BS 9999 -Fire Safety Manual - Regulation 16B

[hammer1]

Also to add to this is, and something some of you might be more familiar with is Article 45 of the fire safety order and that the local authority duty to go pass and consult the enforcing authority any fire plans of new builds, major alterations prior to accepting such plans.


So that's where the problem lies.


On that note I will leave the subject for all to ponder on.

Have a nice weekend.

[wee brian]

Art 45 transposes a requirement that started life in the 1971 Fire Precautions Acts - not exactly news.

Davo says "The problem is how Reg 16B appeared, snook in on an innocuous SI". It was hardly sneeaked under the wire. It was part of the Review of the Building Regs. If you missed that then you must have been on the moon.

[CivvyFSO]

As Wee Brian points out, the duty to consult has been around since Mr Holroyd stuck his oar in.

[hammer1]

Ah yes indeed so.

The reason for highlighting Art 45 is;

So is it the enforcing authorities missing the boat, hence the problem lies there. Local authorities are consulting the enforcers who seem to forget Reg16B and other guides, hence the lack of it and lack of interpretation from Building control.

Did someone say 'competent'?? not me squire..............

[Davo]

Gents

'The Buildings and Approved Inspectors (Amendment) (Number 2) Regulations 2006' hardly gives a clue as to the importance of the contents IMHO

davo

[CivvyFSO]

But the supporting guidance does specifically mention it on the very first page.

[Davo]

Civvy

Yes, six half-lines which in the on-line version has 'on-line version' right across it.
Also there is no mention in that intro of Appendix G, nor the comprehensiveness of the requirement.
You have to read all the contents list or the whole document to know of G's existence


davo

[wee brian]

Perhaps future SIs should have titles including such prases as "DAVO should read this".

Fancy having to read the contents page to see what in a document.... outrageous

[kurnal]

I think a lot of the problems with Reg 16B is that fire brigades dont have the time ask questiions and insist on seeing a copy when they are consulted by the BCO. They dont even have time to take a good look at most of the plans in my opinion (compared to the old days of course). It was always a bit of a rubber stamping job without adequate time allocated under the old OMPIS and its much worse now with the depletion of dedicated teams.

Because brigades dont make a fuss neither does the BCO and especially the approved inspectors. After all the statutory bars gone so does it matter if its missed- if the risk assessment isnt right on audit then enforcement action can be taken. So they get a consultation they dont really want to have to carry out and dont see a huge benefit in it because its someone else's legislation. They have no legal duty to respond to the consultation and it makes no difference to their own enforcement duties if they dont.

Same with the Fire Safety Order and the CDM regs. What a cock up. CDM and Fire Safety Order partly duplicate each other but CDM has a totally different emphasis on who is being protected. It only considers persons on the site. The persons responsible for the CDM Regs compliance is defined- and it isnt the same people as the Responsible Person under the Fire Safety order.  Unless the site has other occupiers the  fire related provisions of the CDM are enforced by the HSE and they dont want to know and aren't used to the Fire Safety Order. On multi Occ sites the Fire Authority enforce and quite rightly they would much rather enforce the FSO , dont want to know anything about the fire provisions in the CDM Regs.

Outcome is that most of the time nobody thinks or cares about Reg 16b. At plan stage the fire authority arent interested because the FSO applies to places not plans.

[hammer1]

All fair comments.

But if BS 9999 is the new bible, how come consultants are not taking up the baton about producing the fire safety manual at design stage then??.

[AnthonyB]

Because often we are brought in when it's too late - a site gets a new build or a virtual re-build and they complete the works, then suddenly remember "we need an FRA too".

We turn up & ask for the fire safety manual to blank looks. The contractors are long gone and we then have to pour through the entire O&M, M&E and H&S Files to try and locate the seemingly randomly placed snippets (& often a snippet is all the depth of info you get) of fire related info.

[kurnal]

And very often just a photocopy of the entire sales catalogues of the equipment suppliers, sometimes  not even identifying which equipment is actually fitted. And a Cause and effect matrix? "You are joking. Thats commercial confidential that is."  Wheres the backup for the config? "We keep that in our service kit"

A lot of the problems are exacerbated with design and build  projects in which the end user  has no commercial relationship with the various contractors. Thats when the problems as expressed by Davo tend to arise.

Further example is a design and build project for a new sprinklered care home in which the sprinkler system installed by an LPCB approved company does not meet BS9251  - roofspaces and stores not covered due to provision of L1 fire alarm system!!!! Goodness knows where that idea came from. Then I look at the BS5839 commissioning certificate " L1 but roof spaces and stores not covered due to provision of sprinkler system". Principal contractor not interested, approved inspector wont visit site or give an opinion, has issued completion certificate, fire service ho hum dont know what we can do its not our proble. Poor old client has to dig further into his pockets  to fix it and then even further if he is to receive any redress inthe civil courts. But what can he claim? He can only claim the damages- not the cost of putting it right. 

[mw]

But if BS 9999 is the new bible, how come consultants are not taking up the baton about producing the fire safety manual at design stage then??.

At least one AI now uses Regulation 16B as a marketing tool to generate work for its fire safety engineering subsidiary (plan checkers are encouraged to ask for fire safety information in their plan check letter on appropraitely sized schemes). I am sure that as more and more design teams are made aware of their obligations by helpful consultants or AIs with in house fire engineers to support we will see an increase in activity.

[rn976]

dear all

Bit confused about some comments re what appear to be engineeered soultions in new builds by approved inspectors
I am reading the building act right when in 8(1) & (2) it says that the only people who can go outside the ADB is the local authority.



confused in a big world 

[CivvyFSO]

No.

It means that the local authority can relax or remove the requirements (B1 to B5 in our case) of the regulations if they feel it is appropriate. It is not in reference to people using or varying from ADB.

AI's and LA's can vary from ADB as much as they want, but the functional part of the regulations must always be met. i.e. You have to supply a good means of escape. However, if for any reason it would be completely unreasonable, or uneccessary then they can relax or remove the actual requirement.