Hotel Fire Doors

[kurnal]

Yes Phil.

But we must recognise that persons in rooms are relevant persons and even though statistics show people do not die in hotel rooms and you could use this to inform a probabalistic risk assessment, it is much harder to argue from the viewpoint of a qualitative risk assessment.

After all statistics also show that the people who live in category A council tax rated properties dont die in house fires but we impose the same buiilding reguilations requirements for smoke alarms on them as we do the HMOs where 40% of fire deaths occur.  

So considering the possibility that a fire does break out in the hotel bedroom, however remote that chance may be as a result of our other risk control measures, will a heat detector give sufficient warning to alart them? No of course we know it wont. Will a smoke detector be any better? Maybe or maybe not- I dont know of any studies that have been carried out on tenability  within the room of origin based on a wide range of fire scenarios that would be necessary to come to absolute conclusions, though much was done on this in respect of residential sprinklers.

But if we leave the heat detector in place are we adapting to technical progress? What argument can we use to convince the fire authority and the judge that risk is ALARP if we dont update the detectors?
I too agree with Colin Todds point of view as expressed elsewhere in this forum, but recognise that the problem of false alarms need not now be an issue with multi sensor technology- but for many hotels their existing system would not support this.

I have tried and tested this argument in a number of situations without much success - many brigades have adopted it as a policy to upgrade all detectors to smokes, whereas in other areas they still appear to be tolerating the lowest of standards- with some manual systems still in place. Thats where brigades should focus their enforcement resources not hounding the small B&Bs and making them upgrade to make their homes fit the pictures in the guides.

[PhilB]

I quite agree with all you say Kurnal and yes of course the person in the room is a relevant person. Yes there is a need to adapt to technological progress but I'm not convinced that spending thousands of pounds to replace heat detectors or to place domestic smoke alarms alongside heat detectors is the best way forward.

Hotel with manual fire alarm, no question, upgrade is needed and smoke detection should be used.

Hotel with L3 OR L2 but heat detection within rooms, personally I would live with. As a consultant I would of course recommend that the system be upgraded as part of an ongoing improvement programme.

What if there is heat detection and poor fire doors and limited funds. Would the upgrade of the doors not be better use of available funds.

It is a tricky one for the hotelier because ultimately what he must provide depends on the competence of the consultant, inspector and/or the policy of the FRS, and as we know that varies greatly.

[Midland Retty]

Perhaps as Phil states a balanced approach would be to agree with the RP that when each room undergoes re-decoration part of the works should involve changing the heat to a smoke detector.

Thats said of course I still take issue to a large degree with the " sacrificial guest" argument. As we know smoke kills, not flame, and our unwitting guest may never wake up by the time the heat detector has activated.

Conversely take a 200 bed hotel - how on earth do they afford to upgrade heat to smoke detection in one go?

[Thomas Brookes]

Another way of looking at this, on Legal and Moral grounds.

Assuming you have carried out a fire risk assessment on this 40 bedroom hotel, you look at the doors and there are not any smoke seals anywhere.
You talk about this to the owner who explains hes not got enough money to do the work, because he's had to spend all his money of refiltting the kitchen etc.
After some sole searching you deside not to reccomend smoke seals.

Six months later a fire happens on the middle floor in room 25 at 1.15am, Mr Bigs staying and has gone out for the evening and left his laptop on charge, it bursts into flames because of a battery fault and because it was left on the bed it was soon a very big fire, and because you did not spot that the detector was a 90 degree heat detector the fire is massive before the fire alarm activates.
Before long the room is engulfed in flames and at around the time the 90 degree detector goes off the door fails and smoke is now puthering out in to the hall way, this is rapidly spreading through the hallway. People are evacuating, some are hesitating "it must be a faulse alarm they think" Mrs Smith on the top floor is sound a sleep after her sweet sherry in the bar earlyer and had removed her earing aid along with her false teeth, so does not hea the sounder thats out on the landing. Mr & Mrs  Johnson on their honeymoon are dead to the world after spending all evening pub and clubing, those vodka redbulls were going down a treat.
After 9 mins the fire & rescue services attend and find a large group outside, flames are now bursting out the first floor windows and smoke has completely filled the upper floor.
Unfortunately Mrs Smith & Mr & Mrs Johnson  never woke up, the drink ensured they were sound asleep and then they peacefully died of smoke inhiliation.

Six months later its your big day, you arrive at court and sat their waiting are Mr & Mrs Johnsons parents along side their three year old sobbing child who was staying at Gran's while mummy & daddy had a honeymoon, Gran points you out as the man who could have made a difference to the out come, Mrs Smiths son is there and hes mad as a box of frogs he is being help back by his wife, he just wants to beat you to a pulp.

In court you sit though the porceedings and all the expert witnessess saying how they all had smoke in their lungs and the fact that the fire never actually got to the top floor. Jack Smith the smoke seal manufacturer brings in videos and documents all about smoke seals the jury see just how good his seals are and that they may have helped save Mrs Smith & the Johnsons. Jack then drops his bomb shell, "the hotel owner even asked for a quote, but said that they were to expensive".

Its now your turn and the best prosicutor in the uk on fire safety ask's you this question. " As the expert advising the hotel owner, why did you not insist on smoke seals in your assessment".
You look around the court and see the shattered look from the Johnsons child and answer " because the hotel owner said he could not afford them"

[kurnal]

Thank you Thomas, I know where you are coming from but it isnt going to be like that.

My argument is not agaisnt the benchmark standards, I am very familiar with them and and their presecessors, have seen fire safety develop from the disasters ands earliest days of the fire Precautions Act and Fectories Act etc evolve into their current state. At every stage I have tried to understand the back ground to the changes made in apporach over the years and wholeheartedly support improvements and criticise errors and fudged issues, as these all too soon become imposed on Responsible Persons by enforcers and building inspectors some of whom should know better.

The benchmark standard is the goal. If all premises met the benchmark standard and was given a set of rules to operate with we wouldn't need tisk assessments- we would be back to the old days of prescription. But people and buildings are diverse with different characteristics and needs and that is why risk assessment is recognised as the most efficient and cost effective way of meeting those needs in an appropriate but proportionate manner.  Our goal is to reduce the level of fire risk as low as is reasonably practical- ALARP- and what is reasonably practicable for one building will be insufficient for another building and over the top for another.

So it is unlkrly that I will be in the dock answering your question. Instead I may be explaining how I took account of the level of risk,  applied an appropriate action plan to reduce that level of risk taking all factors into account.
I will explain how that plan was produced- by recording and evaluating the Strengths and Weaknesses of the building and its management, identifying the underlying hazard and recommending ways to control them, taking any Opportunities to balance or offset Weaknesses against the Strengths if appropriate, and fully evaluating all Threats from fire.

SWOT analysis and Gap analysis are an essential element of a risk assessment if you want to move beyond the concept of a tick box checklist that any jobsworth can carry out. But whilst the methodology is implicit in  PAS79 etc, most do not do it this way and so have to make the building fit the pictures in the guide.

Now please tell me how I can recognise a 90 degree head. Cos in all honesty I cant at the moment and am keen to learn.

[jokar]

ALARP is the standard and is time trouble and inconvienience versus cost.  Proportionality is also a big player as recognised by the Government and its Enforcement Concordat.  We all know that the highest standard is the best standard but not every business can afford pressurised staircases and other engineered solutions at the top end of the market.  Detection and warning systems are also expensive as are new fire doors.  Retrofitted strips and seals are again aan expense and I am not that sure that they will provide the protection required in BS 476 part 22.

However, they all may play a part and all those involved in fire safety as enforcing officers or assessors should know the benchmarks and work towards them as far as possible.  As Val indicated in a separate thread, not all buildings can be changed to look like the guides and there nice diagrams so there has to be some degree of common sense approach for all concerned.  Again as in a previous thread action plans are a way forward on this but not if they go against a structured FRA which is proportionate to the risk of the premises.

And here I think lies a problem between FRS and there staff and competent RA's.  Some FRS staff take no account of ALARP or proportionality and have the belief that all buildings can be adapted to look like the diagrams and that is the end of it.

Many endings to the same story then.

[Thomas Brookes]

You  have to take ALARP along side all the the other HSE recomendations such as COMAH (control of major accident hazards) and AMN (All measures necessary), ususally in Uk we use SFAIRP. If anyone has got a several hours to read all these rec's most are on the HSE web site. Below is a couple of snippets which highlights some of the points made. Unfortunately these reccomendations can be mislead and I wil demonstrate what I mean in ext paragraph.

These are examples to show a point, I am not saying this is what this particular hotel is doing.
I can apriciate the cost of £6148 is a lot of money so may be is it reasonable practicalble esspecially if the hotel has just a few rooms and turns over is around £40k a year.
How ever Im not sure how many doors this hotel needs altering but I would shop round for prices including looking at buying the seals yourself and paying a chippy to price up installing them. Doing a quick search I found smoke/Fire seals for around £11 each door a good chippy can do a door an hour especially if you get him a helper to take down and re-hang the doors, so you could be looking around £40 per door. Then if you consider this is a 40 bedroom hotel charging £75 per night per room total turn over now is £1,092,000 per year. I think everyone would consider spending £6148 out of a turnover of £1m a year is not a massive drain and would be reasonable to expect it to be done, esspecially if you go along with Kurnals process of phasing it in over a few years.

This now is my opinion and I apriciate a lot on here seem to feel smoke seals are to expensive for the risk and as risk assessing is not perscriptive we will all assess slightly differently, How ever I feel compartmentation and smoke sealing is one of my highest priorites for people protecton especialy in sleeping accomadation. I still feel in a big hotel not looking at smoke seperation may leave an assessor on a sticky footing in a fire death situation.


Legal background to ALARP
The principal health and safety legislation in the uk is the Health and Safety at Work etc. Act 1974 (HSW Act). It requires risks to employees, and others, to be reduced ‘so far as is reasonably practicable’ (SFAIRP). The meaning of SFAIRP has been the subject of legal judgment in the UK courts (Edwards v National Coal Board). Risk assessments are also required by The Management of Health and Safety at Work Regulations, Reg 3.

Regulation 4 of the COMAH Regulations requires Operators to "take all measures necessary (AMN) to prevent major accidents". This is interpreted as the equivalent of reducing risks "as low as reasonably practicable" (ALARP). In terms of what they require of duty-holders, HSE considers that duties to ensure health and safety so far as is reasonably practicable ("SFAIRP") and duties to reduce risks as low as is reasonably practicable ("ALARP") call for the same set of tests to be applied.
The demonstration that AMN have been taken to reduce risks ALARP for top tier COMAH sites should form part of the Safety Report as required by regulations 7 and 8 of the COMAH Regulations. The required level of detail is specified in Schedule 4 to the Regulations.

[kurnal]

Hi Thomas
Yes I agree with most of what you say, The bottom line is that only the Judge can decide whether the duty of care has been met.

Not sure why you  refer to COMAH though? "AMN" is a specific duty under COMAH Regs  not relevent to the  Fire Safety Order which instead point to the duty to implement "general fire precautions"

[Username]

HSE thoughts on ALARP etc here: http://www.hse.gov.uk/risk/theory/alarpglance.htm

[dusty]

Gents,

I enjoy the wonderful exchange of views on this site and particularly in this area and the use of scenarios to illustrate the point, and, although I am admittedly long in the tooth and a bit of a dinosaur try this augment for size:

I will not comply with your recommendation mister fire safety officer from the local brigade to replace my heat detectors with smoke detectors in bedrooms as I fully comply with the latest BS. I quote:

BS 5839-1:2002+A2:2008

Hotels and hostels L1 or L2 In bedroom areas, the design requirements are usually based on the recommendations for a Category L3 system. Detectors are, however, typically installed inmost other rooms and areas, as a fire in almost any area of the building could pose a threat to sleeping occupants; the system Category is, therefore, at least L2. In practice, few, if any, areas are left unprotected and the system Category is effectively L1, except that a variation from the recommendations applicable to a Category L1 system may apply to the siting of heat, smoke or carbon monoxide detectors in bedrooms; this often follows the recommendations of 22.3e) for detectors in a Category L3 system.

And

Similarly, it is acceptable, in a Category L2 or L3 system within a building in which people sleep, to install heat detectors in bedrooms. The objective of these detectors is not to provide the earliest possible warning to occupants of a bedroom in which fire starts, but to warn other occupants before the integrity of the door of the bedroom is threatened by fire. Earlier warning would be given by smoke

This would appear to be the current standard and I note that the HMG guide to sleeping accommodation refers to this BS

[Davidrh]

Hi Thomas
I've got a job for you and I will gurantee twice your current salary Plus a new Merc 320E 5 weeks holiday in Rio Ist class and pension IF and only IF you can Turnover £1.092.000 per year for rooms alone at our 40 bedroom hotel, In fact I'll give your wife a Merc as well.
Trust me we would NOT be having a conversation about spending £6000 on smoke seals.
I wish !!!!!!!!!!!!!!!!!!!!!!!
and in any case its not turnover that matters its the bottom line after all the costs (that dirty word profit)

[Davo]

Davidrh

Thomas is quoting max theoretical turnover.
Say you make £5 per room per night, that is £73k per year.
Say you average 60% capacity each day
That gives you £43,800 profit
Does spending £6148 seem reasonable?
You could do it over two years as the Phil and MR suggest


davo

[CivvyFSO]

Dusty, a well made point.

BS5839 also states :

In England, Scotland and Wales, legislation requires that, where necessary
to safeguard relevant persons in case of fire, premises are equipped with
appropriate fire detection and alarms. Equivalent legislation applies in Northern
Ireland.

So since the person in the room of origin is a relevant person, how are you safeguarding them?

BS also states that the type of system should be subject to a risk assessment. That risk assessment should be looking at how all relevant persons are protected, or how they can be protected.

It is a tough call though. As you say, our very own CLG guides refer to this, and I would expect that if the rest of the fire precautions in the hotel are adequate, then the FRS would lose an appeal on these grounds.

[Davidrh]

Hi everone
I need further help here.
The Fire officers who gave me till August to put in smoke seals has now said that my existing intrumisent strips (in my lobby and hallway doors..some double) are also no good and they need smoke seals with brushes "
Is that right . Where does this all end ??

[messy]

ALARP is the standard and is time trouble and inconvienience versus cost.  Proportionality is also a big player as recognised by the Government and its Enforcement Concordat.  .

The cost & proportionality part of ALARP worries me.

Does this mean:

If I audit a Hilton or Holiday Inn and find a problem, I should not worry too much about how much it's going to cost to fix, as they are big £multi concerns that can afford the changes.

Alternatively, when dealing with the owner of the scruffy old single staircase sole trader £30-a-night Hotel (yes we do have some in London) down the road, where I find an identical problem, I have to go easy because what I might require is too financially onerous.

Surely using a risk based approach (& using Sir Toddy's argument) the punter in the flea pit is far more likely to die by fire than the 4* luxury Hotel, so surely it is that scruffy Hotel that I should put more pressure on to raise FS standards regardless of costs and not vice versa.

I personally take no prisioners when it comes to (the scruffier) single staircase Hotels, regardless of who runs them and how deep their pockets are. Am I wrong??