When you read Approved Document B to the Building Regulations I think you can see gaps when a building under construction is part occupied – and that is my point. It only covers the functional requirements of the Building Regulations in relation to fire and provides guidance as to how these functional requirements can be met.
Compliance with the approved document is only one way of demonstrating compliance and increasingly the Building Regulations are being satisfied by engineered solutions. Whichever approach is taken it is a fact that that until buildings are completed none of the safety systems required by the regulations are fully in place, commissioned or operative. A part occupied building can have incomplete [or non-existent mains], detector and alarm coverage limited, problems with access etc.
The B5 Guidance within the Approved Document provides details on fire mains and hydrants, vehicle access, access to buildings for fire fighting personnel and the venting of heat and smoke from basements. I would say that these have to be considered as soon as part of a building is occupied. To my mind it is equally important whilst the building is under construction as when the building is completed and occupied
There are many other aspects of building construction, in terms of both building materials and building systems that are not totally secure until building completion.
There are clear statements in the APD and Guidance, “Once a building is occupied and in use, the fire safety enforcing authority takes on the co-ordinating role as they have the enforcement role for the Fire Safety”
My point is that part of a project would be under FSO and part under HSE and that could create a risk. I mentioned the fire at Colindale with 200 plus flats, multi storey timber frame in 5 blocks. If the fire had occurred a few weeks later one or more blocks could have been occupied. Would the FSO risk assessment on the occupied blocks have identified the danger from the construction on the other blocks? If so who would have had responsibility? Would working methods be changed etc?
I am still not sure that ADB 2006 gives all the answers.
