Fire risk assessment
The future of fire risk assessment and management post Hackitt
Competency was a recurrent theme as FPA Principal Consultant, Howard Passey, explored the implications for fire risk assessors (FRAs) of the Independent Review of Building Regulations and Fire Safety at FIREX 2019, as reported by Adam Bannister, Editor of IFSEC Global.
Speaking in the Expertise & Guidance Theatre on the third and final day, Passey said a “new world order” was being ushered in two years on from the worst residential fire in living memory.
The growing emphasis on competence was something “we all have to get used to, especially in high risk premises”, where you simply won’t get the job unless you can validate your credentials. If you’re not already working towards demonstrating competence, he told risk assessors in the audience, it’s time to start.
Passey, a former engineer and site manager in the construction industry, told attendees that the CDM (construction design, management) Regulations had rightly been cited by Hackitt as a positive that was worth building on.
Dutyholders and Higher Risk Residential Buildings (HRRBs)
The ‘responsible person’, the person ultimately responsible for fire safety in a building, will be replaced by a duty holder. Whereas the identity of the responsible person is often unclear, it could be an individual, a board of directors, or even a corporation, duty holders will be qualified by accredited industry bodies and listed on a public register.
Passey was in doubt about the need for greater transparency here. He recalled numerous occasions where recommendations he’d made in a fire risk assessment had still not been acted on 12 months later.
A call for evidence in respect to the Regulatory Reform (Fire Safety) Order 2005, which “might need a judicial review” according to fire safety lawyer Warren Spencer, has since closed, at the end of July.
In Building a Safer Future Dame Judith Hackitt wrote, “the dutyholder for a HRRB should proactively demonstrate to the JCA through a safety case at regular intervals (as determined by level of risk) that they are discharging their responsibilities. The safety case must identify the hazards and risks, describe how risks are controlled, and describe the safety management system in place.”
He added, “the dutyholder should ensure that any recommendations/requirements outlined in the fire risk assessment are undertaken and completed in a timely manner. Fire risk assessments should be reviewed at least annually until a first safety case review has been completed, where this applies.”
Evaluating a site’s risk level is not necessarily always just about the type of building, said Passey, it’s about the users too. Fire stats prove that vulnerable people are at greater risk, he said, therefore fire risk assessors need to have significant experience and credentials.
The Hackitt Review identified a dearth of skills, knowledge and experience deployed throughout the lifecycle of higher-risk residential buildings. In response, a ‘Steering Group on Competencies for Building a Safer Future’, a sub-group of the Industry Response Group (IRG), will create a body with oversight of competence requirements.
The group will be subdivided into engineers, installers, fire engineers, designers, architects, project managers, site supervisors, building control, fire safety enforcement officers and building safety managers.
Google ‘fire risk assessors’, said Passey, and you’ll generate an enormous volume of results. Unfortunately, however, standards vary widely. Any assessor whose training extends to two hours of e-learning, a “nonsense”, frankly “frightening”, will likely sit at the inferior end of the spectrum.
One of more than 100 training providers in this discipline, the FPA had trained around 1,000 FRAs in the last 12 months, said Passey.
He listed the FRA registers and the number of companies on each (as of that time, Mid June 2019):
- IFE: 241
- IFSM: 55
- FRACS (Warringtonfire) 48 individuals, four companies
- BAFE SP205 – 78 companies
Three tiers of competence
Much of the FRA role’s complexity, said Passey, lies in balancing multiple variables. For instance, they might compensate for ageing fire systems by recommending more staff such as fire wardens.
Hackitt said FRAs must be free do make these judgements, but this was contingent on a high level of competence: “An outcomes-based framework requires people who are part of the system to be competent,” she wrote, “to think for themselves rather than blindly following guidance, and to understand their responsibilities to deliver and maintain safety and integrity throughout the life cycle of a building.”
Competency steering groups were focused on providing a clear path to competence through training and on-the-job experience. However, the notion, raised in some quarters, that all assessors should have a comparable skillset to a chartered engineer was “nonsense” and not a goal of the steering groups.
Rather, the aim is to create tiers of competence and assigning appropriately qualified FRAs depending on building type. BAFE has set the template here in terms of developing a certification scheme for assessors.
Three grades are proposed:
- Trainees: for simple premises only
- General practitioner: intermediate complexity
- High-risk: premises like hospitals, care homes, high risk residential
The government is rightly focusing on care homes and residential buildings, noted Passey, but what about construction and manufacturing? These sectors “seem to be ignored”, he said, albeit Hackitt was considering situations on a case by case basis.
He also recommended that FRAs become an OSHCR (Occupational Safety and Health Consultants Register) consultant, the requirements of which are set out here.
Competency is a journey not a destination
Achieving competency is not akin to gaining a driving licence, which (criminal penalties notwithstanding) you then have for life. Competency can be lost if practitioners fail to keep track of changing regulations, standards and best practice.
He urged delegates to maintain competence through CPD and ongoing training as well as on-the-job experience.
Passey recommended using the FPA’s CPD scheme. He mentioned the FPAs hot work passport scheme, completion of which, said Passey, was demanded from contractors by Tesco.
However, in terms of achieving the optimum CPD mix, FRAs should use their judgment as to what works best for them.
The new building safety regime for multi-tenant properties that are at least 18 metres and six storeys high will involve a new building safety regulator.
The government says the system is designed to evolve and expand to cover more buildings over time. The regulator’s remit could therefore soon take in places where people sleep, said Passey: prisons, hospitals, sheltered housing and so on.
Passey also noted the growing amount and range of combustible materials being used in the built environment. Timber buildings, for instance, often contain more plastic than timber, rendering timber-based fire resistance tests unrepresentative of real world conditions.
The use of PV (solar) panels on roofs and ground-source heating instead of traditional boilers also had implication for fire protection.
Many organisations are unaware, said Passey, that the DSEAR 2015 amendments reclassified substances that are corrosive to metals and gases under pressure as flammable liquids. This meant diesel was now classed as a flammable liquid.
The future of fire safety and protection is thus highly complex, said Passey. In light of these and other challenges, he recapped the FPA’s principal recommendations for improving fire safety:
- Requirement for more than one staircase on buildings above 18 metres
- Making sprinklers mandatory above 18 metres
- Statutory defence in law for designers and building owners for third-party certification
- Widespread installation of multi-sensor AFD sensors
Passey also suggested the resilience of businesses after fires was often neglected. What is an organisation’s risk appetite? Variables such as material selection, compartmentation, fire resistance design, construction methods and use of suppression can make a critical difference to business continuity and the scale of damages resulting from fires.
If his FPA colleague O’Neill had sounded a frustrated note about progress post-Grenfell at FIREX, Passey more optimistically said that “cultures are changing already and momentum building”. One housing association in particular had done a phenomenal amount of work in upgrading its housing stock at considerable cost.
This article was originally published on IFSEC Global.