Manufacturer Hilti is helping draw up a new Fire Protection Plan of Work, a task given fresh urgency by recent events
In light of the horrific Grenfell Tower fire, manufacturers who have long campaigned for more stringent certification and sign-off processes in the construction industry feel an even greater imperative to drive change so that such a tragedy might never recur.
For Dr Paul Langford, head of Hilti’s Fire Protection business unit, the deregulation that over time saw fire stopping problems manifest in PFI hospitals and schools has evidently affected housing too – and it’s time to call a halt to it.
But it’s not just about reviewing Part B of the Building Regulations. ‘Product auditing and compliance is a key aspect of the current problem,’ he says. ‘It’s about testing products in their specific installations and having greater clarity on who is qualified to inspect and sign them off.’
Allocating roles and responsibilities for fire stopping from design to practical completion was the goal that drove the development of the new Fire Protection Plan of Work, a non-statutory strategic document aiming to prioritise passive fire protection across all RIBA Plan of Work stages rather than leaving it to the end of the project to resolve.
This initiative is spearheaded by Paul Bussey, technical design/CDM/fire/access lead at AHMM; Niall Rowan, chief operating officer for the Association of Specialist Fire Protection (ASFP); and ASFP member Hilti. It came about after a 2016 round table event looking at how the industry might better address fire protection by filling the gaps between regulation, guidance and reality. The view is that current industry methods are fragmented in terms of detailed design and inspection and that by looking at the Plan of Works holistically, passive fire protection is bound into the project from the outset rather than reactively imposed at the end. It aims to set a standard for best practice in the field.
For Niall Rowan there appears to be a disparity between regulatory guidance on passive fire stopping designs and sign-off and inspection processes aimed at validating them. This is due in part to the government’s general drive to deregulate. Approved Document B and BS9999 remain the core guidance and are ultimately prescriptive in their methods, but they are undermined by the less than rigorous nature of an inspection and sign-off process, leading to buildings being completed with inadequate or missing passive fire protection, usually fire stopping.
As Rowan explains, the critical issue is that with the introduction of the Regulatory Reform Fire Safety Order 2005 the statutory inspection role moved from the fire service to a ‘responsible person’ (usually the builder owner or landlord). The order requires the undertaking of a fire risk assessment, including passive measures such as fire stopping. If such an evaluation is not carried out or recommendations not followed up, this leaves the responsible person liable to prosecution. It’s a spreading net of liability too. ‘If the responsible person carries out further work and this is inadequate, then both he and those installing are liable under the order,’ Rowan says.
Of course this might be seen as shutting the stable door after the horse has bolted because if the building was built correctly in the first place there would be far fewer problems. But this is hard to achieve in an atmosphere of deregulation where installer self-certification is standard procedure and thus a minefield for those employing the less scrupulous passive fire protection operators. ‘If you want to be a gas engineer you need qualifications but if you want to install and approve fire stopping all you need is a mastic gun, a bread knife and a white van,’ Rowan warns. Such scenarios leave building occupiers exposed to danger and their owners in a precarious position legally.
The Fire Protection Plan of Work aims to remove the chaos by ensuring that passive fire protection such as fire stopping is designed, specified and installed correctly within a framework that allows for adequate design, instruction, and, crucially, sign off by all stakeholders concerned.
Rowan also makes a clear distinction between the demands of the ADB and the FSO2005, with ‘the former prescriptive in terms of design and the latter more about operations and maintenance’. This O&M aspect of the FSO2005 concentrates owners’ minds on passive fire protection over the life of the building and acknowledges that it is, over time, an evolving entity – something that Regulation 38 of the Building Regulations concedes and draws attention to. Again, liability lies with the responsible person.
For AHMM’s Paul Bussey, the Plan of Works document exemplifies a more holistic overview of passive fire protection – one dictated by sensible design strategies rather than ‘overwrought’ fire engineering principles. Linking roles and responsibilities to the Plan of Work and beyond into a building’s operating life isn’t about meeting regulation but sensible facilities risk management. ‘For us, it’s about looking at the problem from a first principles point of view, taking on board an architectural and fire engineering approach simultaneously,’ says Bussey. ‘Our view has always been to ensure the process is design led – about collaboration throughout from the whole project team rather then just last minute engineered solutions.’
Bussey, who is on the DCLG committee consulting on the next iteration of ADB (the progress of which will undoubtedly be accelerated due to the recent events), is trying to change the mindset of architects who are used to merely meeting the demands of prescriptive building regulations. He feels the CDM firestop guidelines he’s helping pull together could be a game changer. ‘What the Plan of Works project has brought to light for me is that rigorously following guidance doesn’t necessarily mean you get compliance,’ he adds. ‘What its matrix does is assign at the earliest possible stage optimum engagement times for consultants and contractors to help develop the fire strategy.’ ADB might help in ensuring practical completion, he thinks, but simple fire engineering to ensure it ‘can create the illusion of safety’ as a building evolves in its working life, entailing unmonitored changes to fire stopped penetrations – data cables for instance. The Plan of Works guidelines, by contrast, take account of this, and passive fire stopping suppliers can bring a lot to bear on the process.
Hilti has sought to invest in the development of the Plan of Works guidelines as part of a longer term business strategy pre-empting greater accountability for passive fire protection. It is aware that this is too often adopted far too late in the process. For Hilti’s Langford, there’s a lot to be learned from best practice abroad that can be translated into the UK scenario. He aligns himself more with Rowan’s desire to meet statutory guidance than with Bussey’s broader discussion of workflow but agrees that ‘fire stopping decisions need to be made much earlier in the design process’. He cites the situation in Finland, where fire stopping details have to be lodged with the local authority when a planning submission is submitted. But, he says, ‘fire stopping needs to take account of the fact that buildings change over time – that penetrations will move and be added to’.
Langford highlights the fact that both Germany and the US demand third party inspection and sign off for passive fire protection, the former only granting certification after an onerous examination process, whereas in the UK contractors installing the products can sign them off. Like Rowan, he believes that in the climate of deregulation, this is unlikely to change, which is why he feels vindicated with Hilti’s efforts to step into the breach.
‘Post Grenfell, the talk is of a more regulated environment with less reliance on self-certification and increased scrutiny of third party design documents instead of ADB. However that pans out, the need for the Plan of Works is more pressing than ever,’ he says. ‘Our Firestop Documentation Manager (CFS-DM) software allows for all stakeholders to individually audit every penetration. It is all about peace of mind, both for inspectors and, ultimately, for clients.’ Langford’s view is that 80% of fire stopping scenarios can be dealt with using 20-30 standard details whose benefits, adopted early enough in the design process, can be felt throughout the building’s operational life. The Plan of Works guidelines should help identify those key moments.
‘It’s a pattern book approach about making workflows clearer and individual responsibilities better defined throughout the design,’ he concludes. ‘We just want to support architects in their principal designer role by working with them much earlier in the process.’ In doing so, the logic runs, it should finally bring transparency, efficiency and, crucially, safety, to the specification process.