAT testing.

There was never any talk then of why it was done - it was double door protection. A fire would have to burn through two fire doors and smoke would have to pass two sets of rebates to affect the stairs. No science to it , and no requirements were made for the size of the lobby- I have seen 4 inches between two doors.

Now we have FD30S, full detection, no smoking, safer furniture, 30mA RCDs as the norm, central heating, PAT testing, and we are still asking people to ruin an EXISTING building by taking a corner out of each room to create a lobby?

We will know of the fire early before the smoke level descends to the top of the door of the room involved, the smoke and fire seals will do their job and the stair will remain sufficiently safe to enable escape.

If we are seeking to prevent smoke from a room on fire from entering the staircase does it make sense to ventilate a stair within the evacuation phase when the slightly negative pressure caused by the stack effect will draw smoke from rooms into the stair just as people are needing to escape?

Does anybody have any experience of pressurising a staircase in what is essentially a private house? I have never heard of it and cant see it as a practicable solution.  Where would we put the plant room?

Sprinklers or water mist- yes I wholeheartedly agree, but I contend its a sledgehammer to crack a nut - bringing huge benefits but out of proportion to the identified crux of the problem.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 14, 2008, 09:23:39 PM
Picking up on on earlier point hs anyone got a view on how best to approach the fire officer and get him on side prior to us opening dialogue again with the BCO?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 14, 2008, 10:30:56 PM
Hi Fiona
Call the local fre and rescue service HQ, ask for the number of your area fire safety office. It may be
Scarborough Fire Safety Department North Marine Road, Scarborough, North Yorkshire, YO12 7EY
 01723 374433

If it isnt they will put you right.

Ask to speak to the senior fire safety enforcement officer for your area. Ask them to visit you to give you advice or if you can visit them. If you visit them take your photos and plans.  They will have a file following your building regs application.
Be straight with them tell them of your problems and ask for their advice, taking all we have discussed into account. They are usually nice people who are willing to help. Dont ask them to take sides or to help you take on the BCO. They wont. But draw them into giving an opinion which you can later develop into stronger support. Just something like a verbal opinion that in this case they would not be concerned with your proposals.  

An experienced officer is most likely to take a reasoned view, a less experienced personmore likely to hug the codes.
So show interest in the inspector ask questions such as how long in the service, how long on the trucks,  where they have served,  how they enjoy their job, what they find rewarding.

If you think they may be fairly inexperienced in terms of fire safety dont draw them into committing themselves - ask them to consider and come back to you later. They will then bounce it off one of their colleagues before digging themselves in.

You will then be armed to revisit the BCO knowing whether or not the brigade has sympathy with your position. It may then be worth having a tripartite meeting at your place confident that you know the brigades view and the psychology will do the rest.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: messy on February 14, 2008, 11:01:43 PM
One more suggestion, Take a copy of this entire thread (and any on other forums!) with you to your meeting with the fire safety team. It will be a good reference source for you and will be able to help the FS Officer understand your argument.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 15, 2008, 06:53:26 AM
timandfi
Wait a day until I do some final research.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 15, 2008, 08:27:52 AM
Thanks again for all the help and support and is very very much appreciated.
Will wait to hear on your further piece of research Nearlythere.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: AFD on February 15, 2008, 09:08:03 AM
Without going into the ins and outs of the lobbies.

If the problem is the protection of the escape staircase i.e. single door or lobby, how does an L1 system compensate for the lack of a lobby ?

The risk rooms and routes onto the stairs that the lobbies would be used to protect the staircase route, would already be covered by AFD with an L2 !

Also without looking at the full guidance and standards, can it be done with single door etc. what about a positive pressure ventilation system for the staircase ( i.e. keep the smoke in the rooms and out of the stair ?)
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: AFD on February 15, 2008, 09:11:02 AM
Sorry ! I forgot to add I think London FRS have similar buildings with this solution in, ie one big fan in/on roof
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: 1stclasschef on February 15, 2008, 10:33:19 AM
Hi I have worked in the hospitality business for many years and have owned 4 guesthouses/hotels as well in that time, not all at once though! I have never worked in a place that has a lobby as extra fire protection, and cannot think of any, except the large hotels where I now live that have them, there are many guest houses hotels and B&Bs, 3 storey places, one staircase, no other means of escape, other than climbing out of the window.

Why do these regulations not apply to self catering cottages/houses, I stay at a 4 bedroom cottage in cornwall, that can sleep 7-8 people, it has 2 battery operated smoke alarms, and a fire blanket in the kitchen and a small extinguisher, no fire doors, etc. yet have 4 people or even 1 person stay at your own home which you let a couple of rooms for B&B and everything kicks in regulation wise.

With these new fire regulations, I can personally see the smaller operaters i.e 3 rooms or less not existing any more in the near future, which will be a shame.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 15, 2008, 12:13:03 PM
Quote from: 1stclasschef
Why do these regulations not apply to self catering cottages/houses, I stay at a 4 bedroom cottage in cornwall, that can sleep 7-8 people, it has 2 battery operated smoke alarms, and a fire blanket in the kitchen and a small extinguisher, no fire doors, etc. yet have 4 people or even 1 person stay at your own home which you let a couple of rooms for B&B and everything kicks in regulation wise.
Because  a self catering cottage is not a B&B, guesthouse or hotel. It is essentially a single family dwelling.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: 1stclasschef on February 15, 2008, 12:28:29 PM
Yes It is a single dwelling, but still run as a business, paying business rates, fire risk in my opinion no less than having 4 or 6 people stay in your b&b, infact, fire risk could be more in a self catering house sleeping 7 or 8 people, no owner on site the occupants could smoke in the rooms, fall asleep, set fire to the house...
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: CivvyFSO on February 15, 2008, 01:09:04 PM
In the house the people are living together as a family unit and as such are less of a risk to each other than 6 separate families/couples sleeping in seperate rooms.

Nearlythere, the cottages still come under the fire safety order, the occupants are still relevant persons. It doesn't quite come under the umbrella of "single private dwelling".
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 15, 2008, 01:14:45 PM
One more thought on our options, in the event of not getting a resolution to this current situation. As I understand it BC are involved because of the change of use. If we were to only do 3 bedrooms (6 persons) as B&B we do not need planning permission so is it correct to assume we do not need building regs? I accept we need BC if we put in ensuites where they have not been before etc but in relation to ADB and the lovely lobbies?? And if this is the case do all the letting rooms need to be on the first floor?

We would not change the plan to install the L2, fire doors and all the requirements of the RRO. Just do less rooms to avoid change of use.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 15, 2008, 03:13:33 PM
Quote from: timandfi
One more thought on our options, in the event of not getting a resolution to this current situation. As I understand it BC are involved because of the change of use. If we were to only do 3 bedrooms (6 persons) as B&B we do not need planning permission so is it correct to assume we do not need building regs? I accept we need BC if we put in ensuites where they have not been before etc but in relation to ADB and the lovely lobbies?? And if this is the case do all the letting rooms need to be on the first floor?

We would not change the plan to install the L2, fire doors and all the requirements of the RRO. Just do less rooms to avoid change of use.
You would still need BC approval because it is a change of purpose group. If you used only the first floor as guest rooms then BC may not require double door protection.
But as you know anything could happen.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on February 15, 2008, 04:02:35 PM
Kurnal I would agree with you if it is a silly little lobby into the corner of the room then it is not fit for purpose and you should find an alternative.

You state “There was never any talk then of why it was done” well there certainly was in my brigade, maybe because a BCO had been asked in court why he had required double door protection and was unable to give a satisfactory reply. He was systematically ripped up for the proverbially. It was discussed at some depth and the consensus of opinion was for smoke control which I still accept. I agree not scientific but if it does not achieve this aim then it is not an acceptable solution. Any other theories would be interesting.

I accept the smoke reservoir above the door limiting the amount of smoke getting into the staircase so I withdrawn my comments about AFD.
 
When the door closes in the room of origin how can the slightly negative pressure caused by the stack effect makes things worse? The door is closed the small amount of smoke in the staircase is expelled. The only way a large volume of smoke would enter the staircase if a door burnt through or self closer were not fitted and with AFD this should not happen.
 
The improvements in safety you highlighted will reduce the fire risk but not eliminate it, so in the case of a fire you still have the problem of smoke control.

Back to this problem I think Timandfi needs to establish why the lobbies are required. If they are as I suggested controlling the movement of smoke then

1. Sprinklers or water mist are discounted for the reasons you stated
2. Pressurising a staircase again for the reasons you stated.
3. AFD and automatic natural ventilation discounted which I disagree with you.
4. Finally the preferred option is AFD to a L1 standard combined with an explanation why. Provide calculations to show how quickly the occupants of a room involved, could vacate the room and how long the door would be open. Provide smoke calculations taking into account the reservoir above the door and how much smoke would enter the staircase. To what degree this smoke would hinder the escape of other occupants or something on those lines.

I think it is essential for Timandfi has to make a good case for his alternative solution to convince the BCO.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: messy on February 15, 2008, 07:10:21 PM
Can somebody tell me what would be wrong with 1 hour fire doors instead of lobbies?

Yes - they are a bit 'lumpy' and yes- you don't get the smoke reservoir that a lobby provides, but this assumes that persons would be escaping from the room of origin.

How often do people need to escape from the room of origin? Assuming the occupants did need to evacuate that room, how much smoke would enter the staircase with them? I suggest that for the vast majority of cases, if the smoke is at the level which allows occupants to self rescue, it would not create the thick plume which would cause difficulties in the stairwell.

In addition, how long would it take for 2 persons (an average room occupancy) to escape through an open door in a fire situation? Probably a little quicker than if negotiating two doors in a tight lobby scenario such as Kurnal described earlier. Then the door closes behind giving plenty of time for others to pass by it.

I agree with Kurnal's earlier observations that lobby protection (in some cases) is yesterday's technology and perhaps with difficult buildings such as the one in question, a tad more lateral thinking might be helpful
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on February 15, 2008, 07:58:17 PM
Quote from: messy
Can somebody tell me what would be wrong with 1 hour fire doors instead of lobbies?
Using your philosophy I don’t think you need 1 hour fire doors 30FDS would be sufficient as 30mins for MOE is usually considered adequate.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 15, 2008, 10:48:58 PM
Quote from: messy
Can somebody tell me what would be wrong with 1 hour fire doors instead of lobbies?

Yes - they are a bit 'lumpy' and yes- you don't get the smoke reservoir that a lobby provides, but this assumes that persons would be escaping from the room of origin.

How often do people need to escape from the room of origin? Assuming the occupants did need to evacuate that room, how much smoke would enter the staircase with them? I suggest that for the vast majority of cases, if the smoke is at the level which allows occupants to self rescue, it would not create the thick plume which would cause difficulties in the stairwell.

In addition, how long would it take for 2 persons (an average room occupancy) to escape through an open door in a fire situation? Probably a little quicker than if negotiating two doors in a tight lobby scenario such as Kurnal described earlier. Then the door closes behind giving plenty of time for others to pass by it.

I agree with Kurnal's earlier observations that lobby protection (in some cases) is yesterday's technology and perhaps with difficult buildings such as the one in question, a tad more lateral thinking might be helpful
2 x 1/2fr doors are not there to provide 1 hr protection. They are there to provide a smoke lock. The validity of this is questionable in all circumstances and appears to be more of "thats the way it has always been, so we'll keep it in the books."
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 16, 2008, 02:55:20 PM
Not sure I agree with or understand the comment re needing BC for 3 bed rooms? There are B&B's opening all over with only 2 or 3 rooms and no suggestion of BC involvement, I could name a number that have done this here in the last 6 months and I definately know BC not involved, this applied to the house 2 doors away from me and he has had the local fire station officer round. My understand was BC only got involved if we applied for a Planning permission change of use. In we only do 3 bedrooms we do not need to apply for change of use and are still classed as a domestic dwelling, no commercial rates etc.
I fully accept we would still need to comply with the RRO but do not see the grounds for BC involvement.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Ricardo on February 16, 2008, 05:31:17 PM
Quote from: timandfi
An interesting point on the last posting by Kurnal you say the sleeping accommodation document is being held up as best practice in the courts, is there any information freely available on any such cases? May be useful to cross reference in any justification we submit to BCO.
timandfi: see the Sparrow Hawk Hotel case in Lancashire which I can forward to you if you send me your email address.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: PhilB on February 16, 2008, 06:16:58 PM
Quote from: nearlythere
2 x 1/2fr doors are not there to provide 1 hr protection. They are there to provide a smoke lock. The validity of this is questionable in all circumstances and appears to be more of "thats the way it has always been, so we'll keep it in the books."
Quite correct Nearlythere 1hr fire door is not the answer, the lobby is for smoke control...not a smoke lock..... but to prevent smoke entering stairs by reducing the pressure of the hot smoke.

Could one fire door fitted with cold smoke seals for cool smoke, and intumescent strips for when things heated up provide a suitable alternative...probably yes.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 16, 2008, 06:59:14 PM
Quote from: PhilB
Quote from: nearlythere
2 x 1/2fr doors are not there to provide 1 hr protection. They are there to provide a smoke lock. The validity of this is questionable in all circumstances and appears to be more of "thats the way it has always been, so we'll keep it in the books."
Quite correct Nearlythere 1hr fire door is not the answer, the lobby is for smoke control...not a smoke lock..... but to prevent smoke entering stairs by reducing the pressure of the hot smoke.

Could one fire door fitted with cold smoke seals for cool smoke, and intumescent strips for when things heated up provide a suitable alternative...probably yes.
PhilB this is an interesting view and a new one, I understand intumescent strips but have not heard of cold smoke seals. What do these do and could you maybe point me in the direction of website to source these?

Thanks
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 17, 2008, 10:22:25 AM
Hi
Found the cold smoke seals on a Goolge search. Thanks
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Deadendburied on February 17, 2008, 12:14:25 PM
First post for me.  

I've read this thread with interest and it raises some interesting points, the most straightforward one being that what is being proposed, supported with a suitable & sufficient Fire Risk Assessment, and well managed, would mean little difficulty in meeting legal obligations under the Fire Safety Order.  Unfortunately this doesn't help with the Building Regulations.

With hindsight, some pre-application discussions with a number of approving bodies might have found one with a more sympathetic view of the proposals (apparently this does happen!!!)

My advice would not be to contact the local Fire Safety Officer.  This is likely to be seen as at best trying to bypass the system and at worst playing one authority off against the other.  This is unlikely win favour with either party.

In terms of reference to the Fire Safety Order in Building Control Consultations, my understanding is that the Fire Authority respond firstly on compliance or otherwise with the Building Regulations, benchmarking to ADB unless specific variations are detailed, and secondly, any "Additional" requirements to meet the legal obligations of the Fire Safety Order or other legislation.

The requirement for the Fire Authority to advice on matters of Fire Safety is open to local interpretation.  Some still provide the full unpaid consultancy role of old, with those that have fully embraced the change to a professional auditing and enforcement authority, considering reference to guidance on either their own or Government websites, and very generic verbal advice as meeting their legal obligations.   The guiding principal is I understand "its your risk, you manage it", with the footnote reading ".... and if you don't have the expertise to do it yourself, you should employ someone who does, to do it on your behalf".
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Ricardo on February 17, 2008, 02:14:25 PM
Quote from: timandfi
Hi
Found the cold smoke seals on a Goolge search. Thanks
timandfi
The following may also be of use to you, see page 122 onwards and also figure 65 for an easy to follow diagram

http://www.communities.gov.uk/documents/fire/pdf/151786
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on February 18, 2008, 08:33:58 AM
Quote from: Ricardo
Quote from: timandfi
An interesting point on the last posting by Kurnal you say the sleeping accommodation document is being held up as best practice in the courts, is there any information freely available on any such cases? May be useful to cross reference in any justification we submit to BCO.
timandfi: see the Sparrow Hawk Hotel case in Lancashire which I can forward to you if you send me your email address.
Don't thnk this is the same issue Ricardo. From what I read in the Sparrow Hawk Hotel case there did not seem to be fire doors on the rooms at all. In timandfi's case the issue is about have to provide two.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 18, 2008, 08:44:06 AM
Timandfi
To answer your question on the number of bedrooms and building/ planning law, you may need to take legal advice. I personally dont know where the definition of use of a building is founded. If the Building Regulations are subordinate to Planning on this - I think they may be- you may have a point. The material change of use is quite specific under building Regulations- it is words to the effect of "where a building is to be used as a hotel where previously it was not"

TWS
In this particular EXISTING building, if lobbies are to be installed there is no option but to create a silly little lobby in the corner of each room. That is what the BCO would have timandfi do. I dont disagree that in a new building a properly considered and well laid out lobby can make a significant contribution to fire safety. But it is not practicable to be it in any meaningful way in this building.

On ventilation the greater the pressure differential across a  door the greater the leakage across it. We know that a fire produces a slightly positive pressure in the upper parts of a room involved, and we know that in a staircase the air in the head of the stairs is likely to be warmer than that at the foot and will almost certainly be warmer than the air outside. The rooms will all be below the level of the vent.  So if we have an opening vent in the head of the stair the pressure in the stair itself will be slightly reduced  as the chimney stack effect causes the warmer air to flow out of the vent and inlet air flows in. Wheres the inlet air to come from- probably from leakage paths around the doors to the rooms. One of which may even have (above the neutral plane I accept) a slightly higher positive pressure than the others.

Theres a time for ventilation I grant you to assist access by firefighters and to clear smoke if the staircase does become contaminanted. But I still feel that to provide a vent in the stair that opens on first detection of fire is more likely to impede the safe evacuation in the early stages of the fire by increasing the pressure differential across the fire door and increasing any smoke leakage past it.

Lets remember the discussion we had on flats- the lobby is vented to maintain a negative pressure relative to the stair in order to keep the staircase clear of smoke.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Ricardo on February 18, 2008, 08:53:24 AM
Quote from: nearlythere
Quote from: timandfi
An interesting point on the last posting by Kurnal you say the sleeping accommodation document is being held up as best practice in the courts, is there any information freely available on any such cases?
Don't thnk this is the same issue Ricardo. From what I read in the Sparrow Hawk Hotel case there did not seem to be fire doors on the rooms at all. In timandfi's case the issue is about have to provide two.
Yes, just saying that the guides have been used in court to support a fire authorities case and thought it may have been useful to timandfi
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on February 18, 2008, 09:41:03 AM
Kurnal I agree entirely with you I was not arguing the need for lobbies in this case, I was saying if lobbies are not provided and you wish to meet the relevant requirements in some other way then simple saying upgrade the AFD is not sufficient you need to give a full detailed argument why, I believe it is that which will convince the BCO.

My point about the ventilation was assuming the fire door to the room of origin had smoke seals and as it would only be open a short period of time the amount of smoke entering the staircase would be minimum and the ventilation would more than able to cope with the situation.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 18, 2008, 03:27:19 PM
Hi, Sorry to pester for further advise but a development today which may well in the long term be good but has left us feeling a little abandoned. The fire consultant chap we were dealing with has spoken to the fire authority and most recently to the local fire safety officer, although he is the local station manager too (is this usual?). The fire officer has suggested a site meeting with BC and I have subsequently called him to understand how best to arrange this. I now have the impression that our fire consultant chap is perhaps backing off as the fire officer is none to keen on the velux window option for exactly the reasons some of you have mentioned (he quoted a residential home in Glasgow where someone smoked and many had died from cold smoke?) although the consultant says BC appear OK with it. Fire officer is very pro sprinkler systems but did say he will be led by BC as long as we conform to the RRO.
We want to be as prepared as possible in advance of this meeting and will take on board may of the kind suggestions you have put forward. But my biggest concern out of today is figure 50 page 98 of the sleeping accom document. I had always thought we conformed to that and that this would be good defence in meeting the RRO but our fire consultant says we do not because the diagram shows the top storey as just one room and we have multiple? I quoted text to him re 'access to a stairway from any room is through one fire door' but he says para above 'the corridors serving bedrooms in sleeping areas and stairway are protected routes, completely enclosed in 30 minute fire resisting construction and all doors onto the corridor and stairway are self closing fire doors' and we do not have protected corridors. We don't have corridors full stop but is the stairway not classed as protected bacause all doors onto it are fire doors with self closers? He says the figure for a 4 stoery building relates to us?
Would the fire officer be swayed if we offered an L1 system and / or the cold smoke seals someone mentioned? Would it be good for us to time getting out of the building via the escape route and also the time to open and close doors and if so is there a calculation to assess how much smoke could enter the escape route when a door is opened?
Thanks
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: FORRIE on February 18, 2008, 09:47:01 PM
timandfi
I feal sorry for your problem, and have read all the good advice you have been given, it appears to me that if you cannot provide two door protection to the single three storey staircase you must come up with a fire egineering solution which ADB indicates ventilation to the staircase. It seems that two door protection in an old building is difficult or near impossible to provide. The problem with  two door protection if it was fitted in such a confined space that the occupiers of the bedrooms could wedge open the inner door which would then effectively become one door protection! There is a far greater risk in an HMO that most local authorities would allow with single door
protection to a three storey building, but that doesn't help your case .
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on February 18, 2008, 10:00:53 PM
Curiouser and curiouser. Timandfi  I cant answer the new developments cos they dont make any sense to me.

A protected route is defined on page 134 of the fire safety order guidance and in different terms on page 143 of ADB. Your proposed staircase enclosure creates a protected route with a single door protection, the ADB is looking for double door protection- the question is all about how much protection is required and appropriate in this case.

The corridors and single room bit is absolute hogwash. Sounds to me like the meeting with the fire officer was the blind leading the visually impaired. None of the guidance documents are perfect, they are guides not bibles.  There are very many direct contradictions between ADB and the Fire Safety guidance- take a look at the position of inner rooms- ADB para 3.10.b, guidance page 73- direct contradiction.
Take a look at fire doors table B1 box 10- fire doors to places of special  fire risk dont need smoke seals!

And yes the fire officer will be very pro sprinkler systems, we all are but is a sprinkler system a reasonable and proportionate response to your design problem?  I think sprinklers are a great solution but your duty of care is as far as reasonably practicable in the circumstances of the case.

Lets be clear if you are going anywhere with this your fire doors must be FD30S SC - they must incorporate intumescent fire and cold smoke seals preferably - as most are- combined seals. You must provide detection to L2 and offering L1 is not much of a further enhancement in your building- probably one or two additional detectors in the roof space.

Yes there are calculations methods based on assumptions but this could be a very  time consuming, toruous and costly route to go down because they all are based on 1001 assumptions and in such a small fire compartment consequences of error and variations in fire growth and development would make a huge potential difference. Any element could be challenged at any stage- fire and fuel, fire development rate, location of fire in room,  degree of ventilation of the fire compartment, leakage round the door seals, fire door open or closed or 1/4 open as in the BRE flats   Common sense is the better route I think.

You are only going to get one more go at this so make it count. Theres plenty of information in this thread and suggestions of suitable alternative solutions. I believe  both the history and the Fire Safety order guidance are on your side. But there can be no guarantees.
Sopmething like this:

History of double door protection- then and now
Double door protection- strengths and weaknesses
Creation of artificial lobbies in existing buildings- a flawed solution- size of lobby, abuse by occupants
Limited travel distance
SWOT analysis
Taking on  the strengths - bettering the weakness
Multi sensor detection- the earliest warning of all types of fire
FD30 S doorsets and quality workmanship- additional seals?
Swing free closers - beating the wedge, guaranteeing the escape route
Opportunities for good management driving down the risk- furnishings, heating systems, electrical and gas safety, management and supervision.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on February 19, 2008, 09:12:15 AM
Thank you once again.
We are going to take a little time to thoroughly prepare our written documentation with all your kind suggestions included prior to meeting with BC and the Fire Officer.
Will keep you all informed on progress!
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on August 06, 2008, 09:45:11 AM
Good Morning All

You may recall around 6 months ago this posting on the forum and our promise to advise you of the final outcome. Well I am very very pleased to report that we now have our full plans building regs approval for change of use to a B&B. This is in the main due to the generosity and fantastic work of the guys at TFS Ltd. TFS initially contacted us via the forum as they thought we had had a good deal of conflicting advise and thought our case was worth a fight that could indeed be won. They offered their expertise free of charge and conducted a full risk assessment of our premises and based on this devised a proposal to put forward to building control. Their amazing knowledge was coupled with a common sense approach which was  sympathetic to the age and structure of the building but in no way compromised the safety of our future guests. The proposal was submitted and after 8 nail biting weeks was agreed without amendment and we can now move forward on the whole project.

Our aim had never been to 'get something for nothing' from the forum but as a start up business facing such an up hill battle with a seemingly uncompromising BCO we will be forever grateful to TFS and the forum in general. What this whole situation has made us realise is the value of professional risk assessment and we hope you can do our part promoting this to others in the future.

As a gesture of thanks to all who offered their advise we have made a donation to the fire service charity and once we are up and running any member of the forum will be very welcome to stay at our B&B in Whitby at a special discounted rate. And at least you will know if will be one of the safest B&B's around!

Once again thanks to one and all and especially TFS.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on August 07, 2008, 06:34:46 PM
Thanks for the update Fi and that is good news.
Presumably you have ended up with a protected staircase with a single fire door to each room and detection in all rooms and the staircse? Or have you had to do more?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on August 07, 2008, 07:03:21 PM
Quote from: timandfi
Good Morning All

You may recall around 6 months ago this posting on the forum and our promise to advise you of the final outcome. Well I am very very pleased to report that we now have our full plans building regs approval for change of use to a B&B. This is in the main due to the generosity and fantastic work of the guys at TFS Ltd. TFS initially contacted us via the forum as they thought we had had a good deal of conflicting advise and thought our case was worth a fight that could indeed be won. They offered their expertise free of charge and conducted a full risk assessment of our premises and based on this devised a proposal to put forward to building control. Their amazing knowledge was coupled with a common sense approach which was  sympathetic to the age and structure of the building but in no way compromised the safety of our future guests. The proposal was submitted and after 8 nail biting weeks was agreed without amendment and we can now move forward on the whole project.

Our aim had never been to 'get something for nothing' from the forum but as a start up business facing such an up hill battle with a seemingly uncompromising BCO we will be forever grateful to TFS and the forum in general. What this whole situation has made us realise is the value of professional risk assessment and we hope you can do our part promoting this to others in the future.

As a gesture of thanks to all who offered their advise we have made a donation to the fire service charity and once we are up and running any member of the forum will be very welcome to stay at our B&B in Whitby at a special discounted rate. And at least you will know if will be one of the safest B&B's around!

Once again thanks to one and all and especially TFS.
Well done. Pity they could not have seen the situation right at the start without having to resort to what you went through. Glad you hung in there. Many would have given up.
Where is Whitby anyway?
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on August 07, 2008, 07:39:29 PM
I must assume you are not a fan of DRACULAR :)
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on August 07, 2008, 08:27:48 PM
Quote from: twsutton
I must assume you are not a fan of DRACULAR :)
Eh?????????
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Tom Sutton on August 07, 2008, 10:39:15 PM
http://www.draculawhitby.co.uk/
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on August 08, 2008, 09:34:08 AM
Good Morning

Final solution was to enhance the new L2 system with voice alert (fire cryer) on the second floor and to demonstrate all benefits the renovations added eg rewiring to current standard, new plastering, new fire door seals etc and this was all shown in the FRA with the backing of some calculations on smoke ingress etc.
As an aside the local authority BC dept also changed to a centralised North Yorks Building Control body so different people handling the case too.
As I said before we know promote he benefits of professional FRA to all we come into contact with!

And yes we are in central Whitby...will let you know when we are up and running.

Thanks again to all
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on August 08, 2008, 09:37:42 AM
And theres me thought Dracula was a fictional character.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on August 08, 2008, 10:05:14 AM
No he most certainly works in the Building Control Department!
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: nearlythere on August 08, 2008, 11:17:42 AM
Quote from: timandfi
No he most certainly works in the Building Control Department!
Don't say a word about BC until you are open for business.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: timandfi on August 08, 2008, 12:02:26 PM
Very good advise, I retract my earlier comment!
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: Wiz on August 08, 2008, 12:53:16 PM
Quote from: timandfi
No he (Dracula) most certainly works in the Building Control Department!
Also don't mention Count Dracula until you have a store of garlic, silver bullets and religious artifacts. I once did so, and got it right in the neck.
Title: Change of Use to B&B, Part B regs and RRO compliance
Post by: kurnal on August 08, 2008, 06:29:12 PM
Wiz
You should have put a steak through its heart. I understand that can work but its quite rare.