Sorry - More questions on common parts of flats

[messy]

Sorry about the length of this post, but I am still trying to make sense of how residential (common parts) FRAs fit in to the whole FSO approach and would appreciate your views:


Building Regulations

1) The Lacors guide refers to buildings constructed or converted before of after 1991 when determining which measures may be required. How would an assessor recognise/determine that such work was completed before of after 1991?

AFD

2) As the FSO only relates to the common parts, why does the Lacors & DCLG guide suggest stand alone LD3 detection within flats? OK, good advice, but surely this is unenforceable using RR(FS)O 2005?.

3) Similarly, some RPs may have difficulty installing and maintaining HD inside flats (as part of the part 6 Grade A systems for protecting common parts_. How would you approach such an issue where access into the flats is not going to be possible?

3) With regards to difficult access to flats, if a LD2 system is installed (circulation spaces only) in the common parts of a block, will sounders be required in flats to achieve the 65/75DbA level?

Protected Routes

4) Where a protected route is required, what is your view on the issue of letterboxes in doors leading onto common parts? I have received a number of enquiries from worried residents where the landlord is replacing front doors with blank/plain doors and then installing a communal pigeon hole arrangement by the front door (and in the protected route). Less risk perhaps compared with a well developed fire in a flat, but perhaps over the top?


I appreciate that every case is different and as such, any replies would have to be generic. But I am just after a flavour of your current thinking.

[messy]

Sorry, can I add one more question.

When there''s no RP, what systems do you recommend for managing the AFD system in residential buildings?

Ie who is going to search, silence, reset the system in a wholly resi block?

[colin todd]

Questions, questions, the ever-questioning youth of today. Love the sub-headings by the way. I always like sub-headings.

1. With difficulty, but can be done with enough investigation. Could even ask BC. Though it is difficult, the conversion date is a fair point.

2. Detection within flats is unenforceable under FSO, unless it is part of the L3/L2 system protecting common parts, but do not forget that Housing Act still applies within the dwellings. (In Scotland, where you really should go for your hols, Messey, the equivalent legisaltion applies to the whole of a licensed HMO, not just common parts interestingly enough.)

3. FSO can require cooperation of persons in non-FSO premises.

3. (Your second 3) Do not even go there, and do not put systems in common parts of blocks of purpose-built flats (or equivalent conversions), other than to operate AOVs.

4. Letter boxes should be low down if possible and could be protected with fire resistant type. You are right, each case is different, but may be a case sometimes, even if just long term objective.

Re supplementary question:  You can't. That is why, since Adam was a boy (or, even earlier, when Kurnal was double declutching crash gearboxes) it has not only been the party line that there is no need for systems in the common parts, but it is actually often a BAD thing to do. (As always, however, there are rare exceptions.)

[jokar]

Which is what all keep saying but for some raeson CFOA keep wanting fire alarms in common parts as well as FFE.  Can not be done as you quite rightly say, no one in a block of flats is going to take reposibilty for silencing alarms, dealing with the system or making sure FFE is available to use.

[colin todd]

While CFOA have much to answer for, they fully understand everything that has been said about this subject. It is people carrying out fire risk assessments who do not understand. CFOA are not guilty of everything in the world, though I blame them for the invasion of Iraq and global warming.

[jokar]

Then why do FRS staff whose masters are the above righteous people keep insisting on them?  I believe that from the enquiry in Manchester, we now have a situation whereby both are almost requiements for FRS staff.

[colin todd]

CFOA are not the masters of inspecting officers. Each F&RS is autonomous, though they try to get their act together through CFOA regions, without, in E&W a lot of success. Most inspecting officers understand all the points I have made. Poor old Dorset wrongly came under a lot of criticism for doing nothing more than accepting the FRA of H$S consultants that advised to get rid of FEA in common parts of blocks of flats.

[jokar]

No one is the master of IO's, not CFOA not their bosses, just themselves.  No matter what training they have had, they will still do whatever they think is correct, rightly or wrongly and bury their heads in the sand.  Everything was rosy under FPA as they could dictate, quite wrongly inlost of cases what they wanted.  Nowadays they mostly have the same attitude, do not consider hazard and risk, passive fire safety and AFD is the answer to everything and FFE is really needed to protect the escape routes.

Its no matter that AFD is to protect escape routes as if you put in it office blocks with numerous of them, lone workers will be safe!!!  Put FFE in sheltered housing and the aged population will use them every day to put out the numerous fires that occur in such premises.  As for common parts of flats with 60 minute separation, most have never heard of defend in place as an evacuation strategy and believe that all should depart.

A rant I am afarid and I apologise to those good IO's out there wherever they are.

[messy]

Then why do FRS staff whose masters are the above righteous people keep insisting on them?  .

It's because some (not all) IOs are rigidly applying the table in the DCLG sleeping risk guide or they are hugging the Lacors guide, both of which state providing AFD in residential common parts (esp pre 1991 buildings/conversions).

Paragraph 22.2 of the Lacors guide goes further and states "Virtually all residential premises where people are sleeping will require some form of automatic fire detection and warning system"

There is no definition of what is meant by the word "virtually" -ie what premises would not require AFD, and the word "premises" (not flat or room) could easily be interpreted as the whole building, including the common parts.

What a mess! With official guidance such as that, it's no surprise there's perhaps confusion and as a result, over provision of AFD in residential premises FRAs at the moment.

[JC100]

Then why do FRS staff whose masters are the above righteous people keep insisting on them?  .

It's because some (not all) IOs are rigidly applying the table in the DCLG sleeping risk guide or they are hugging the Lacors guide, both of which state providing AFD in residential common parts (esp pre 1991 buildings/conversions).

Paragraph 22.2 of the Lacors guide goes further and states "Virtually all residential premises where people are sleeping will require some form of automatic fire detection and warning system"

There is no definition of what is meant by the word "virtually" -ie what premises would not require AFD, and the word "premises" (not flat or room) could easily be interpreted as the whole building, including the common parts.

What a mess! With official guidance such as that, it's no surprise there's perhaps confusion and as a result, over provision of AFD in residential premises FRAs at the moment.

In my view, the LaCors guidance is aimed at HMO's only not at blocks of residential flats.

BS 5588-1 states

There is no statutory requirement for a common fire alarm system to be provided in a building solely
containing flats and/or maisonettes and, in buildings designed and constructed in accordance with this
code, it is generally unnecessary and undesirable for a fire alarm system to be provided.

A common fire alarm system ought to be provided only in a building in which some control can be achieved over the occupants so that a pre-determined response leading to the evacuation of the building can be triggered.
In flats and maisonettes in normal use this kind of response cannot be achieved, nor is it necessarily
desirable that evacuation should take place from areas remote from the fire, unless these areas themselves
become threatened by fire.
However, there may be circumstances in which a common fire alarm system is necessary and these include the following:
a) sheltered housing;
b) flats and/or maisonettes which form part of a mixed user development;
c) flats or maisonettes which, although not sheltered housing, are occupied predominantly by elderly
and/or handicapped persons.

Automatic fire detection may need to be installed for a number of reasons:
1) to monitor part of a building left unattended at night in which there may be a fire hazard;
2) to operate active fire protection equipment, for example closing down ventilation plant, activating
pressurization systems, opening smoke ventilators or releasing fire doors held open by retaining
mechanisms.

[kurnal]

Thats right Smokescreen- but we must not forget that BS5588 part 1 is a building design guide and needs to be adopted in its entirety. If it is- especially with regard to compartmentation, travel distances, ventilation etc - then common areas fire alarm systems are not required.

The LACORS guidance can be used to inform a fire risk assessment in existing buildings converted to flats  which may not  meet these stringent standards- particularly older conversions.

Whilst all this apparently conflicting guidance can be very confusing, it can be helpful if it is used to inform a decision rather than to prescribe a standard.  I usually end up sitting down and listing first the  strengths, and then the weaknesses of a building and then comparing these to the benchmarks and guidance documents. There is then some opportunity to offset strengths against weaknesses and come up with the right level of detection and alarm for the right reasons meeting the circumstances of the case.

[wee brian]

When there''s no RP, what systems do you recommend for managing the AFD system in residential buildings?

Ie who is going to search, silence, reset the system in a wholly resi block?

There is always an RP.

There may not be anybody on site to rest the system. That's why (as CT says) its best not to have them.

[JC100]

Thats right Smokescreen- but we must not forget that BS5588 part 1 is a building design guide and needs to be adopted in its entirety. If it is- especially with regard to compartmentation, travel distances, ventilation etc - then common areas fire alarm systems are not required.

I agree with what you're saying kurnal about compartmentation etc, however, the guide says that alarms are not required in buildings containing flats / maisonettes AND buildings designed to this code. Surely this means that blocks of flats built prior to 1991 do not require an alarm? If compartmentation issues are picked up in the FRA then an alarm would be necessary if not resolved.

[JC100]

4. Letter boxes should be low down if possible and could be protected with fire resistant type. You are right, each case is different, but may be a case sometimes, even if just long term objective.

Further to your comment, BS 8214 says that letter plates should be installed in the neutral pressure zone, between 800 - 1000mm above the threshold.
A letter plate installed towards the lower part of the doorset will be exposed to negative pressure and air will be drawn into the furnace. A letter plate in the upper part will generally be unable to prevent flames and gases egressing under positve pressure without the assistance of a second (internal) flap.

[wee brian]

Clever how the BS knows where the NPP is going to be. They must be expecting british standard fires.