FireNet Community
FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: hammer1 on June 24, 2009, 12:38:26 PM
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Am I the only one who regards the above as something that seems to be placed under the carpet.
At a recent IFSM fire conference in Leeds the subject was only touched on.
Regulation 16B and also Appendix G in the ADB requires prior to the building or major alteration to be signed off, there MUST be a fire manual in place with all information in regards to passive/active fire protection, evacuation design, fire plans etc etc.
Also BS9999 has more info about the fire safety manual and the requirement for it to be set up at the design stage etc etc.
For your complex buildings fire engineering/fire strategies will be in place.
All of the above provides the RP with the information to start and manage fire safety (use the evacuation design, take into account passive fire protection prior to alterations in the future etc etc) to a god standard. It also provides detail information for future FRA's.
Now here comes the major issue......
In most cases this is not being done, not even to a small scale, and even though building control should not sign off buildings until relevant info is in place, this is not being done. This is largely due to designers, building control not having a scooby about any of it. Also the client is unaware.
Why don't we have something along the principles of CDM Regs, where as with the H&S file, a Fire file is produced with both docs handed over to RP at end of project. As with notifiable and non-notifiable, where the fire design is complex and engineering solutions are used, all official parties are notified and work together instead of the old skool building control and Co to scared to accept new solutions and work together improving all parties knowledge and setting new boundaries for future projects.
I am involved in the construction side as well as fire and find it shocking that this is not a major gripe with you guys. This is the foundation of good fire safety management for a buildings life span is it not?????????????
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Cor blimey yes yes and yes. But its why I chose my avatar- pigs might fly.
With my cynical head on in my experience its all a load of fairy tales and fine aspirations. It all sounds great in theory but just not happening in the real world at the sharp end. New buildings completed and occupied long before there is any sign of detailed design drawings, O&M manuals, fire strategy etc. Did a new factory last week- just being occupied, some hairy scary stuff in there and some sophisticated kit to protect it and not a inkling of when any of the documentation will be provided. Nothing at all - but its up and running ( Though half the systems aren't interfaced to each other) And I get the feeling the Building Inspector (approved) never left his desk.
What do I do? tell the client he cant have his risk assessment till he gives me the documentation? Nope. get on with it as best you can.
The trouble is that most of these people who write dream up these schemes standards and legislation are so remote from the sharp end and the procedures so removed from custom and practice that nobody takes a blind bit of notice.
rant over.
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hammer1
Reg 16B is the CDM Regs. Its already in place ;D.
Yes, I have yet to see one also
davo
But alas, it has not the enforcing/regulatory back up as the CDM Regs have. It has no where near the same scale of information/guidance available as CDM Regs. Major problem is no one even knows about it, including the susposed enforcers ;)
Fire Safety Order is for the fire safety management.
Lets have a Fire Safety order for the Design stage (include the construction stage, which again is not clear to most, even though it is a high risk environment). We have this have other industries, surely fire safety should as well.
It is not exactly rocket science, if you don't produce a H&S file at end of construction stage there will be a lot of people on your case, same principles for fire safety manuals.
Granted with O&M manuals and stuff, can take time to be included in the H&S files and sometimes the building is passed anyway due to pressures etc. BUT at least there is something in place, there is some procedure to collate all information and somewhere to go in the future during the buildings life span.
If we cannot even get the foundations correct then surely you/me have no argument on the management side of things.
Kurnal, should you not have been advising/educating your client from day one about collating such information. Detailed design plans should be submitted at the early stages of any construction. Fair comment about the O&M manuals, but we get this every day in the CDM Regs/construction side of things, but least there is something in place that can only benefit the management for fire safety of the building. CDM Co-Ordinators have the role of communicating between designers, clients and contractors and is responsible for collating such information. If you have a client, should you or someone like you be delegated a similar role????
If it works for CDM, why not fire safety??????????
What we need are clear available legislation on this area to give the client clear instructions and to incorporate Regulation 16B, ADB, BS9999 information into one simple to follow ACOPS.
Job done ;)
Surely you guys agree something must be done, especially when we get good engineering solutions buffed by prescriptive old skool building control bodies that have a lack of knowledge and understanding.
I thought the long term aim was to move way from prescriptive ideals???? If we cannot do it from the design stage, then all your arguments about the fire safety order and interpretation will never go away.
What is the point of conducting a FRA 1-2 years after a building life span to advise this and that is wrong, creating extra costs to issues that could of been dealt with at the beginning. You would not build a house and then 2 years later decide a kitchen is required????
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Agreed completely. It has been mentioned before and IMO while we (The FRS) are consulting on a project at planning stage, our comments could or should make reference to this document.
If it is consistently ignored, like it seems to be, it will never be rectified.
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Hammer 1 where clients come to us at design stage we can and do advise them correctly. But most architects and BCOs have never heard of or cant be bothered to think about Regulation 16B (Many architects still specify BS5839 1988)Most of or clients only come to us on handover and occupation.Thats when we tell them with sadness how much money they have wasted and how much more still needs to be done.
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Dear Mr Pen Pusher,
There's no time for any faffing around with manuals and certificates.
I build real things that exist. Not just shuffle bits of paper.
Most importantly, I've got to get the building handed over to my customer and get paid!
Anyway, the building user will have mislaid any manuals and certificates within 3 months and swear blind that they've never seen them! What is the use of all that effort put in to provide them?
Yours in Site Office
Mr Betty Swollocks
(Main Contractor)
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I think this is the exact problem Hammer1 is referring to. We have all resigned ourselves to the fact that it probably won't happen, so why even bother?
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Dear Mr Pen Pusher,
There's no time for any faffing around with manuals and certificates.
I build real things that exist. Not just shuffle bits of paper.
Most importantly, I've got to get the building handed over to my customer and get paid!
Anyway, the building user will have mislaid any manuals and certificates within 3 months and swear blind that they've never seen them! What is the use of all that effort put in to provide them?
Yours in Site Office
Mr Betty Swollocks
(Main Contractor)
If you had this excuse under CDM Regs you would not be working for very long ;)
If you have a A/C system that cost £100,000, you dam sure will want the manual, certificate and even a gold star in case the thing is faulty/goes wrong. Secondly you want certificates to ensure the work is done to a standard that is required, building regulations are there for a reason and mainly for the safety of occupiers of the new owners. The insurance company will no doubt tell you where to go if all you have is joe bloggs builder saying 'trust me, its all ok, I build things'.
That attitude has certainly changed in the construction industry for medium-large scale projects. Common sense prevails, you may only need a few pages for simple premises or more for complex ones.
It is not about just certificates, manuals it is about good information to help the RP provide appropriate fire safety management of the building...........as I have said, not rocket science.
Oh, we in the construction industry use electronic paperwork, scanners for some of our H&S files, works a treat, try it sometime ;)
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Hammer1
Lets face it, its not just fire that can be missed by the BI who is overworked etc etc.
Also many H & S files are crap, saw one with a pile of data etc for a certain brand of fire door in it, pity we didn't have any of those doors in the build! Careless, sloppy etc or what!
I heard of one contractor where the client was holding back £60K as he hadn't got the manuals.
Contractor decided it would cost more to provide them so stuck two fingers up!
davo
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Dear Mr Pen Pusher,
There's no time for any faffing around with manuals and certificates.
I build real things that exist. Not just shuffle bits of paper.
Most importantly, I've got to get the building handed over to my customer and get paid!
Anyway, the building user will have mislaid any manuals and certificates within 3 months and swear blind that they've never seen them! What is the use of all that effort put in to provide them?
Yours in Site Office
Mr Betty Swollocks
(Main Contractor)
If you had this excuse under CDM Regs you would not be working for very long ;)
If you have a A/C system that cost £100,000, you dam sure will want the manual, certificate and even a gold star in case the thing is faulty/goes wrong. Secondly you want certificates to ensure the work is done to a standard that is required, building regulations are there for a reason and mainly for the safety of occupiers of the new owners. The insurance company will no doubt tell you where to go if all you have is joe bloggs builder saying 'trust me, its all ok, I build things'.
That attitude has certainly changed in the construction industry for medium-large scale projects. Common sense prevails, you may only need a few pages for simple premises or more for complex ones.
It is not about just certificates, manuals it is about good information to help the RP provide appropriate fire safety management of the building...........as I have said, not rocket science.
Oh, we in the construction industry use electronic paperwork, scanners for some of our H&S files, works a treat, try it sometime ;)
Listen 'ere Hammer1, I use your head on my sites to bang me nails in. So I know wot you are all about. :)
I understand and realise the purpose of manuals and certificates. I'm sure any right-minded builder would. They're a great idea. But until there is a bit of reasonable breathing space between 'finishing' the job (and getting paid) and the time before the building is actually used by the client and with all manuals and certificates in place, then there is always gonna be this problem.
The only way I can see around it, is for me to get the certificates written up before I start the job. Is that a good solution?
And because the manuals I'm required to provide (in triplicate), must include instructions on how the building user will do everything (including wiping his backside) I throw any old tosh in them towards the end of the job to make 'em look full up. I'd rather spend a month at the end of the job putting them together nicely using relevant information, but I'm not given the time.
It's all rush to Finish job, handover to client, get me dosh.
It's alright for the office wallahs to have all these great ideas but in practice it all takes time for all me trades to get all the info together. (This doesn't include the 100K AC unit for which there is any amount of info available, but the sparky can never find the user instructions, EN standards approval document, planned maintenance schedule, hazardous waste disposal instructions and commissioning certificate for the 75p pull switch he installed in the disabled WC!)
Gotta go, I can feel the morning's bacon buttie working its way through.
Yours in Portaloo
Mr Betty Swallocks
(Main Contractor)
:)
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Cor blimey yes yes and yes. But its why I chose my avatar- pigs might fly.
With my cynical head on in my experience its all a load of fairy tales and fine aspirations. It all sounds great in theory but just not happening in the real world at the sharp end. New buildings completed and occupied long before there is any sign of detailed design drawings, O&M manuals, fire strategy etc. Did a new factory last week- just being occupied, some hairy scary stuff in there and some sophisticated kit to protect it and not a inkling of when any of the documentation will be provided. Nothing at all - but its up and running ( Though half the systems aren't interfaced to each other) And I get the feeling the Building Inspector (approved) never left his desk.
What do I do? tell the client he cant have his risk assessment till he gives me the documentation? Nope. get on with it as best you can.
The trouble is that most of these people who write dream up these schemes standards and legislation are so remote from the sharp end and the procedures so removed from custom and practice that nobody takes a blind bit of notice.
rant over.
Have just finished a CDM fire install and it was new to me.It was also new to a lot of other guys that I know working for other majors that have projects that run over the notification hours etc.
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Hammer1
I heard of one contractor where the client was holding back £60K as he hadn't got the manuals.
Contractor decided it would cost more to provide them so stuck two fingers up!
davo
Dear davo,
I think that was one of my jobs! I calculated it would take a dozen people two months to get all the paperwork together but they wanted it all 'by the end of the week' otherwise they said they would keep the retention of 60K. I told 'em to keep it.
Their building still looks nice though, two years on.
Yours now in pub.
Mr Betty Swallocks
(main contractor)
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Dear Mr Pen Pusher,
There's no time for any faffing around with manuals and certificates.
I build real things that exist. Not just shuffle bits of paper.
Most importantly, I've got to get the building handed over to my customer and get paid!
Anyway, the building user will have mislaid any manuals and certificates within 3 months and swear blind that they've never seen them! What is the use of all that effort put in to provide them?
Yours in Site Office
Mr Betty Swollocks
(Main Contractor)
If you had this excuse under CDM Regs you would not be working for very long ;)
If you have a A/C system that cost £100,000, you dam sure will want the manual, certificate and even a gold star in case the thing is faulty/goes wrong. Secondly you want certificates to ensure the work is done to a standard that is required, building regulations are there for a reason and mainly for the safety of occupiers of the new owners. The insurance company will no doubt tell you where to go if all you have is joe bloggs builder saying 'trust me, its all ok, I build things'.
That attitude has certainly changed in the construction industry for medium-large scale projects. Common sense prevails, you may only need a few pages for simple premises or more for complex ones.
It is not about just certificates, manuals it is about good information to help the RP provide appropriate fire safety management of the building...........as I have said, not rocket science.
Oh, we in the construction industry use electronic paperwork, scanners for some of our H&S files, works a treat, try it sometime ;)
Listen 'ere Hammer1, I use your head on my sites to bang me nails in. So I know wot you are all about. :)
I understand and realise the purpose of manuals and certificates. I'm sure any right-minded builder would. They're a great idea. But until there is a bit of reasonable breathing space between 'finishing' the job (and getting paid) and the time before the building is actually used by the client and with all manuals and certificates in place, then there is always gonna be this problem.
The only way I can see around it, is for me to get the certificates written up before I start the job. Is that a good solution?
And because the manuals I'm required to provide (in triplicate), must include instructions on how the building user will do everything (including wiping his backside) I throw any old tosh in them towards the end of the job to make 'em look full up. I'd rather spend a month at the end of the job putting them together nicely using relevant information, but I'm not given the time.
It's all rush to Finish job, handover to client, get me dosh.
It's alright for the office wallahs to have all these great ideas but in practice it all takes time for all me trades to get all the info together. (This doesn't include the 100K AC unit for which there is any amount of info available, but the sparky can never find the user instructions, EN standards approval document, planned maintenance schedule, hazardous waste disposal instructions and commissioning certificate for the 75p pull switch he installed in the disabled WC!)
Gotta go, I can feel the morning's bacon buttie working its way through.
Yours in Portaloo
Mr Betty Swallocks
(Main Contractor)
:)
;D
Not sure what jobs you are involved with Mr (seems like smoky bandits general builders). O&M manuals can take time, but that is only part of the H&S file. Anyone requesting such info a week after construction completion is living in cuckoo land. On notifiable jobs under CDM you have the CDM Co-Ordinator to dump all relevant info on and it is them who needs to produce H&S file. I have people that can work on £1-10 million projects and can single handed produce such files, be it some info taking a lot longer than project completion (but it still gets there). Third party accreditation is a wonderful thing don't you think if used correctly and wisely.
Either your pen pushers have not a clue or the arrangements with your clients need to be changed. No need to complicate things that can be simple.
Totally gone off topic here and think this should be in a construction forum ;)
Fire safety is far more simpler than what me and Wiz have been waffling on about. The onus is on the design,client rather than the construction/cowboy outfit to fulfil............
I'm off back to the Ranch with no nails, hilti and filler....
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Betty (I can call you that I hope?)
First of all, welcome to Firenet
I don't think it was one of yours, unless you work oop Norf ;D
The problem is how Reg 16B appeared, snook in on an innocuous SI
davo
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davo, I can be found on most building projects around this country. Fearlessly fighting the insidious creepage of rules and regulations for no good reason, but embracing those that have merit whilst fighting the seeming impossibility of embracing them against the expectations of short contract times and low cost expected by my bosses and their clients.
I am part of a team. My colleagues are Mr R.S. Crack (Site foreman) and Mrs Mel E. Armpit (admin). Our arch enemy is Mr Job Sworth who represents the 'people who ain't gotta clue' and paid by yours and my tax contributions.
Yours, in cafe.
Mr Betty Swollocks
(Main Contractor)
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Also to add to this is, and something some of you might be more familiar with is Article 45 of the fire safety order and that the local authority duty to go pass and consult the enforcing authority any fire plans of new builds, major alterations prior to accepting such plans.
So that's where the problem lies.
On that note I will leave the subject for all to ponder on.
Have a nice weekend. ;)
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Art 45 transposes a requirement that started life in the 1971 Fire Precautions Acts - not exactly news.
Davo says "The problem is how Reg 16B appeared, snook in on an innocuous SI". It was hardly sneeaked under the wire. It was part of the Review of the Building Regs. If you missed that then you must have been on the moon.
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As Wee Brian points out, the duty to consult has been around since Mr Holroyd stuck his oar in.
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Ah yes indeed so.
The reason for highlighting Art 45 is;
So is it the enforcing authorities missing the boat, hence the problem lies there. Local authorities are consulting the enforcers who seem to forget Reg16B and other guides, hence the lack of it and lack of interpretation from Building control.
Did someone say 'competent'?? not me squire..............
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Gents
'The Buildings and Approved Inspectors (Amendment) (Number 2) Regulations 2006' hardly gives a clue as to the importance of the contents IMHO
davo
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But the supporting guidance does specifically mention it on the very first page.
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Civvy
Yes, six half-lines which in the on-line version has 'on-line version' right across it.
Also there is no mention in that intro of Appendix G, nor the comprehensiveness of the requirement.
You have to read all the contents list or the whole document to know of G's existence
davo
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Perhaps future SIs should have titles including such prases as "DAVO should read this".
Fancy having to read the contents page to see what in a document.... outrageous
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I think a lot of the problems with Reg 16B is that fire brigades dont have the time ask questiions and insist on seeing a copy when they are consulted by the BCO. They dont even have time to take a good look at most of the plans in my opinion (compared to the old days of course). It was always a bit of a rubber stamping job without adequate time allocated under the old OMPIS and its much worse now with the depletion of dedicated teams.
Because brigades dont make a fuss neither does the BCO and especially the approved inspectors. After all the statutory bars gone so does it matter if its missed- if the risk assessment isnt right on audit then enforcement action can be taken. So they get a consultation they dont really want to have to carry out and dont see a huge benefit in it because its someone else's legislation. They have no legal duty to respond to the consultation and it makes no difference to their own enforcement duties if they dont.
Same with the Fire Safety Order and the CDM regs. What a cock up. CDM and Fire Safety Order partly duplicate each other but CDM has a totally different emphasis on who is being protected. It only considers persons on the site. The persons responsible for the CDM Regs compliance is defined- and it isnt the same people as the Responsible Person under the Fire Safety order. Unless the site has other occupiers the fire related provisions of the CDM are enforced by the HSE and they dont want to know and aren't used to the Fire Safety Order. On multi Occ sites the Fire Authority enforce and quite rightly they would much rather enforce the FSO , dont want to know anything about the fire provisions in the CDM Regs.
Outcome is that most of the time nobody thinks or cares about Reg 16b. At plan stage the fire authority arent interested because the FSO applies to places not plans.
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All fair comments.
But if BS 9999 is the new bible, how come consultants are not taking up the baton about producing the fire safety manual at design stage then??.
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Because often we are brought in when it's too late - a site gets a new build or a virtual re-build and they complete the works, then suddenly remember "we need an FRA too".
We turn up & ask for the fire safety manual to blank looks. The contractors are long gone and we then have to pour through the entire O&M, M&E and H&S Files to try and locate the seemingly randomly placed snippets (& often a snippet is all the depth of info you get) of fire related info.
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And very often just a photocopy of the entire sales catalogues of the equipment suppliers, sometimes not even identifying which equipment is actually fitted. And a Cause and effect matrix? "You are joking. Thats commercial confidential that is." Wheres the backup for the config? "We keep that in our service kit"
A lot of the problems are exacerbated with design and build projects in which the end user has no commercial relationship with the various contractors. Thats when the problems as expressed by Davo tend to arise.
Further example is a design and build project for a new sprinklered care home in which the sprinkler system installed by an LPCB approved company does not meet BS9251 - roofspaces and stores not covered due to provision of L1 fire alarm system!!!! Goodness knows where that idea came from. Then I look at the BS5839 commissioning certificate " L1 but roof spaces and stores not covered due to provision of sprinkler system". Principal contractor not interested, approved inspector wont visit site or give an opinion, has issued completion certificate, fire service ho hum dont know what we can do its not our proble. Poor old client has to dig further into his pockets to fix it and then even further if he is to receive any redress inthe civil courts. But what can he claim? He can only claim the damages- not the cost of putting it right.
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But if BS 9999 is the new bible, how come consultants are not taking up the baton about producing the fire safety manual at design stage then??.
At least one AI now uses Regulation 16B as a marketing tool to generate work for its fire safety engineering subsidiary (plan checkers are encouraged to ask for fire safety information in their plan check letter on appropraitely sized schemes). I am sure that as more and more design teams are made aware of their obligations by helpful consultants or AIs with in house fire engineers to support we will see an increase in activity.
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dear all
Bit confused about some comments re what appear to be engineeered soultions in new builds by approved inspectors
I am reading the building act right when in 8(1) & (2) it says that the only people who can go outside the ADB is the local authority.
confused in a big world ??? ???
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No.
It means that the local authority can relax or remove the requirements (B1 to B5 in our case) of the regulations if they feel it is appropriate. It is not in reference to people using or varying from ADB.
AI's and LA's can vary from ADB as much as they want, but the functional part of the regulations must always be met. i.e. You have to supply a good means of escape. However, if for any reason it would be completely unreasonable, or uneccessary then they can relax or remove the actual requirement.
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CivvyFSO
Thanks for that
???
Not so confused still in a big world
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CivvyFSO
just a quick question re the AI and ADB can you let me know where this interpretion has come from as massive debate now going on and its difficult to hear the cricket scores
many thanks
confused in a big world ???
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Try this link: http://www.communities.gov.uk/documents/housing/pdf/465607.pdf
That gives information regarding appeals and determinations. There is not much to debate about it. :)
Just to clarify the point about ADB: ADB is issued only as 'guidance' to assist persons to comply with the building regs. Any variation from ADB (even a full engineering solution) can be assessed by a BCO or an AI as to whether, in their professional opinion, it still meets the requirements of the regulations. It is any disagreement at this point that could give rise to a determination, which will have to go to the Secretary of State.
An appeal is very different and you should read the link posted above for information regarding this.
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To CivvyFSO
once again many thanks
knowing someone who knows where to look
Priceless
confused in a big world :)