Application of the RRFSO to internal flats

[William 29]

Following recent events, we are increasingly being asked questions around the application of the fire safety order to any common facilities i.e. common vents in kitchen and bathrooms between purpose-built flats and risers etc internal to the flats, that could only be viewed by an invasive survey.

As I am sure most are aware a "Type 1" FRA is enough to satisfy the RRFSO but we recommend at least a "Type 3", where we will access a sample of the flats. I am looking for opinions as to if the RRFSO could be applied to such "common" areas as they are common to one or more flats? To my knowledge, this has not been challenged.

[nearlythere]

Following recent events, we are increasingly being asked questions around the application of the fire safety order to any common facilities i.e. common vents in kitchen and bathrooms between purpose-built flats and risers etc internal to the flats, that could only be viewed by an invasive survey.

As I am sure most are aware a "Type 1" FRA is enough to satisfy the RRFSO but we recommend at least a "Type 3", where we will access a sample of the flats. I am looking for opinions as to if the RRFSO could be applied to such "common" areas as they are common to one or more flats? To my knowledge, this has not been challenged.

Due to the rose tinted governmental glasses this shouldn't have been an issue with FRAs dealing with the management of fire safety only, as I read when this was launched. Sure all buildings are built to Building Regs anyway hahahaha.
I have surveyed a few modern blocks of flats since Grenfell and I am astonished that the quality of build and control of construction is so poor. So poor to the extent that "Stay Put" should be removed from the Fire Safety lexicon as being a pie in the sky strategy.

[William 29]

Sorry, I don't agree. The majority that we are seeing have some compartmentation issues but nothing that can't be fixed or that warrants stay put being thrown out of the window. The alternative is full evac and this throws up all sorts of different problems that I don't want to go into here. I was just interested in the interpretation of the application of the RRFSO as posted. 

[Animal]

The current benchmark guidance for purpose built blocks of flats covers this area in detail regarding kitchen/bathroom ducts.
The application of the fire safety order is for the common parts only, therefore the internal vents grills ducts within the flats and between the flats is housing act.

If you carried out a Type 3 survey, any internal recommendations for the flats would have to be made under the housing act and this would/should be clearly defined in the risk assessment as the RA is for the FSO.

Hope that is of help. Keep it simple you know it makes since.............sometimes.

[William 29]

The current benchmark guidance for purpose built blocks of flats covers this area in detail regarding kitchen/bathroom ducts.
The application of the fire safety order is for the common parts only, therefore the internal vents grills ducts within the flats and between the flats is housing act.

If you carried out a Type 3 survey, any internal recommendations for the flats would have to be made under the housing act and this would/should be clearly defined in the risk assessment as the RA is for the FSO.

Hope that is of help. Keep it simple you know it makes since.............sometimes.

I think I am in agreement. However, we are increasingly seeing this on Fire Authority "Notices of Deficiencies" under the RRO. And I am told that this could be enforced but is unlikely to be pursued, so why included in the Notice? It would be better to have a section "Areas not enforceable under the RRO" and detail these deficiencies under a Housing Act section?

[Owain]

The current benchmark guidance for purpose built blocks of flats covers this area in detail regarding kitchen/bathroom ducts.
The application of the fire safety order is for the common parts only, therefore the internal vents grills ducts within the flats and between the flats is housing act.

In my building the shared bathroom extractor ducts run in the service risers off the common stair.

[Messy]

I note the reference to type 1, 2 3 etc FRAs in this thread and a simple Google search has show the definition of each. I also note that these types have originated from our own Sir Colin of Toddshire in his residential guidance book (which I understand is a good read, but lacks sufficient photos for me to by one!)*

I also note that a number of FRA providers are offering types 1 to 4 FRAs for all FRAs, regardless of type of premises. Is this the future? If so, what are the benefits?

(*I haven't been involved in residential FRAs for 7 years, so am a bit rusty on this guidance)

[Animal]

Owain the doors to the risers on to the common parts FSO the duct work going in to the flats is housing act.

With regards to what you write in the requirements in your RAs should be FSO however if you see anything under the housing act you must make it very clear and state advice given under housing act.

As to enforcement officer putting ducts in to enforcement notices if they are enforcing it under the FSO this not correct. There is a memorandum of understanding between the enforcers of the housing act and fire authorities stating the lead authority for housing issues would be the local authority not the fire authority.

[Tom Sutton]

"domestic premises" means premises occupied as a private dwelling (including any garden, yard, garage, outhouse, or other appurtenance of such premises which is not used in common by the occupants of more than one such dwelling)

If the ventilation shaft can be defined as, other appurtenance of a premises, and is used in common, it cannot be describe as domestic premises and subject to the RR(FS)O.

[colin todd]

Ah Appurtenance, there is a word you didn't hear much on blue watch at Salford, Tam.

[Tom Sutton]

I wouldn't know the nearest I got to Salford was Newton le Willows.

[William 29]

Ah Appurtenance, there is a word you didn't hear much on blue watch at Salford, Tam.

I only served on Green and Red watches at Salford so must of missed that? However, are you able to offer any clarity on the issue Mr T?

[Dinnertime Dave]

"domestic premises" means premises occupied as a private dwelling (including any garden, yard, garage, outhouse, or other appurtenance of such premises which is not used in common by the occupants of more than one such dwelling)

If the ventilation shaft can be defined as, other appurtenance of a premises, and is used in common, it cannot be describe as domestic premises and subject to the RR(FS)O.

I'm with you Tom, if as the assessor you know of any such duct then comment on the assessment. I've recently found a gas pipe that isn't protected in one of our blocks and and enclosed it. Caused problems gaining access to 3 flats but I sleep at night.

[Animal]

Dave exactly the point I was making but the gas pipe work would be enforced under the housing act as the RA is under the FSO

[Tom Sutton]

Dave exactly the point I was making but the gas pipe work would be enforced under the housing act as the RA is under the FSO

That's my point, the bathroom extractor ducts that run in the service risers would be a appurtenance of such a flat and used in common by the occupants of more than one such dwelling, therefore would be subject to the RR(FS)O.