Part M

[David Rooney]

We are being told more and more (by one particular london council) of the need to comply with part M which requires beacons in all toilets.

a.   why is this in part M and not 5839?
b.   why haven't our BAFE inspectors ever pulled us up for not installing beacons in all toilets?
c.   if we as a company design a system and put our name to it as compliant with 5839, what right has a council official to say it doesn't comply because of the part M regs?

thanks

Dave

[wee brian]

It may well comply with BS 5839 but that dosn't mean it complies with the Law. In this case Part M of the Building regs (its in Part B now too)

BAFE will only pick it up if they are checking for compliance with Building Regs. As a third party cert company they check to see if you have complied with what you say you have.

[David Rooney]

So is part M/B retrospective ?

We maintain hundreds of buildings and I can't say that any of them have beacons in all the toilets.....

[jokar]

No,

Part M is not retrospective.  It is for use when work under the Building Regulations is taking place.  However, under the Fire Safety Order and under DDA, the Responsible Person should be looking at how all relevant people are warned of a fire and reasonable changes that need to be made to ensure that vulnerable persons are warned of fire in a premises.  That will not make it retrospective but it will be on a risk assessed and reasonable basis.

[Wiz]

I have had a quick look at the Governments info on this subject and I have as many questions as David.

Whilst part M is titled ' Access And Use Of Buildings' it doesn't appear to cover anything to do with fire alarm warning beacons in toilets. Why did a council official refer to that document

Section B1 of Document B is entitled 'Means Of Warning and Escape' and again, my cursory glance at the contents didn't appear to highlight anything about beacons in toilets.

Obviously beacons might be required where someone couldn't hear the normal fire alarm audible warning (i.e. loud ambient noise or for someone with hearing impairment). However, my understanding of the DDA isn't that every location in every building has to have everything necessary that a disabled person might want just in case a disabled person might use the facilities.

For example, a public building  would have to have reasonable disabled toilet facilities but not every toilet facility within that building would have to be converted to disabled user standard.

Therefore, the facilities for being warned of a fire alarm in a building that may infrequently used by hearing impaired persons may be met by installing a vibrating pager system, or by the provision of someone who takes responsibility to ensure the hearing impaired person is advised of fire alarm warning signals etc. etc.

I would appreciate anyone's guidance on this matter, preferably backed up with precise details of any documents confirming any 'facts'

[Allen Higginson]

I have had a quick look at the Governments info on this subject and I have as many questions as David.

Whilst part M is titled ' Access And Use Of Buildings' it doesn't appear to cover anything to do with fire alarm warning beacons in toilets. Why did a council official refer to that document

Section B1 of Document B is entitled 'Means Of Warning and Escape' and again, my cursory glance at the contents didn't appear to highlight anything about beacons in toilets.

Obviously beacons might be required where someone couldn't hear the normal fire alarm audible warning (i.e. loud ambient noise or for someone with hearing impairment). However, my understanding of the DDA isn't that every location in every building has to have everything necessary that a disabled person might want just in case a disabled person might use the facilities.

For example, a public building  would have to have reasonable disabled toilet facilities but not every toilet facility within that building would have to be converted to disabled user standard.

Therefore, the facilities for being warned of a fire alarm in a building that may infrequently used by hearing impaired persons may be met by installing a vibrating pager system, or by the provision of someone who takes responsibility to ensure the hearing impaired person is advised of fire alarm warning signals etc. etc.

I would appreciate anyone's guidance on this matter, preferably backed up with precise details of any documents confirming any 'facts'

The only thing is that hearing impaired people do not necessarily have to use the disabled toilets as they may be physically fully able otherwise (so consultants take note when you stick them only in the disabled toilets).

[Wiz]

I have had a quick look at the Governments info on this subject and I have as many questions as David.

Whilst part M is titled ' Access And Use Of Buildings' it doesn't appear to cover anything to do with fire alarm warning beacons in toilets. Why did a council official refer to that document

Section B1 of Document B is entitled 'Means Of Warning and Escape' and again, my cursory glance at the contents didn't appear to highlight anything about beacons in toilets.

Obviously beacons might be required where someone couldn't hear the normal fire alarm audible warning (i.e. loud ambient noise or for someone with hearing impairment). However, my understanding of the DDA isn't that every location in every building has to have everything necessary that a disabled person might want just in case a disabled person might use the facilities.

For example, a public building  would have to have reasonable disabled toilet facilities but not every toilet facility within that building would have to be converted to disabled user standard.

Therefore, the facilities for being warned of a fire alarm in a building that may infrequently used by hearing impaired persons may be met by installing a vibrating pager system, or by the provision of someone who takes responsibility to ensure the hearing impaired person is advised of fire alarm warning signals etc. etc.

I would appreciate anyone's guidance on this matter, preferably backed up with precise details of any documents confirming any 'facts'

The only thing is that hearing impaired people do not necessarily have to use the disabled toilets as they may be physically fully able otherwise (so consultants take note when you stick them only in the disabled toilets).

This is what I am talking about. If you install the beacons in every toilet facility then the costs will be horrendous. We will all end up paying for the cost of this in one way or another. A designated disabled toilet facility contains visual fire alarm warning so why can't the hearing impaired person use that facility. The affected person knows they have the impairment and so should be willing and sensible enough to use the facilites specifically provided to assist in reducing the impact of their disability. I have always understood the DDA  to be a sensible legislation asking for very reasonable requirements. However, many people seem to think that the act requires that everything everywhere has to be changed to be suitable for disabled persons - and I think they must be wrong.
The DDA does not provide specific precise requirements - it just provides an explanation of what must be achieved. BS and the building regs etc. confirm what should be provided where it is required, but these have been interpreted by many as being what is required everywhere when surely it is not.

[Mike Buckley]

I had a quick look at ADM and from what I can see there is no requirement to put fire alarms in the toilets. The wording (5.4 g) is "any fire alarm emits a visual and audible warning to warn occupants with hearing or visual impairments".

I would read this as meaning if there is a fire alarm in the toilet then it does need a beacon, however it does not say fit fire alarms in the disabled toilets. This is unlike the requirement to fit emergency pull cords in the toilets where it does say that they are needed to fit the requirements.

I would say this comes back to the Risk Assessment which needs to assess the risk to disabled people in the toilets. The whole thing then balances on the hazard and probability and finally on other measures i.e. a fire warden checking the toilets.

[Wiz]

Hi Mike,
Thanks for your input.

Taking your example findings and relating them to my previous post, I have had a quick scan through the Document M and I would summarise my understanding of the requirements as follows:

IF a building was new, or being materially altered or extended or changing use to a public building, hotel etc. etc. (Clause 0.1) AND there was only one W.C. on any particular storey (Clause 0.4 Example 1) then that w.c. would be designated as the facility for 'disabled' persons, so THEN it would be fitted with a visual (and audible) alarm warning device (Clause 5.4.g)

From this, relating back to the original question of why the council officer insisted on beacons being fitted in all the toilets, surely;

1) They would not yet be required if the building wasn't new, being extended/materially altered or undergoing a change of use to a 'public' building.

2) Only one w.c. facility per storey would be designated a disabled w.c. anyway, and then require the appropriate facilities.

I accept that other factors, such as a fire risk assessment, may have a bearing on the requirement for the beacons, but the original point asked was why the Council Officer insisted Document M required them in every w.c. in every building

I accept that my summary was based on a quick scan through Document M and I welcome any advice that explains why I might be wrong!

[Allen Higginson]

I think the thing is that it is open to personal interpretation.I am still of the mindset that disabled = less able bodied (ie - physical).With the example given by Mike it should be easy (ish) to retrofit LED indicating units on to existing sounders (Fulleon are one manufacturer that do such units) or new combined units - the additional load is a lot less than having to fit the old xenons.
However as it is not retrospective the cost implications are there only in new installs or building mods and I'd say all of the addressable manufacturers offer some degree of loop powered sounder/beacons.

[Wiz]

Buzz,
these sort of documents are written to try and do away with personal interpretation (!). It is possibly lack of knowledge or knowledge based on rumour that causes so many problems. If this council guy is telling all  contractors etc. that they have to fit visual warning beacons in all toilets everywhere because of part M, then, I believe, he is wrong and he will force people to spend hundreds of thousands of pounds that is not necessary. This cost will be passed on to the whole of society in one form or another. The DDA is trying to make sure facilites are available to make buildings accessible and usuable by disabled people. It is asking for the minimum amount of facilities to achieve this, not asking that every facility has to be converted for disabled use.

We are not talking about upgrading an audible warning to a combined audible/visual warning in the case of the original post. We are talking about someone, who should know better, possibly giving the wrong interpretation of the guidance/regulation documents and asking for new equipment in every toilet. These toilets are probably served only by a sounder in a corridor nearby, which if upgraded to a audible/visual would do no good if the toilet WAS designated 'disabled facilities'

In respect of Mike's last input, I actually feel that his interpretation of 5.4.g is wrong, and it is this specific clause that IS actually confirming that disabled toilets DO need audible and visual alarm warning indicators in all circumstances. However, this is not the important part of my argument.

My argument is that visual fire alarm warning does not have to be installed in every toilet but only those that are designated as 'disabled facilities'. Not every toilet has to have disabled facilities but only at least one on every storey of a building. Not every building has to create a toilet with disabled facilities unless it is new, or materially extended or altered or undergoing a change of use to a public building. That is how I've read the document  and I welcome any guidance on any point that I have misunderstood.

[wee brian]

OK Boys - extract from ADB 2006 vol2. This applies to new buildings. This says to me that the majority of toilets (not just toilets for disabled people) in new buildings should have visual warning. What you do in exisitng buildings is a matter for your client and the DDA.

Warnings for people with impaired hearing

1.34 A suitable method of warning (e.g. a visual and audible fire alarm signal) should be provided in buildings where it is anticipated that one or more persons with impaired hearing may be in relative isolation (e.g. hotel bedrooms and sanitary accommodation) and where there is no other suitable method of alerting them.

In buildings such as schools, colleges and offices where the population is controlled, a vibrating paging system may be more appropriate. This could also be used for alerting people with other disabilities.

Clause 8 of BS 5839- :2002 provides detailed guidance on the design and selection of fire alarm warnings for people with impaired hearing.

[Wiz]

Well done wee brian.

I would read that exactly as you do.

Document B (not M) asks for visual fire alarm warning devices in all toilets.

I have only now quickly scanned Document B (2007) but you indicate that it only applies to new build. Do you know which clause explains this? Furthermore, out of interest, do you know if the visual warning item was worded exactly the same in the 2006 edition?

This obviously doesn't necessarily change anything in respect of the original post by David, but it probably explains why people are getting confused.

[wee brian]

The 06 and 07 ADBs are the same, the 07 version has some of the typo's corrected.

If you want to know what the Building Regs cover then you need to look at the Regs themselves.

Its a bit complicated but a simple trnaslation would be.

New Buildings - Comply with ADB (or another approach that gives the same level of protection)

Extensions - The Extension Complies with ADB (or as above), the rest of the building should not be made worse. If escape routes from the extension run through the exisitng building then it may need some upgrading.

Alterations - Whatever you are doing should comply and this should not make the building worse than it was before.

If you want to read the regs (good luck) they are at http://www.planningportal.gov.uk/uploads/br/BC_Consolidated_Bldg_Regs.pdf

[Wiz]

Wee Brian,
Thanks for your reply.

It sounds as if Document B applies in the same circumstances as Document M i.e. New, extensions & possible some changes of use. I found this explained in M but couldn't see it in B.

If I was David I would say to the Council official that what he wants is Doc. B, not Doc. M and it may not be applicable to his hundreds of existing buildings anyway.