Fire Risk assessment Vs Building Regulations.

[Brian Catton]

I have a situation in an old part of a Hospital. There are three offices at second floor level served by an external and internal staircase. The internal staircase discharges into a corridor where there are offices that have to be passed to reach the main staircase. Two of these offices have windows that are under or directly to the side of the external escape and they do not have FR doors. AFD is installed in every risk room and the corridors. The windows to the offices have been sealed wiyth FR glazing in frames fixed shut and ventilation provided by a motorised extraction unit in each office. The problem is that the offices get very warm and are practically inhabitable during the summer and the fans are so noisy they have to be turned off. I am tempted to do a FRA that would result in findings that say the risk that an undetected fire would occur in these offices of such magnitude that it would prevent persons using the external staircase is very low indeed. Based on this we would reopen the windows. I know however this would be contrary to the Building Regs and HTM 81. My point is what is the point of doing a Fire Risk Assessment when you know that the outcome would be contrary to Design Codes. The estates manager is considering windows that would close on actuation of the AFD but this would cost £5000 and is it really necessary? We could also put FRSC doors with auto releases on the two offices, again very costly. I would be grateful for your views.

[Paul]

Brian,

I assume the issue here is the occupants of the offices complain of hot working conditions in the summer months.  If this is the case, would it not be better to look at improving  the current ventilation / air con, rather than reducing the current fire precautions to achieve more comfortable working conditions.

I know prescriptive standards can be restrictive but I would be a little concerned to see you put your name to FRA that reduces the level of compartmentaion to achieve a cooler office.  Yes in terms of the welfare regs you have to provide a balanced working environment, but I’m not sure that a FRA is the medium to achieve this.

Sorry if I’ve interpreted this the wrong way, but it is late.

Paul

[Reg]

Brian,

I agree totally with Ps.  The hospital needs to look at the root cause of the problem rather than compromise the integrity of the protection.  You know what they say about compromise - everyone gets what nobody wants!!!  IMHO The ventilation / aircon needs to be sorted.

[PhilB]

To raise an old argument, I do not believe you can use your risk assessment to determine that the risk of a fire occurring is so low that standards that have been set for life safety can be reduced.
   
The fire may occur only once in 400 years but it could occur tomorrow. What you can do is determine that if a fire does occur the speed and development, coupled with the time to detection and time for evacuation results in a safe building.

I don't think we have enough information here to answer the question you pose Brian. I am not suggesting the opening of the windows is ok, but I am sure I am not the only person who has seen unnecessary fire protection provided on the recommendations of over zealous inspectors or BCOs.

It may be perfectly acceptable to open the windows if no-one has to pass the window i.e. are there alternatives that could be used. Are we talking about patient access areas together with office use or are no patient access areas involved here?

Come on chaps we must move away from the idea that if a code or guide recommends something it has to be there regardless of the risk.

I repeat I am not talking about risk of fire occurring. I am talking about the risk posed by the consequence of a fire.

[Paul]

Completely agree Phil.

I think all of us are very well aware of BCO's being over zealous in trying to enforce prescriptive standards.  I don’ think any of us actually believe you must always stick to the letter of the design codes etc.

I think the issue here is the fact that Brian has told us that there are two escape stairs, one internal and one external.  Occupants working in the offices must traverse the offices internally or pass over windows for the same offices via an external escape.

You would assume occupants working on a floor where the only method of escape is vertically are able bodied and can escape unaided ( yes wrong to assume but this is the information we have).  Brian already states that AFd is provided in all risk areas, does this mean all offices?  What type of AFd is provided?  

As you suggest Phil, you would assume that occupants would be able to escape given the active fire precautions provided, and the ability of the occupants to escape.  My thread above was more concerned with using a FRA as the medium to reduce the level of fire precautions to achieve a more comfortable working environment.  Challenge the building regs and design codes with adequate justifications yes, FRA to this no.

Paul

[jokar]

Working on the basis that a Fire Risk Assessment is actually the journey to an outcome and that the assessment will look at hazards and then the likelihood/severity of an incident occurring, there is no problem at all with undertaking the FRA.  Regardless of the guidance in HTM or B1 or any similar document, we are talking about risk, the reduction and prevention of it.  Without knowing the whole circumstances, it is, as has already been discussed, difficult to work out exactly what is required to do the 2 things above.  A fire in the circumstances stated with not develop unnoticed by staff or AFD, therefore, in its incipient stages it could be tackled by trained staff.  It is unlikely, unless an arsonist chose to do this, that 2 or more fires will commence at the same time in the same place and thereby take out both escape routes.  It seems an anomaly then that an external escape staircase should require protection if the other staircase has sufficient capacity to allow all persons present to escape.  Of course if both staircase are required then this is a different ball game.  

Brian, do the FRA and find the outcome on a logical basis, at least that way expenditure on air con etc, can be justified wothout impinging on peoples safety.  To work the other way around just invites a problem to occur.  You never know you may find justification.

[Brian Catton]

You are all absolutely right more info is required. Phil I have considered the consequences but could not put a score of more than two to the assessment based on the 5 x 5 matrix.
If we look nat the hazards and control measures we have.
Electricity - Circuits tested according to a PPM
Electrical appliances - tested in accordance with a PAT programme.
Arson. - The offices are within an area secured by coded locks. All staff are trained annually and it is a none patient area
AFD - is tested in accordance with BS 5839 Part1 2002 by a national certified company on a contract basis.
Housekeeping - flammable waste is removed daily and combustibles in the offices are kept to a minimum.

The Fire Risk assessment is reviewed annually by an external consultant.
The risk according to my assessment would probably be scored at 4 Likelihood 2 Consequences 2
That still leaves me with my original dilemma and one that I have always found perplexing. Why do we need additional protection just because  national guides say so..

[PhilB]

Brian

I repeat my belief that likelihood x consequence is not appropriate for fire risk assessments. It is not the likelihood you are interested in as I said in my first reply it may not be likely to happen but it may happen tommorow.

What is of importance is likely development and time for evac vs tenability.

Take your  fish-gutting factory, stone masons, church etc...the type of premises that so many people claim have a low possibility of fire occuring...I think many people miss the point.

You still have a reasonably foreseeable chance of a fire occuring unless you have no electricity supply and no persons are ever allowed to enter. Not a very practical building I would suggest!

Once you introduce these two possible ignition sources surely you have a likelihood of fire. What you don't usually have is likelihood of significant or rapid development that would compromise means of escape.

There are in my opinion a lot of defective methodologies....PAS79 to name but one that considers likelhood of fire a factor to consider when providing protective measures.

Likelihood is of importance so that property protection & mission continuity can be improved but you cannot remove necessary life safety protection because likelihood of fire occuring is considered very low.


On your final point I do not think you do need additional protection just because a guide says so. Guides are good benchmarks but we need to look at the actual risk and provide what is appropriate.

[wee brian]

National guides serve as abenchmark, without which risk assessment is meaningless. Ideally we could just set the level of acceptable risk using an absolute value (say 42!). But this is almost impossible to do and fire risk assessments would take so long to do that the country would grind to a halt.

The simple risk matrix you are talking about is nothing more than a handy way of comparing risks relatively. They do not give an absolute value.

Instead we have standards and guides that suggest what should be done in different types of building. If, for some reason, you wish to do something else then you need to consider the implications.

In the case you are talking about the national guides say use FR glass to protect the escape route. This would be based on a presumption about the level of risk in the offending accomodation. The powers that be are saying that we should take account of a potential fire in this accomodation on the escape routes from above.

If this accomodation contained no fire loading or such a low fire load that a fire likely to threaten this escape route was very unlikely then (this is where I disagree with Phil) you could argue that the FR Glass is unnecessary. However what you have said so far does not convince me. The provisions you have listed would be (near enough) what would have be expected in a code compliant building.

[PhilB]

Sorry Brian but on which point do you disagree with me? It appears very spookily that you are agreeing with me. If there is little or no chance of fire development I don't see the need for fr glazing.

That is entirely different from doing away with fr glazing because a fire is unlikely to occur. It is not likelhood of occurence but likelihood of development that matters.

[kurnal]

Brian and other friends
I hope to cause no offence or frustration by stating  what may be blindingly obvious but in practical terms:

You are absolutely right to minimise the risk of a fire breaking out and developing in this building, definately the right first consideration. But in every H&S arena we need to have an emergency plan to cater for something going wrong. In the Chemical Industry its a bund wall, in the healthcare industry its standard precautions, and electricians use insulated tools to work on circuits that they know are isolated. And in our industry its the right level of passive and maybe active precautions and good procedures.

In practical terms, in the building in question,
How many vertical exit routes do we need in this building (according to the guidance given in benchmark codes)?
What is the minimum standard of passive measures that would be recommended by the benchmark codes?
If we need two  escape routes is there any chance of a fire cutting off both routes simultaneously?
If we need to separate the routes, does the separation between the routes have to be via fire resisting glazing or could the line be drawn elsewhere, for example the corridor doors?
Or if we dont provide passive separation could we use active measures to provide an equivalent or better degree of safety?

The benchmark codes tend to go a little overboard in always recommending the protection of external escapes. Internal stairs in offices etc only require one door to separate them so why should we always require two lines of separation if one of them is external?

[jokar]

Kurnal, you are perhaps correct.  However, wasn't Buncefield built to prescriptive standards?  I think we would all agree that we need benchmarks but the interesting thing is that we can veer either side of them if we carry out a risk analysis.  Knowing what the benchmark is can be a start, knowing the risk a second and computing the risk against the benchmark may give you an answer.  If we apply benchmark standards all the time nothing would get built, certainly not the Gherkin in London and other equally fine buildings across the UK.  The substitution of one thing for another to enhance the opportunity to build has taken place for many years, we certainly would not build a Pyramid now.  Surely the approach should be to analyse the risk against the benchmark standard, in this case HTM, and assess it.  The interesting point of course, is where the prescription came from in the first instance, if anyone knows or can remember and, is it suitable now.  "You cannot reverse a fire engine more than 20 metres, why, because horses in the long ago days would not walk backwards further than that or its imperial conversion rate".  However, B5 and BS5588 Part 5 still say the same thing, is it relevant to those vast new trucks and their skilful drivers?  I could be more boring, the point is do an FRA assess it all from benchmark standards and make a decision based on "as low as reasonably practicable" and defend that if necessary in a court of law.

[steve walker]

Phil,

I agree that your point raises a fundimental question about fire safety.

There does not seem to be a consensus that the risk of ignition should be considered separately from the risk to life from fire development.

I tend to agree that if there is a significant (whatever that is) chance of ignition then sufficient measures should be in place to allow safe escape.

However do you consider that a system like OxyReduct that reduces the likelyhood of ignition without removing the fuel would compensate for removal of basic escape route protection?

[PhilB]

Excellent point Steve! There is always an exception to the rule, except in mathematics which is the exception to the rule that there is always an exception to the rule......

Yes with a oxyreduc system I concur there would not be a risk of fire occuring and so some protection could therefore be removed. But usually in normal conditions there will always be a risk of fire occuring.

In my opinion this is a fundamental point that many seem to miss.

I believe when we talk about fire risk we should be looking at the potential for a fire to cause harm when it occurs not the potential for a fire  to occur. Because in all premises (except those with oxyreduc) containing people and/or electricity you have an ignition source and so a potential for a fire to occur. If the only fuel available is a wet fish you may reduce fire protection because rate of development will be very slow.

[Chris Houston]

Yes with a oxyreduc system I concur there would not be a risk of fire occuring and so some protection could therefore be removed. But usually in normal conditions there will always be a risk of fire occuring.

Assuming the system works, the ingegrity is maintained and that oxygen levels are reduced to the correct level for that fuel.  Fuels need different oxygen levels to burn.  A new fuel might be introduced.