Fire Risk Assessments - Responsible for re designing buildings!?

[Suttonfire]

I am increasingly being asked about building design issues at properties at which I am undertaking fire risk assessments.

In accordance with current approved guidance I understand that a fire risk assessment should not be undertaken at the design stage, and that there is a whole process which should be adhered to in relation to the design and construction and approval of buildings before handover; following which a fire risk assessment is then undertaken.

However, I am increasingly being asked to account for perceived defects relating to the existing building design/structure, i.e. whether existing ventilation arrangements are sufficient, the performance of building materials etc. Whilst I would attempt to address clear deviations from approved designs, defects observed, and to apply reasonable recommendations in accordance with current guidance etc, my view is that it is unreasonable to expect a fire risk assessor to effectively re engineer or re design a building.

I was wondering whether others have met with similar queries etc and what your responses would be?

[Phoenix]

If the building occupiers have doubts about the existing fire safety provisions in a building then something has gone wrong somewhere.  That is not to say that this situation is unusual. 

Building occupiers have to have information passed to them by the developers under the Building Regs explaining how the fire safety provisions work, etc.  But this information is often inadequate.

In older buildings it is not uncommon for the building occupiers or managers to change and for information on the fire safety provisions to be lost in the transfer.

There are a number of ways in which the occupiers can find themselves short of fire safety information.  In such a case, who better is there to ask than the person doing the fire risk assessment?

Indeed, the fire risk assessor has to judge the building that he or she inspects against some standard and so has to know what fire safety measures should be in place.  This knowledge can either come from a fire strategy (or similar) or, if no such documentation is available, from a knowledge of what would normally be required in such a building.  Therefore, the fire risk assessor has to know what should be provided anyway, so why not share that knowledge with the client?

A fire risk assessor could, especially with a new building, assume that the building has been built to a code compliant standard and just look for faults or issues with fire safety management and use of the building.  And most of the time the fire risk assessor would get away with it.  But we all know that buildings rarely fully comply with guidance so, without some documentation such as a fire strategy justifying any deviation there might be, I would say that it is the fire risk assessor's duty to look, to an appropriate degree, at the suitability of the design and construction of the building to meet the requirements of the legislation under which the assessment is being carried out.

[Suttonfire]

I think that the key is understanding what would constitute knowing the building design to an 'appropriate degree'. I would expect that a fire risk assessor should be able to identify building features etc which should be in place by referring to approved guidance etc; however, if no information is available to verify the performance of active/engineered solutions etc it becomes difficult.

I'm certainly not advocating cutting corners, or 'getting away with it' (I am one of those assessors who actually checks lofts, risers, above false ceilings etc). However, it can't be right that Designers, Building Control etc can get away with not following the correct processes, with the blame being lumped on to the fire risk assessor if anything has not been done properly at that stage.

[Phoenix]

Yes, I'll agree with you.  What is the worst, and maybe this is what sparked your original post, is when a relatively new building is evidently sub-standard and also has no documentation to offer any mitigating considerations that might have contributed to the acceptance of what appears to be a poor design.  The causes for this reasonably common scenario are complex and diverse. 

As for the poor old fire risk assessor that comes along and finds this mess, they are often put into an awkward situation.  Sometimes they have to recommend large scale remedial works on a building that others have passed as satisfactory.  I've been there a few times and many of us probably have experience of situations where pressures are brought to bear from both sides.  Sometimes a client has bought a property in good faith, got a fire risk assessor in, in good faith, and then been faced with large bills for remedial works that they can barely afford.  It really isn't good enough.

But that's the world these days - crap - don't get me going.  What we do have to be absolutely sure of as fire risk assessors is that we are assessing the risk and not comparing the building against a construction code such as ADB.  By being careful about this, it is possible to find pragmatic and cost effective solutions.

[nearlythere]

In theory a survey of a new building should reveal no evidence of breaches of building standards and, as was said, should only be an exercise in the assessment of portable extinguisher cover and fire safety management.
However, woe betide anyone who makes this assumption and doesn't have a good look at the condition of the building especially above suspended ceilings and anywhere else a head can be poked.
Remember that building control bear no responsibility for what it does or don't do in relation to the provision of fire safety measures in a new build. But the poor old fire risk assessor, who lacks the benefit of x-ray vision, could well come a cropper for making the assumption that if it has a completion certificate it is fully compliant.
Surveyor beware.

[AnthonyB]

You can have more actions on the construction and layout of a new build than a 30 year old building. Building Control sign off has no bearing on the standard of work or actual physical compliance and if you take an extinguisher and sign survey approach rather than a full comprehensive inspection as you would an existing build you risk it coming back to bite you!

"It's been signed off" doesn't hold water as if you blindly accept that who in reality will have been found to be the most recent person to sign off the life safety if something goes wrong....you! And they convict fire risk assessors don't they? (Unlike building inspectors who get a wrist slap for 6 months in a post on an obscure web site...)

As stated you can end up in difficult situations as everyone before you has ridden off into the sunset leaving behind paperwork, but if it's wrong, it's wrong and it's your career, criminal record and the safety of occupants that are on the line.

[Dinnertime Dave]

As stated you can end up in difficult situations as everyone before you has ridden off into the sunset leaving behind paperwork, but if it's wrong, it's wrong and it's your career, criminal record and the safety of occupants that are on the line.

Leaving behind paperwork? I wish.

[Mr. P]

Copies of the project Fire Strategy document are likely not available unless you were involved in the original works. You can RA on the evidence you find but, you can also go back to the person who engaged you to explain that what you have found 'is far too risky' or you to RA, thank you very much, and, hand the cheque back. It may be harder to explain to your boss if not self employed but, that the dilemma. A 'difficult' premise may need more than one person to RA to produce a doc which will hold up for the 'owner' and you as the assessor.

[Fishy]

In my experience it's emerging that there are potentially different levels of intervention that can be undertaken when (as fire safety specialists) we're supporting our clients' compliance with fire safety legislation.  In our case, we're primarily designers or the larger and/or more complex buildings, and as such nearly every building we design is non-compliant with standards and guidance to a certain extent - we justify those non-compliances and put them in our fire safety strategies.  The fact that a building doesn't comply with guidance doesn't make it unsafe, provided that you know what the guidance was aimed at and you can justify that variation / departure.  Of course, fire safety strategies are a design deliverable that have only really been widespread in the last 20 years or so, and by no means every building that's built today has one produced (they're not mandatory).

What we're increasingly being asked to do is to go into existing buildings and write a fire safety strategy (FSS) for it in 'steady state' - basically to reverse-engineer the building and write a document that describes how it either meets current standards or why the design might be considered safe for other reasons, together with recommendations for remedial works, enhanced or extraordinary maintenance activities, more detailed investigation or modernisation works.  This basically replaces the fire safety strategy that would normally be produced round about RIBA stages 2 and 3 in a 'traditional' design process and it sits on record for the clients, occupiers and/or fire risk assessors to refer to.  In essence, what we're doing for them is retrospectively producing what they should get under Regulation 38 if the building were built now: http://www.legislation.gov.uk/uksi/2010/2214/regulation/38/made.  Sometimes this is for a building that they occupy already, other times it's when they're considering taking it over, or changing the use. 

My own personal opinion is that this isn't something that you would do as a matter of routine under a FRA, but it's a one-off piece of work that might be done if the building had a high enough risk to warrant it - if it were large, complex, accommodated vulnerable persons or high occupancy numbers or if it were significantly non-compliant with standards.