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

[wee brian]

Pressurisation is a nightmare in existing buildings - it will cost a packet.

[timandfi]

Thanks wee brian

I can confirm I do not have a packet to spend! As I have said previously we are not looking to compromise safety but are seeking and hoping for a solution that is sympathetic to a building built in 1895 and one which is practical for its size and level of occupation at a max of 12 persons including the owners.

[nearlythere]

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?

I agree with you entirely Kurnal and I can recall yonks ago that double door protection in single staircase conditions over 2 storeys was the norm. This was relaxed in many cases with the introduction of new technology in the form of AFD which seemed to cure all ills.
Everybody in this site would agree that full AFD in small premises could be a reasonable compensatory factor under the circumstances but unfortunately the enforcement authority does not.
We have to remember that the technical guides are exactly that, guides. But with this BC it is the law.
I have no doubt that a good lawyer advised by a good Risk Assessor could convince a court that the place is fine but the cost would be prohibitive.

[Tom Sutton]

I agree with you entirely Kurnal and I can recall yonks ago that double door protection in single staircase conditions over 2 storeys was the norm. This was relaxed in many cases with the introduction of new technology in the form of AFD which seemed to cure all ills.

What do you consider the reasons for double door protection I believe it is to control the movement of smoke and if that is correct then AFD by itself will not be a satisfactory solution? AFD combined with automatic ventilation yes.

What is your rationale with regards to AFD being satisfactory by itself?

[kurnal]

Conversely TW for this particular scenario- building in a silly little lobby into the corner of each room in an existing building- how does this help anybody?

Remember the many buildings ruined in this way in the early days of the FP Act guides, in those days smoke detection was unusual and if it was installed usually covered the staircase only, in the days of screwing asbestos sheets to the back of panel doors and glueing and screwing one inch rebates to existing frames. We had furniture made of dangerous polyuerthane foam and widespread use of coal fires and smoking was the norm. Electrical equipment was protected by wired fuses and RCDs were rare - and then with 80mA tripping current. No rules on PAT testing.

There was never any talk then of why it was done - it was double door protection. A fire would have to burn through two fire doors and smoke would have to pass two sets of rebates to affect the stairs. No science to it , and no requirements were made for the size of the lobby- I have seen 4 inches between two doors.

Now we have FD30S, full detection, no smoking, safer furniture, 30mA RCDs as the norm, central heating, PAT testing, and we are still asking people to ruin an EXISTING building by taking a corner out of each room to create a lobby?

We will know of the fire early before the smoke level descends to the top of the door of the room involved, the smoke and fire seals will do their job and the stair will remain sufficiently safe to enable escape.

If we are seeking to prevent smoke from a room on fire from entering the staircase does it make sense to ventilate a stair within the evacuation phase when the slightly negative pressure caused by the stack effect will draw smoke from rooms into the stair just as people are needing to escape?

Does anybody have any experience of pressurising a staircase in what is essentially a private house? I have never heard of it and cant see it as a practicable solution.  Where would we put the plant room?

Sprinklers or water mist- yes I wholeheartedly agree, but I contend its a sledgehammer to crack a nut - bringing huge benefits but out of proportion to the identified crux of the problem.

[timandfi]

Picking up on on earlier point hs anyone got a view on how best to approach the fire officer and get him on side prior to us opening dialogue again with the BCO?

[kurnal]

Hi Fiona
Call the local fre and rescue service HQ, ask for the number of your area fire safety office. It may be
Scarborough Fire Safety Department North Marine Road, Scarborough, North Yorkshire, YO12 7EY
 01723 374433

If it isnt they will put you right.

Ask to speak to the senior fire safety enforcement officer for your area. Ask them to visit you to give you advice or if you can visit them. If you visit them take your photos and plans.  They will have a file following your building regs application.
Be straight with them tell them of your problems and ask for their advice, taking all we have discussed into account. They are usually nice people who are willing to help. Dont ask them to take sides or to help you take on the BCO. They wont. But draw them into giving an opinion which you can later develop into stronger support. Just something like a verbal opinion that in this case they would not be concerned with your proposals.  

An experienced officer is most likely to take a reasoned view, a less experienced personmore likely to hug the codes.
So show interest in the inspector ask questions such as how long in the service, how long on the trucks,  where they have served,  how they enjoy their job, what they find rewarding.

If you think they may be fairly inexperienced in terms of fire safety dont draw them into committing themselves - ask them to consider and come back to you later. They will then bounce it off one of their colleagues before digging themselves in.

You will then be armed to revisit the BCO knowing whether or not the brigade has sympathy with your position. It may then be worth having a tripartite meeting at your place confident that you know the brigades view and the psychology will do the rest.

[messy]

One more suggestion, Take a copy of this entire thread (and any on other forums!) with you to your meeting with the fire safety team. It will be a good reference source for you and will be able to help the FS Officer understand your argument.

[nearlythere]

timandfi
Wait a day until I do some final research.

[timandfi]

Thanks again for all the help and support and is very very much appreciated.
Will wait to hear on your further piece of research Nearlythere.

[AFD]

Without going into the ins and outs of the lobbies.

If the problem is the protection of the escape staircase i.e. single door or lobby, how does an L1 system compensate for the lack of a lobby ?

The risk rooms and routes onto the stairs that the lobbies would be used to protect the staircase route, would already be covered by AFD with an L2 !

Also without looking at the full guidance and standards, can it be done with single door etc. what about a positive pressure ventilation system for the staircase ( i.e. keep the smoke in the rooms and out of the stair ?)

[AFD]

Sorry ! I forgot to add I think London FRS have similar buildings with this solution in, ie one big fan in/on roof

[1stclasschef]

Hi I have worked in the hospitality business for many years and have owned 4 guesthouses/hotels as well in that time, not all at once though! I have never worked in a place that has a lobby as extra fire protection, and cannot think of any, except the large hotels where I now live that have them, there are many guest houses hotels and B&Bs, 3 storey places, one staircase, no other means of escape, other than climbing out of the window.

Why do these regulations not apply to self catering cottages/houses, I stay at a 4 bedroom cottage in cornwall, that can sleep 7-8 people, it has 2 battery operated smoke alarms, and a fire blanket in the kitchen and a small extinguisher, no fire doors, etc. yet have 4 people or even 1 person stay at your own home which you let a couple of rooms for B&B and everything kicks in regulation wise.

With these new fire regulations, I can personally see the smaller operaters i.e 3 rooms or less not existing any more in the near future, which will be a shame.

[nearlythere]

Why do these regulations not apply to self catering cottages/houses, I stay at a 4 bedroom cottage in cornwall, that can sleep 7-8 people, it has 2 battery operated smoke alarms, and a fire blanket in the kitchen and a small extinguisher, no fire doors, etc. yet have 4 people or even 1 person stay at your own home which you let a couple of rooms for B&B and everything kicks in regulation wise.

Because  a self catering cottage is not a B&B, guesthouse or hotel. It is essentially a single family dwelling.

[1stclasschef]

Yes It is a single dwelling, but still run as a business, paying business rates, fire risk in my opinion no less than having 4 or 6 people stay in your b&b, infact, fire risk could be more in a self catering house sleeping 7 or 8 people, no owner on site the occupants could smoke in the rooms, fall asleep, set fire to the house...