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

[CivvyFSO]

In the house the people are living together as a family unit and as such are less of a risk to each other than 6 separate families/couples sleeping in seperate rooms.

Nearlythere, the cottages still come under the fire safety order, the occupants are still relevant persons. It doesn't quite come under the umbrella of "single private dwelling".

[timandfi]

One more thought on our options, in the event of not getting a resolution to this current situation. As I understand it BC are involved because of the change of use. If we were to only do 3 bedrooms (6 persons) as B&B we do not need planning permission so is it correct to assume we do not need building regs? I accept we need BC if we put in ensuites where they have not been before etc but in relation to ADB and the lovely lobbies?? And if this is the case do all the letting rooms need to be on the first floor?

We would not change the plan to install the L2, fire doors and all the requirements of the RRO. Just do less rooms to avoid change of use.

[nearlythere]

One more thought on our options, in the event of not getting a resolution to this current situation. As I understand it BC are involved because of the change of use. If we were to only do 3 bedrooms (6 persons) as B&B we do not need planning permission so is it correct to assume we do not need building regs? I accept we need BC if we put in ensuites where they have not been before etc but in relation to ADB and the lovely lobbies?? And if this is the case do all the letting rooms need to be on the first floor?

We would not change the plan to install the L2, fire doors and all the requirements of the RRO. Just do less rooms to avoid change of use.

You would still need BC approval because it is a change of purpose group. If you used only the first floor as guest rooms then BC may not require double door protection.
But as you know anything could happen.

[Tom Sutton]

Kurnal I would agree with you if it is a silly little lobby into the corner of the room then it is not fit for purpose and you should find an alternative.

You state “There was never any talk then of why it was done” well there certainly was in my brigade, maybe because a BCO had been asked in court why he had required double door protection and was unable to give a satisfactory reply. He was systematically ripped up for the proverbially. It was discussed at some depth and the consensus of opinion was for smoke control which I still accept. I agree not scientific but if it does not achieve this aim then it is not an acceptable solution. Any other theories would be interesting.

I accept the smoke reservoir above the door limiting the amount of smoke getting into the staircase so I withdrawn my comments about AFD.
 
When the door closes in the room of origin how can the slightly negative pressure caused by the stack effect makes things worse? The door is closed the small amount of smoke in the staircase is expelled. The only way a large volume of smoke would enter the staircase if a door burnt through or self closer were not fitted and with AFD this should not happen.
 
The improvements in safety you highlighted will reduce the fire risk but not eliminate it, so in the case of a fire you still have the problem of smoke control.

Back to this problem I think Timandfi needs to establish why the lobbies are required. If they are as I suggested controlling the movement of smoke then

1. Sprinklers or water mist are discounted for the reasons you stated
2. Pressurising a staircase again for the reasons you stated.
3. AFD and automatic natural ventilation discounted which I disagree with you.
4. Finally the preferred option is AFD to a L1 standard combined with an explanation why. Provide calculations to show how quickly the occupants of a room involved, could vacate the room and how long the door would be open. Provide smoke calculations taking into account the reservoir above the door and how much smoke would enter the staircase. To what degree this smoke would hinder the escape of other occupants or something on those lines.

I think it is essential for Timandfi has to make a good case for his alternative solution to convince the BCO.

[messy]

Can somebody tell me what would be wrong with 1 hour fire doors instead of lobbies?

Yes - they are a bit 'lumpy' and yes- you don't get the smoke reservoir that a lobby provides, but this assumes that persons would be escaping from the room of origin.

How often do people need to escape from the room of origin? Assuming the occupants did need to evacuate that room, how much smoke would enter the staircase with them? I suggest that for the vast majority of cases, if the smoke is at the level which allows occupants to self rescue, it would not create the thick plume which would cause difficulties in the stairwell.

In addition, how long would it take for 2 persons (an average room occupancy) to escape through an open door in a fire situation? Probably a little quicker than if negotiating two doors in a tight lobby scenario such as Kurnal described earlier. Then the door closes behind giving plenty of time for others to pass by it.

I agree with Kurnal's earlier observations that lobby protection (in some cases) is yesterday's technology and perhaps with difficult buildings such as the one in question, a tad more lateral thinking might be helpful

[Tom Sutton]

Can somebody tell me what would be wrong with 1 hour fire doors instead of lobbies?

Using your philosophy I don’t think you need 1 hour fire doors 30FDS would be sufficient as 30mins for MOE is usually considered adequate.

[nearlythere]

Can somebody tell me what would be wrong with 1 hour fire doors instead of lobbies?

Yes - they are a bit 'lumpy' and yes- you don't get the smoke reservoir that a lobby provides, but this assumes that persons would be escaping from the room of origin.

How often do people need to escape from the room of origin? Assuming the occupants did need to evacuate that room, how much smoke would enter the staircase with them? I suggest that for the vast majority of cases, if the smoke is at the level which allows occupants to self rescue, it would not create the thick plume which would cause difficulties in the stairwell.

In addition, how long would it take for 2 persons (an average room occupancy) to escape through an open door in a fire situation? Probably a little quicker than if negotiating two doors in a tight lobby scenario such as Kurnal described earlier. Then the door closes behind giving plenty of time for others to pass by it.

I agree with Kurnal's earlier observations that lobby protection (in some cases) is yesterday's technology and perhaps with difficult buildings such as the one in question, a tad more lateral thinking might be helpful

2 x 1/2fr doors are not there to provide 1 hr protection. They are there to provide a smoke lock. The validity of this is questionable in all circumstances and appears to be more of "thats the way it has always been, so we'll keep it in the books."

[timandfi]

Not sure I agree with or understand the comment re needing BC for 3 bed rooms? There are B&B's opening all over with only 2 or 3 rooms and no suggestion of BC involvement, I could name a number that have done this here in the last 6 months and I definately know BC not involved, this applied to the house 2 doors away from me and he has had the local fire station officer round. My understand was BC only got involved if we applied for a Planning permission change of use. In we only do 3 bedrooms we do not need to apply for change of use and are still classed as a domestic dwelling, no commercial rates etc.
I fully accept we would still need to comply with the RRO but do not see the grounds for BC involvement.

[Ricardo]

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.

timandfi: see the Sparrow Hawk Hotel case in Lancashire which I can forward to you if you send me your email address.

[PhilB]

2 x 1/2fr doors are not there to provide 1 hr protection. They are there to provide a smoke lock. The validity of this is questionable in all circumstances and appears to be more of "thats the way it has always been, so we'll keep it in the books."

Quite correct Nearlythere 1hr fire door is not the answer, the lobby is for smoke control...not a smoke lock..... but to prevent smoke entering stairs by reducing the pressure of the hot smoke.

Could one fire door fitted with cold smoke seals for cool smoke, and intumescent strips for when things heated up provide a suitable alternative...probably yes.

[timandfi]

2 x 1/2fr doors are not there to provide 1 hr protection. They are there to provide a smoke lock. The validity of this is questionable in all circumstances and appears to be more of "thats the way it has always been, so we'll keep it in the books."

Quite correct Nearlythere 1hr fire door is not the answer, the lobby is for smoke control...not a smoke lock..... but to prevent smoke entering stairs by reducing the pressure of the hot smoke.

Could one fire door fitted with cold smoke seals for cool smoke, and intumescent strips for when things heated up provide a suitable alternative...probably yes.

PhilB this is an interesting view and a new one, I understand intumescent strips but have not heard of cold smoke seals. What do these do and could you maybe point me in the direction of website to source these?

Thanks

[timandfi]

Hi
Found the cold smoke seals on a Goolge search. Thanks

[Deadendburied]

First post for me.  

I've read this thread with interest and it raises some interesting points, the most straightforward one being that what is being proposed, supported with a suitable & sufficient Fire Risk Assessment, and well managed, would mean little difficulty in meeting legal obligations under the Fire Safety Order.  Unfortunately this doesn't help with the Building Regulations.

With hindsight, some pre-application discussions with a number of approving bodies might have found one with a more sympathetic view of the proposals (apparently this does happen!!!)

My advice would not be to contact the local Fire Safety Officer.  This is likely to be seen as at best trying to bypass the system and at worst playing one authority off against the other.  This is unlikely win favour with either party.

In terms of reference to the Fire Safety Order in Building Control Consultations, my understanding is that the Fire Authority respond firstly on compliance or otherwise with the Building Regulations, benchmarking to ADB unless specific variations are detailed, and secondly, any "Additional" requirements to meet the legal obligations of the Fire Safety Order or other legislation.

The requirement for the Fire Authority to advice on matters of Fire Safety is open to local interpretation.  Some still provide the full unpaid consultancy role of old, with those that have fully embraced the change to a professional auditing and enforcement authority, considering reference to guidance on either their own or Government websites, and very generic verbal advice as meeting their legal obligations.   The guiding principal is I understand "its your risk, you manage it", with the footnote reading ".... and if you don't have the expertise to do it yourself, you should employ someone who does, to do it on your behalf".

[Ricardo]

Hi
Found the cold smoke seals on a Goolge search. Thanks

timandfi
The following may also be of use to you, see page 122 onwards and also figure 65 for an easy to follow diagram

http://www.communities.gov.uk/documents/fire/pdf/151786

[nearlythere]

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.

timandfi: see the Sparrow Hawk Hotel case in Lancashire which I can forward to you if you send me your email address.

Don't thnk this is the same issue Ricardo. From what I read in the Sparrow Hawk Hotel case there did not seem to be fire doors on the rooms at all. In timandfi's case the issue is about have to provide two.