Change of Use to B&B, Part B regs and RRO compliance

[TickityBoo]

Even the CLG guides suggest 3 storey premises are unlikely to need lobbies (it is not until the premises comprises 4 storeys that a lobby is indicated as a requirement for smoke control purposes, according to their diagrams).

[timandfi]

Sorry but can you expalin what a CLG guide is please? I can then look it up and use this with the BCO. Thanks

[messy]

It's the Govt guidance offered to help compile a fire risk assessment

Have a look here for the sleeping risk guide

http://www.communities.gov.uk/documents/fire/pdf/151339


Messy

[nearlythere]

So what makes you think the ADF is not sufficient, we will have smoke detectors, emergency lighting, signage to all the escape route. The AFD was passed on the full plans sunmission at L2 level (but also then with a sprinkler system to the escape route as BCO had requested, see first post). No possibility of an alternative MOE (method of escape?) to second floor, the house is not that big! Beleive the travel distant is actually within that of a small premises scope, but obviously we do not fit that criteria as have the second floor.
All along we have said would be happy to go to L1 if it helps but no one seems interested.

Because in small premises L2 would probably end up to L1 standard anyway.
All the provisions you state are nothing new that would go towards a compensatory factor.
Your only hope, I think, is to get a FRA carried out and present it to with your submission. It may be that BC would be happier if someone else to took ownership of the risk.

[CivvyFSO]

One (Simplistic) way of looking at the L1/L2 issue is: Upgrading to an L1 system only gives any benefit if a fire starts in a cupboard so it is no replacement for lobbies. Lobbies are there to keep smoke out of the escape route, the only other way to do this is to physically remove the smoke, i.e. Smoke control as ADB suggests.

For what it's worth, the BCO won't be interested in the CLG guidance, and MOE is "means of escape".

[Midland Retty]

Far be it from me to cast nasturtiums on the knowledge of BCO's, but perhaps this one is actually looking at smoke ingress into the escape route, which is the main reason for asking for lobbies.

I don't doubt for one minute that he is.

But I think its a bit OTT personally. But thats just me.

The more i think about this then the only other thing I can now suggest is looking into smoke control system that ADB and CivvyFSO suggest.

This might be a ball ache though, i just don't see how it could work effectively in that type of premises for the reasons Kurnal suggested earlier in this topic, and you will need to get the experts in to ascertain just how easy this would be to achieve.

I wish there was a simplistic solution for you, but alas Building Control are the lead authority in this case and what they require will differ from the requirements the fire authority would ask for.

I'd be happy with single line of FR and an L1 system in that type of premises, if lobby or corridor approach cant be achieved.

[kurnal]

Back from my travels- lots of new postings since I last looked at this most interesting of cases. Heres my view on it so far for what its worth

1- Change of use from residential 1b to residential 2b does represent a material change of use and to keep within the law it is right to submit an application.Many dont bother- but if you dont you are in breach of the Building Regulations and this could be enforced within 12 months of the change taking effect, you could be served with a notice equiring changes to be made.

2- As far as the Building Regs is concerned, they would normally just look at the present use and work from this rather than what happened 10 years ago

3- Once you have made an application with a building control authority, either local government or approved inspector their protocols do not allow you to switch horses halfway through the race, this is to prevent people trying one after the other till they find someone prepared to accept their scheme.

4- The building inspector does not have to work to ADB- its usually down to the applicant to identify the design strategy adopted. ADB annex does list other documents references as well, the DCLG guidance has no status as far as the buiding Regs is concerned but it would be very interesting in an existing building to take diagram 50 of the Sleeping guide as the design strategy - after all building Regulations B1- B5 are Functional requirements and the sleeping accommodation guidance is being taken as best practice in enforcement cases!

5- Avoid at all costs any determination or appeal to the Secretary of State, these arguments are always  decided on purely technical argument and nearly always find against the apellant.  Does ADB recommend a lobby in this case? Yes. Have you provided one? No Have you provided an alternative system using  pressure differentials to protect the stairs ? No. Appeal dismissed. The secretary of state wont be in the least interested whether lobbies would in this case have any benefit whatsoever, just whether they are there or not.

6- In practical terms you need to resume dialogue with the inspector. Present an alternative offer to him as I suggested in an earlier posting and give him space to ask for a little more. I would speak to the senior fire safety officer for the area- ask him for advice, get him on board and show him your proposals and compare it to the DCLG guide. Despite what the building inspector says the fire officer cannot reasonably turn down a proposal that fully conformes to the Govermnent guide.

7-I would suggest multi sensor detection to an L1 standard to give the earliest warning of any type of fire. And all fire doors to the stair to a pucker standard with (if necessary) new frames. FD30S doorsets. If he still holds out for a lobby I would then offer swing free self closers. Would you prefer two doors likely to be wedged open or one pucker dink fire door you can rely on?

8- You were looking at sprinklers but were unable to find an installer or had a problem with the mains I believe. Before burying this as a solution I would get a quote from someone like aqua mist of Wakefield, which is a low pressure water mist system. Heres their web site http://www.aqua-mist.co.uk/
you could also try one of the many sprinkler suppliers listed here http://www.bafsa.org.uk/mission.php  

Hope this helps and keep us in touch with progress

[nearlythere]

Timandfi
I have read and re-read your posting and cannot make sense of why lobbies are being required and the proposed consultants solution. There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas. I can only assume there is something unusual about the layout such as long dead end corridors or inner rooms or open plan staircase or something?  
Have the building control given any justification for requiring lobbies?  

Did your consultant have experience in a fire safety enforcement department or was he just an operational chap?

Have you downloaded the Fire Safety Order guidance documents from the http://www.communities.gov.uk/publications/fire/firesafetyrisk4
 website  and the building Regulations approved document B from the planning portal site?

Take a look at this thread which may be relevant to your quey:

http://www.fire.org.uk/punbb/upload/viewtopic.php?id=2493

Kurnal
There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas.
They may be operating for some time and are out of the control of BC. They may be unaproved conversions operating on a wing and a prayer.
Unfortunately, new or converted buildings are not assessed under old standards.

[kurnal]

Yes nearlythere but are these "smallish 3 storey hotels with a single protected staircase and full detection in all areas" not fit for purpose?

Does it really make any contribtion to the safety of an existing building if we make these people put in a telephone kiosk type lobby at the entrance to every room in the buiding creating dead space, incredible ugliness and inevitable abuse by wedges? For what benefit? Many of these lobbies are so small that to pass through them both doors have to be opened at once in order to pass through. And if we dont is the building not fit for purpose?

I am proud to say that in my career as an enforcement officer I was never responsible for imposing this monstrous idea on any of my clients though it often happened in the early days under the original Fire Precautions Act red guide for hotels.  In the early days it was easier to justify full detection in lieu because many fire authorities would ask for detection in staircases only for these buildings - later detection to L3 and L2 came along and it was no longer considered to be a trade up to detection in lieu of lobbies. From then on it got a little more difficult to win.

I think that the goal in ADB for lobby protection of a single staircase is a good one for new buildings where it can be incorporated in a sensible way. But in an existing building it is unreasonable and impractical if it means taking a bite out of the corner of every room. If I could see any benefit to it I would go along with it. But nobody has ever been able to convince me what this benefit is and how it works- when the rule was first contrived there was little or no detection, no fire or smoke seals, no swing free self closers available on the market.

HM Goverment guide to fire safety in sleeping accommodation  published in 2006 diagram 50 shows a 3 storey building with single door protection and full detection and in the courts this document is being held up as best practice.

HM Government approved document B published in 2006 says lobbies are required in these circumstances.

Both are different, both are enforced by Government staff- which is the right standard in this case?

[timandfi]

Thank you so much to all for your help and advise, wher to start as a novice is this is overwhelming to say the least but I am sure once we get started the points you have all made will be invalueable.

An interesting point on the last posting by Kurnal you say the sleeping accommodation document is being held up as best practice in the courts, is there any information freely available on any such cases? May be useful to cross reference in any justification we submit to BCO.

[Tom Sutton]

It appears most of you are approaching this problem from a FRA angle as far as I am aware BCO`s enforce the ADB using a prescriptive approach. If it conforms to ADB it is approved, if it cannot then you need to consider compensatory means.

In this case I would suggest lobbies are needed to control smoke therefore you need to provide means of controlling smoke.

1.   AFD will not control smoke and I believe this is why they will not accept an upgrade.
2.   Sprinklers will extinguish a fire in its initial stages therefore limiting the amount of smoke produced
3.   Pressurisation of the escape route would control the smoke
4.   Automatic ventilation would not control the smoke but would keep the escape route passable.

I would think the last three suggestions would be acceptable to BC. Failing that the last option would be an engineered solution with lots of calculations or a well argued solution, or maybe the both.

[jokar]

TWSutton,  I agrre with the pressurisation example, the doors are already there, they will have existing leakage paths and therefore may be the most sensible solution to an entrenched problem.

[Midland Retty]

Timandfi
I have read and re-read your posting and cannot make sense of why lobbies are being required and the proposed consultants solution. There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas. I can only assume there is something unusual about the layout such as long dead end corridors or inner rooms or open plan staircase or something?  
Have the building control given any justification for requiring lobbies?  

Did your consultant have experience in a fire safety enforcement department or was he just an operational chap?

Have you downloaded the Fire Safety Order guidance documents from the http://www.communities.gov.uk/publications/fire/firesafetyrisk4
 website  and the building Regulations approved document B from the planning portal site?

Take a look at this thread which may be relevant to your quey:

http://www.fire.org.uk/punbb/upload/viewtopic.php?id=2493

Kurnal
There are many smallish 3 storey hotels and B&Bs with a single protected staircase and full detection in all areas.
They may be operating for some time and are out of the control of BC. They may be unaproved conversions operating on a wing and a prayer.
Unfortunately, new or converted buildings are not assessed under old standards.

Nope - Id except single stair case condition with L1, 30 min fire doors. As does the sleeping accomodation guide

[timandfi]

Don't understand the comments from Jokar, can you expand further please?

Also picking up on one of Kurnals points, whats the best approach to get the brigade on side? The BCO has not told me who they have consulted only that it is not the main point of contact at our local station. Should I ask BCO or just approach the brigade and is so who / what position are they likely to hold? Just thinking that given the points made that they do not have grounds to object looking at fig 50, pg 98 of the sleeping accom document may be good to explore their opposition first before putting a new proposal to BCO. That is of course assuming BCO have really discussed with them!

[jokar]

You can have a pressuried staircase in some staircases in lieu of lobby approach as the purpose of both is to not allow the opportunity for the ingress of smoke into a staircase.  Normal fire doors can have intumescent strips and cold smoke seals around them, these have to be removed in the case of pressurisation to allow for a leakage path at each floor level for the air.

You can ask advice from the local FRS, just telephone the number given for the headquarters, they are tasked to give advice on fire prevention, means of escape and restricting the spread of fire under the ACT that they work under.