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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: William 29 on October 20, 2017, 01:58:42 PM

Title: Application of the RRFSO to internal flats
Post by: William 29 on October 20, 2017, 01:58:42 PM
Following recent events, we are increasingly being asked questions around the application of the fire safety order to any common facilities i.e. common vents in kitchen and bathrooms between purpose-built flats and risers etc internal to the flats, that could only be viewed by an invasive survey.

As I am sure most are aware a "Type 1" FRA is enough to satisfy the RRFSO but we recommend at least a "Type 3", where we will access a sample of the flats. I am looking for opinions as to if the RRFSO could be applied to such "common" areas as they are common to one or more flats? To my knowledge, this has not been challenged.
Title: Re: Application of the RRFSO to internal flats
Post by: nearlythere on October 20, 2017, 08:35:29 PM
Following recent events, we are increasingly being asked questions around the application of the fire safety order to any common facilities i.e. common vents in kitchen and bathrooms between purpose-built flats and risers etc internal to the flats, that could only be viewed by an invasive survey.

As I am sure most are aware a "Type 1" FRA is enough to satisfy the RRFSO but we recommend at least a "Type 3", where we will access a sample of the flats. I am looking for opinions as to if the RRFSO could be applied to such "common" areas as they are common to one or more flats? To my knowledge, this has not been challenged.
Due to the rose tinted governmental glasses this shouldn't have been an issue with FRAs dealing with the management of fire safety only, as I read when this was launched. Sure all buildings are built to Building Regs anyway hahahaha.
I have surveyed a few modern blocks of flats since Grenfell and I am astonished that the quality of build and control of construction is so poor. So poor to the extent that "Stay Put" should be removed from the Fire Safety lexicon as being a pie in the sky strategy.
Title: Re: Application of the RRFSO to internal flats
Post by: William 29 on October 20, 2017, 09:11:57 PM
Sorry, I don't agree. The majority that we are seeing have some compartmentation issues but nothing that can't be fixed or that warrants stay put being thrown out of the window. The alternative is full evac and this throws up all sorts of different problems that I don't want to go into here. I was just interested in the interpretation of the application of the RRFSO as posted.  :)
Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 21, 2017, 10:56:26 AM
The current benchmark guidance for purpose built blocks of flats covers this area in detail regarding kitchen/bathroom ducts.
The application of the fire safety order is for the common parts only, therefore the internal vents grills ducts within the flats and between the flats is housing act.

If you carried out a Type 3 survey, any internal recommendations for the flats would have to be made under the housing act and this would/should be clearly defined in the risk assessment as the RA is for the FSO.

Hope that is of help. Keep it simple you know it makes since.............sometimes.
Title: Re: Application of the RRFSO to internal flats
Post by: William 29 on October 21, 2017, 01:05:12 PM
The current benchmark guidance for purpose built blocks of flats covers this area in detail regarding kitchen/bathroom ducts.
The application of the fire safety order is for the common parts only, therefore the internal vents grills ducts within the flats and between the flats is housing act.

If you carried out a Type 3 survey, any internal recommendations for the flats would have to be made under the housing act and this would/should be clearly defined in the risk assessment as the RA is for the FSO.

Hope that is of help. Keep it simple you know it makes since.............sometimes.


I think I am in agreement. However, we are increasingly seeing this on Fire Authority "Notices of Deficiencies" under the RRO. And I am told that this could be enforced but is unlikely to be pursued, so why included in the Notice? It would be better to have a section "Areas not enforceable under the RRO" and detail these deficiencies under a Housing Act section?
Title: Re: Application of the RRFSO to internal flats
Post by: Owain on October 21, 2017, 01:37:02 PM
The current benchmark guidance for purpose built blocks of flats covers this area in detail regarding kitchen/bathroom ducts.
The application of the fire safety order is for the common parts only, therefore the internal vents grills ducts within the flats and between the flats is housing act.

In my building the shared bathroom extractor ducts run in the service risers off the common stair.
Title: Re: Application of the RRFSO to internal flats
Post by: Messy on October 21, 2017, 03:27:15 PM
I note the reference to type 1, 2 3 etc FRAs in this thread and a simple Google search has show the definition of each. I also note that these types have originated from our own Sir Colin of Toddshire in his residential guidance book (which I understand is a good read, but lacks sufficient photos for me to by one!)*

I also note that a number of FRA providers are offering types 1 to 4 FRAs for all FRAs, regardless of type of premises. Is this the future? If so, what are the benefits?

(*I haven't been involved in residential FRAs for 7 years, so am a bit rusty on this guidance)

Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 21, 2017, 03:48:35 PM
Owain the doors to the risers on to the common parts FSO the duct work going in to the flats is housing act.

With regards to what you write in the requirements in your RAs should be FSO however if you see anything under the housing act you must make it very clear and state advice given under housing act.

As to enforcement officer putting ducts in to enforcement notices if they are enforcing it under the FSO this not correct. There is a memorandum of understanding between the enforcers of the housing act and fire authorities stating the lead authority for housing issues would be the local authority not the fire authority.


Title: Re: Application of the RRFSO to internal flats
Post by: Tom Sutton on October 21, 2017, 09:05:29 PM
"domestic premises" means premises occupied as a private dwelling (including any garden, yard, garage, outhouse, or other appurtenance of such premises which is not used in common by the occupants of more than one such dwelling)

If the ventilation shaft can be defined as, other appurtenance of a premises, and is used in common, it cannot be describe as domestic premises and subject to the RR(FS)O.
Title: Re: Application of the RRFSO to internal flats
Post by: colin todd on October 21, 2017, 11:10:14 PM
Ah Appurtenance, there is a word you didn't hear much on blue watch at Salford, Tam.
Title: Re: Application of the RRFSO to internal flats
Post by: Tom Sutton on October 22, 2017, 09:20:55 AM
I wouldn't know the nearest I got to Salford was Newton le Willows.
Title: Re: Application of the RRFSO to internal flats
Post by: William 29 on October 22, 2017, 02:52:55 PM
Ah Appurtenance, there is a word you didn't hear much on blue watch at Salford, Tam.

I only served on Green and Red watches at Salford so must of missed that? However, are you able to offer any clarity on the issue Mr T?
Title: Re: Application of the RRFSO to internal flats
Post by: Dinnertime Dave on October 22, 2017, 04:28:32 PM
"domestic premises" means premises occupied as a private dwelling (including any garden, yard, garage, outhouse, or other appurtenance of such premises which is not used in common by the occupants of more than one such dwelling)

If the ventilation shaft can be defined as, other appurtenance of a premises, and is used in common, it cannot be describe as domestic premises and subject to the RR(FS)O.


I'm with you Tom, if as the assessor you know of any such duct then comment on the assessment. I've recently found a gas pipe that isn't protected in one of our blocks and and enclosed it. Caused problems gaining access to 3 flats but I sleep at night.
Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 22, 2017, 07:14:17 PM
Dave exactly the point I was making but the gas pipe work would be enforced under the housing act as the RA is under the FSO
Title: Re: Application of the RRFSO to internal flats
Post by: Tom Sutton on October 23, 2017, 08:04:39 AM
Dave exactly the point I was making but the gas pipe work would be enforced under the housing act as the RA is under the FSO

That's my point, the bathroom extractor ducts that run in the service risers would be a appurtenance of such a flat and used in common by the occupants of more than one such dwelling, therefore would be subject to the RR(FS)O.
Title: Re: Application of the RRFSO to internal flats
Post by: Dinnertime Dave on October 23, 2017, 05:42:21 PM
Dave exactly the point I was making but the gas pipe work would be enforced under the housing act as the RA is under the FSO

That's my point, the bathroom extractor ducts that run in the service risers would be a appurtenance of such a flat and used in common by the occupants of more than one such dwelling, therefore would be subject to the RR(FS)O.

Yes, I'm still with you Tom. It's communal and therefore subject to FSO. I might have google appurtenance though.
Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 23, 2017, 07:25:26 PM
Ok lets run with the ductwork for the moment; the fix maybe to fit dampers/intumescent grill on the inlets/outlets in the bathroom or kitchen within the flat/s.............FSO or housing act?
Title: Re: Application of the RRFSO to internal flats
Post by: Tom Sutton on October 23, 2017, 07:47:27 PM
I would fit the the dampers where the vent enters the duct and I would like to check it, even if its in the flat, like the front door. IMO the duct falls within the FSO.
Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 23, 2017, 08:08:48 PM
Tom, so you are saying it is in a private single dwelling you would fit the dampers and that comes under the FSO?
Title: Re: Application of the RRFSO to internal flats
Post by: Tom Sutton on October 24, 2017, 07:55:51 AM
The dampers are being fitted in the common parts, the vent shaft, but the access may be in the flat.
Title: Re: Application of the RRFSO to internal flats
Post by: William 29 on October 24, 2017, 11:16:00 AM
But the fire officer would have no right of entry into the flat to:

a) know if there was a common vent and if dampers where fitted, without invasive works?
b) have the right of entry to inspect said works after completed to check if the RP has complied with the Notice served under the RRFSO


And hence my question, I don't think these areas can be included on a Notice issued under the RRFSO?
Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 24, 2017, 07:25:08 PM
Tom, lets play this one out then; you want to access my lease hold flat to access the ducts to fit dampers correct? well as the lease holder of the flat I do not permit you access, ok so far? who is going to enforce the access if it is deemed necessary?
Title: Re: Application of the RRFSO to internal flats
Post by: nearlythere on October 25, 2017, 08:51:00 AM
Tom, lets play this one out then; you want to access my lease hold flat to access the ducts to fit dampers correct? well as the lease holder of the flat I do not permit you access, ok so far? who is going to enforce the access if it is deemed necessary?
But that would have been ensured by BC anyway.
Title: Re: Application of the RRFSO to internal flats
Post by: Animal on October 25, 2017, 09:22:10 AM
Nearly, thank you for the reply. BC have no jurisdiction/powers of entry into my existing private single dwelling, in this case to play it out; a man be it a builder wanting to fit dampers, Tom wanting to have a look at where he would like them fitted knocks on my door and I tell him to go away you are not coming in! (of course very politely) Who now enforces entry to fit the said dampers and under what legislation?
Title: Re: Application of the RRFSO to internal flats
Post by: Mr. P on October 25, 2017, 09:23:30 AM
An, think you will find a para or 2 in your 'legal' lease/rent etc. agreement which allows landlord authorised persons, with reasonable notice period, to access your property for maintenance, repair and new works etc. If you deny access and someone dies which could have been avoided if only you had allowed access, you may find yourself answering to the Coroner (albeit in a round about way)...javascript:void(0);
Title: Re: Application of the RRFSO to internal flats
Post by: nearlythere on October 25, 2017, 12:16:50 PM
Nearly, thank you for the reply. BC have no jurisdiction/powers of entry into my existing private single dwelling, in this case to play it out; a man be it a builder wanting to fit dampers, Tom wanting to have a look at where he would like them fitted knocks on my door and I tell him to go away you are not coming in! (of course very politely) Who now enforces entry to fit the said dampers and under what legislation?
Point I'm making Animal is where was it when it was being built.

I'm involved in the fire safety upgrading of a block of flats around 10 years old. Upgrading? After 10 years?

The fire stopping that was passed as compliant with BR is extremely poor or non existent. Exposed structural steel support is untreated. It goes on.
Title: Re: Application of the RRFSO to internal flats
Post by: Tom Sutton on October 25, 2017, 02:43:27 PM
Animal check out, although a last resort, http://www.publiclawtoday.co.uk/housing/housing-law/435-housing-law-features-news/21788-borough-obtains-injunction-to-assess-property-for-potential-fire-hazards  and as far as I remember it was done under the RR(FS)O.

It's unlikely we are going to agree and maybe starting to boring people, so let agree to disagree.