THE LOCAL GOVERNMENT GROUP GUIDE: FIRE SAFETY IN PURPOSE-BUILT BLOCKS OF FLATS

Transcription

1 DERBY HOMES BOARD 24 NOVEMBER 2011 ITEM C5 THE LOCAL GOVERNMENT GROUP GUIDE: FIRE SAFETY IN PURPOSE-BUILT BLOCKS OF FLATS Report of the Chief Executive 1. SUMMARY This report provides a brief overview of the recently published Local Government Group guide Fire Safety in Purpose Built Blocks of Flats. 2. RECOMMENDATION To note the report. 3. MATTER FOR CONSIDERATION The Regulatory Reform (Fire Safety) Order 2005 (the FSO) came into force in October It brought the common parts of blocks of flats within the scope of mainstream fire safety legislation for the first time. There has been a range of problems in applying the requirements to flats with widely different interpretations of the requirements within the enforcing authority itself as well as fire risk assessors and landlords. The guide has been produced to provide clearer official guidance on the requirements for flats. The guide is overwhelmingly positive and supports Derby Homes current approach to the management of fire and our maintenance strategy for buildings and equipment. It fully supports Derby Homes policy of clear sterile areas for blocks of flats. However, there are four most significant issues identified which are: Ventilation ducts in flats Blocks of flats with communal ventilation ducts require investigation and assessment and may need to be fitted with additional protection. This type of system is limited to the flats at St Clare s Close, St Swithins Close, St David s Close and Rivermead House. The regular inspection of fire doors Including individual flat entrance doors Fire doors including individual flat front doors that open onto corridors and communal areas should be inspected to ensure they are in satisfactory condition every 6 months and records of the inspection maintained. It is not reasonably practicable to regularly inspect the internal condition of flat doors due to access issues. It is therefore proposed to adopt a reasonably practicable approach and carry out an external inspection of all doors during six monthly maintenance inspections. This will be supported by an enhanced level of inspection on a vacancy to ensure the door meets the appropriate standard when handed over to the tenant. Version: 10.0 Item C5 The LGG Guide Fire Safety in Purpose Built Blocks of Flats.docx Modified: November 16, 2011 Page 1 of 2

2 The review of Fire Risk Assessments The guide gives guidance on the review periods for fire risk assessments and distinguishes between reviewing an existing assessment and carrying out a new assessment. It states that a new assessment should be carried out every 4 years. The assessments for Derby Homes stock were predominantly carried out in 2006 and therefore, a programme of reassessment is required. The provision of fire detection in sheltered scheme flats Following a recent statutory inspection of Rebecca House and reiterated in the guidance, a potentially significant issue with the alarm systems in sheltered schemes has been identified. These premises require an enhanced level of fire detection with the detection in individual flats linked to a monitored alarm system. This is currently achieved with the smoke/fire detection in individual flats liked to the Horizon supported living call units and monitored by Carelink. Where a resident refuses the supported living service and declines a Horizon unit, the alarm is no longer monitored. A substantial change to the fire alarm systems in these premises may be required to accommodate this. This issue affects Rebecca House, Kestral House and Whitecross House. A more detailed summary of the implications for Derby Homes is provided in the attached document. The full 198 page guide can be accessed at 4. HEALTH & SAFETY IMPLICATIONS It is a legal responsibility of the Board to ensure effective health and safety management is maintained within the Company. This report provides the relevant information to enable the Board Members to monitor this. The areas listed below have no implications directly arising from this report: Consultation Financial and Business Plan Legal and Confidentiality Council Personnel Environmental Equalities Impact Assessment Risk Policy Review If Board members or others would like to discuss this report ahead of the meeting please contact the author, or Phil Davies, Chief Executive, phil.davies@derbyhomes.org Phone: Author: Stuart Hufton, Senior Health and Safety Advisor, Telephone , stuart.hufton@derbyhomes.org. Background Information: Supporting Information: None None Version: 10.0 Item C5 The LGG Guide Fire Safety in Purpose Built Blocks of Flats.docx Modified: November 16, 2011 Page 2 of 2

3 THE IMPLICATIONS TO DERBY HOMES OF THE LGG GUIDE: FIRE SAFETY IN PURPOSE-BUILT BLOCKS OF FLATS ISSUED IN AUGUST 2011 INTRODUCTION This paper provides a brief overview of the Local Government Group guide Fire Safety in Purpose Built Blocks of Flats published in August 2011 and the implications of the guide to Derby Homes. It attempts to highlight the salient points, referring to the guide when appropriate. SUMMARY The document is a guide to ensuring adequate fire safety in purpose-built blocks of flats, regardless of age. Practical advice is offered on how to assess the risk from fire and how to manage fire safety in such buildings. This guide does not introduce new standards or regulations, but builds on existing good practice and guidance currently in place. In particular, it will help landlords, managing agents, enforcing officers and those undertaking fire risk assessments to understand the legislative requirements relating to blocks of flats and to apply them in a consistent and reasonable manner. Although comprehensive at 192 pages, the guide is clear and well laid out. Rather than reiterate all the applicable advice here, the original document should be consulted for those who need detailed guidance on specific issues For Derby Homes, the guide is overwhelmingly positive and supports our current approach to the management of fire and our maintenance strategy for buildings and equipment. It fully supports our use of stay put policies and our adoption of sterile areas for the common parts of flats. KEY ACTIONS Detailed below are the areas identified that impact directly on Derby Homes. However four of those are considered significant and need addressing as a priority. They are: The assessment of ventilation ducts in flats The regular inspection of fire doors Including individual flat entrance doors The review of Fire Risk Assessments The provision of fire detection in sheltered scheme flats REPORT DETAILS Ventilation Ducts In Flats The guide highlights the potential risk of shared ventilation ducts contributing to the spread of smoke and hot gasses throughout the building and states that systems Page 1 of 6

4 without shunt ducts, dampers or intumescent grills not acceptable. This may apply to some of our properties including Rivermead House and the St Claries/St Switthens blocks. However, there are blocks of flats that do not incorporate shunt ducts and have no adequate means of preventing fire and smoke-spread between flats via ventilation ducts. The absence of measures to prevent fire and smoke-spread via common ventilation systems is so far removed from what is acceptable today that action will be necessary to reduce the risk it poses. In existing flats, it will rarely be practicable to upgrade ventilation systems to meet current benchmark standards and retrospectively introduce mechanical fire and smoke dampers into the ducts. However, one way of reducing the potential for firespread between flats would be to fit intumescent fire dampers to the vents into the ducts. Although this would not restrict the spread of smoke in the early stages of a fire, it would prevent spread of flames and hot gases. This is a reasonable approach for bathrooms, but is less satisfactory for kitchens, where there is the potential for a serious fire in the room in which the vent is located. In these cases, the ideal solution would be to rearrange the ventilation to discharge directly to outside and not via a common duct. Again, the difficulties of access to retrofit intumescent fire dampers in an occupied block of flats, particularly where these are leasehold flats, need to be considered. (page 74) Fire Doors Including Individual Flat Entrance Doors The guide fully supports the policy of not upgrading doors for the sake of it if they met the appropriate standards at the time they were installed and are still in good condition and fully serviceable. However, it recommends that fire doors be inspected every 6 months. In practice, this means that all flat common areas need to be inspected every 6 months by a technically competent person (surveyor) and detailed records kept. It is clearly not practical to inspect the tenant s side of flat front doors so a visual inspection of the front for signs of obvious damage should be sufficient. However, this should be supported by a full recorded inspection of door during a vacancy. Fire Risk Assessments The guide gives guidance on the frequency of review for fire risk assessments. It suggests that every two years is generally sufficient to review an assessment but suggests a new assessment be carried out at least every four years. The majority of fire risk assessments for Derby Homes properties were carried out in 2006/7 and therefore, should now be renewed. As a general guide, for a low risk, modern, low-rise block (eg a block of no more than three storeys above ground, built within the last 20 years), a review every two years might be sufficient, with a new fire risk assessment completed every four years. For blocks with higher risk arising from social factors, the age of the building, and so forth and blocks over four storeys in height, an annual review might be more appropriate, with a new fire risk assessment every three years. In extreme cases, for the highest risk premises, an annual fire risk assessment might be appropriate. (page 49) Page 2 of 6

5 Sheltered Scheme Alarms The fire detection in all individual flats of corridored sheltered schemes must be connected to the central monitoring point (in the case of Derby Homes, Carelink). This issue has also been highlighted during a recent statutory fire audit. Originally, the schemes had hard wired warden call and alarm systems linked directly to the warden s flat. In recent years, these have been replaced with equipment that connects via a phone line to Carelink. The current policy of allowing residents to opt out of the supported living service and not have call equipment installed has had the unintended consequence of removing the fire monitoring in those flats. The provision of an adequate system of fire detection within premises must be addressed urgently. In sheltered housing, fire alarm signals from individual flats should be relayed to the same location as alarm signals from any social alarm system. If there is an on-site scheme manager, fire alarm signals should be investigated by the scheme manager eg using a two-way speech communication facility between the scheme manager s facility and the dwelling prior to summoning of the fire and rescue service. If no on-site scheme manager is present, and fire alarm signals are transmitted to an alarm receiving centre that has a direct two-way speech facility for communication with the flat, the alarm receiving centre should endeavour to determine, by using of this facility, whether the alarm signal is a false alarm, before the fire and rescue service is summoned. Where fire alarm signals are transmitted to an alarm receiving centre by the same equipment as social alarm signals, the two types of signal should be separately identifiable at the alarm receiving centre. It should be ensured that the receipt of fire alarm signals cannot be delayed significantly by a previously initiated social alarm signal. If smoke (and heat) detectors are connected to an existing social alarm system that has no facilities for discrimination between different types of alarm signal, the recommendation for distinguishable signals need not be followed in the case of signals transmitted to an on-site scheme manager. This is provided that the pre-planned response by the scheme manager to signals from the fire alarm system in any flat is identical to the pre-planned response to other alarm signals and is an appropriate action in the event of fire. (page 157) Stay Put Policy The guide fully supports stay put policies in both general needs blocks and sheltered schemes Most blocks of flats are designed on the stay put principle. Although this relies on there being effective compartmentation, it is a principle that should be adopted wherever possible. (page 22) The limitations of the residents of sheltered housing schemes should be taken into account when determining suitable fire safety measures. However, the principles of a stay put policy apply equally to such schemes. (page 67) Page 3 of 6

6 Fire Resistance and Compartmentation The guide dispels the suggestion that a structural survey is required to establish fire comparmentation in most buildings before stay put can be implemented. Some enforcing authorities and fire risk assessors have been adopting a precautionary approach whereby, unless it can be proven that the standard of construction is adequate for stay put, the assumption should be that it is not. This is considered unduly pessimistic. Indeed, such an approach is not justified by experience or statistical evidence from fires in blocks of flats. (page 28) Fire Alarms In Communal Parts of General Needs Flats The guide recommends against fire alarms in common areas and states that: In general needs blocks designed to support a stay put policy, it is unnecessary and undesirable for a fire alarm system to be provided. (page 29) Meeting Current Standards The guide recognises the limitations in being able to upgrade existing buildings. It is wholly inappropriate to impose the current guidance for new blocks of flats retrospectively to existing buildings. Nevertheless, current guidance can be considered when setting benchmarks against which to assess the adequacy of fire protection within existing blocks of flats. It will often need to be accepted that it is neither realistic to meet current benchmark standards, nor risk proportionate to impose many of the solutions available today to the situations found in the designs of existing buildings. (page 31) Building Work In Flats The guide suggests that Building Control should be the abettors of the implications of structural work with regards to fire. Any structural modifications undertaken by Derby Homes must go through Building Control. Even if the block satisfied earlier legislation, proposed alterations must be considered in the light of the current Building Regulations; it is not sufficient to carry out alterations on the basis of the earlier legislation. (page 34) Tenants Carrying Out Work In Flats Residents carrying out even minor work in flats may impact on the fire protection of the overall building. In light of this, the new repairs handbook issued at signup has been reviewed to reflect this. Even small alterations such as making holes in walls for cables and pipes or fitting an extractor fan can have a serious effect. Staff who deal with permit applications from tenants need to be especially aware of the importance of any proposed work in flats. Page 4 of 6

7 Responsible Person The naming of a Responsible Person, who that should be and their level within an organisation has been a bone of contention since the Regulatory Reform (Fire Safety) Order came into force. The guide clarifies this. In our case it is acceptable for the responsible Person to be Derby Homes. The FSO imposes requirements and duties on the responsible person. In the case of a block of flats, the responsible person is the person having control of the premises. However, if any part of the block is a workplace, the responsible person in that workplace is the person who employs people to work there. Commonly, the responsible person is, therefore, not a named individual, but a company or organisation. (page 37) Sterile Areas The guide discusses the relative merits of managed use against sterile areas for common areas and supports the adoption of sterile areas in the type of properties managed by Derby Homes. A zero tolerance policy should: be adopted by way of default always apply when there is doubt over the ability of residents to apply a managed use policy be adopted where flats open directly onto stairways unless managed use is considered acceptable by the fire risk assessment (page 59) Flat Front Doors The issues relating to the standards of flat front doors and letterboxes are discussed at length in Part F: Managing fire risk fire protection. However, the guide supports the retention of existing doors that are in good condition and met the appropriate standards at the time. Original flat entrance doors may lack intumescent strips and cold smoke seals and will not have protected letterboxes. There would have been reliance on 25mm door stops to achieve smoke control. Where older doors were self-closing, this was sometimes achieved by using rising butt hinges. Upgrading existing doors simply because they are not fitted with intumescent strips or smoke seals, or fail to meet some other requirement of current standards, should not be made a generic recommendation applicable to all existing blocks of flats. Similarly, upgrading existing letterboxes in flat entrance doors to meet current standards is not always necessary. This will depend on: the location of the letterbox in the door the location of the flat within the block the construction of the letterbox (page 98) Page 5 of 6

8 Evacuation Plans For tenants of flats, we need to give them a copy of the fire procedures for the building at sign-up. However, the procedures do not need to be over complicated and in most cases, a simple fire action sign is sufficient. It is a requirement of the FSO that there should be a suitable emergency plan for the premises. Rarely, in purpose-built blocks of flats, will it be necessary to have a more elaborate emergency plan than a simple fire action notice (see Appendix 5 for examples). Nor will it be universally necessary to display such notices. Indeed, it is more common not to display notices, but to convey this information to tenants in other ways (eg through residents handbooks and so forth). (page 118) Premises Information Boxes The use of Premises Information Boxes that are accessible to the Fire Service and contain pertinent information about residents and the building should be considered for the sheltered schemes. However, the guide discounts their use for most general needs blocks. Even in sheltered housing schemes, there will be reliance ultimately on rescue by the fire and rescue service in the event that residents cannot escape by themselves. However, in sheltered housing schemes, it is commonplace to hold information relating to any resident with particular mobility or other issues affecting their ability to escape. This can be made available to the fire and rescue service on arrival at the premises (eg by keeping it in a premises information box, which can only be unlocked by the fire and rescue service, at the main entrance). Details of any residents using oxygen or other medical gases are also usually kept with this information. It is not realistic to expect such an approach to be adopted where there are disabled people and others requiring assistance in a general needs block. Any attempts to keep information of this kind must be updated regularly as inaccurate information could potentially be more harmful than no information. (page 120) Page 6 of 6