Lawrence Webster Forrest
Tel: +44 (0)20 8668 8663 Fax: +44 (0)20 8668 8583
Lawrence Webster Forrest
Tel: +44 (0)20 8668 8663 Fax: +44 (0)20 8668 8583
The requirements of Regulation 38 of the Building Regulations 2010 are those formerly covered under Regulation 16b and relate to the fire safety information to be provided by the person carrying out work. This requirement has been around for a number of years however there is still confusion with regards to what is required to demonstrate compliance and often the standard of information provided varies greatly.
Regulation 38 applies to a building that is erected or extended, or has undergone a material change of use, and where the Regulatory Reform (Fire Safety) Order (RR(FS)O) applies to that building or extension. For these buildings Regulation 38 requires that fire safety information be provided to the Responsible Person, as defined under the RR(FS)O, to assist them in fulfilling their duties in respect to the fire safety for the building.
The information provided should contain details of all fire safety precautions and design assumptions to a level of accuracy which is suitable to allow the effective ongoing maintenance and operation of the building. Information should be provided no later than the date of completion or first occupation of the building and Local Authorities and Approved Inspectors should not provide completion certificates or final notices until they are reasonably satisfied that Regulation 38 has been complied with.
The exact nature and detail of the information required to comply with the requirements of Regulation 38 will depend upon the complexity and nature of the building; and a ‘case by case’ approach is recommended within the guidance. It may be that this ‘case by case’ approach has lead to the inconsistency we see today in the standard of information provided.
Why It’s Important
The way a building has been designed plays an important part in the way it is then used and the design assumptions made can often restrict the use of a building or its ability to be effectively used for a purpose it was not designed for. This is true for the structural, architectural and services design and is equally the case for fire safety. Understanding the assumptions and key components of the design can be vitally important in being able to effectively manage the ongoing fire safety in the building. This is particularly important where buildings utilise fire engineering designs based upon compensatory features and/or management requirements. A failure to understand the fire safety design for a building could result in inappropriate use of the building and increased life safety risks should a fire occur.
The fire safety information required by Regulation 38 should also inform future fire risk assessments and allows the building owners/users to identify where changes to the building arrangements may affect the fire safety precautions.
What Information Should Be Provided?
Guidance on the type of information which should be provided to comply with Regulation 38 is given in Appendix G of Approved Document B – Volume 2 (ADB). The ADB guidance is divided into two parts giving recommendations on the type of information required for ‘Simple’ and ‘Complex’ buildings.
For simple buildings the guidance recommends that only basic information is required. This information could take the form of a detailed as built plan of the building showing locations of the fire safety precautions in place, such as:
· Means of Escape & Signage
· Compartmentation & Fire Doors
· Automatic Fire Detection & Emergency Lighting
· Fire Service Provisions & Fire Fighting Equipment
· Sprinklers & Smoke Control Systems
· Hazard Areas
Any assumptions relating to the maintenance and management of the fire safety precautions should also be identified.
For complex buildings a more detailed record of fire precautions and fire strategy should be provided. This information will not only include as built drawings detailing all of the passive and active fire precautions in the building; but also information relating to any assumptions and analysis that has been conducted as part of the design. Design restrictions on the use of the building, fire safety management assumptions and procedures must be identified and understood.
BS9999 recommends that compilation of a Fire Safety Manual be started during the design stages of a project and progressed until it can be handed over to the Responsible Person on completion of the project. The intention is that this would then provide a valuable record of the design process and the decisions/compromises that have been made.
From our experiences both as Fire Engineers involved in the design of new buildings as well as Fire Risk Assessors; it is often the case that very little information is transferred to the occupier or that what is handed over is in an unordered state that is difficult to follow and is of no real value to those that would use it.
The types of documents and what they get called can vary depending on the project and what has been asked for by the Approving Authority, as a minimum we would recommend that most medium to large developments be provided with a fully developed Fire Strategy, As Built Fire Plans, a Preliminary or Pre-occupation Fire Risk Assessment as well as design documents and maintenance schedules for all fire safety systems in the building. This information then forms the basis for the Fire Safety Manual for the building.
With an ever increasing number of engineered buildings and new construction technologies being developed it becomes even more important that the requirements of Regulation 38 be complied with and that the standard of information provided to the occupiers/Responsible Person is of a high standard.
This bulletin has been written by Richard Sherwood BEng (Hons)
In LWF’s Fire Engineering blog series for Architects and others in the building design business, we have been looking at fire safety engineering. In part 26, we looked at how the choice of fire hydrant can affect the efficiency of delivery and by working out the additional time required to prime an underground hydrant when compared to a pillar hydrant with instantaneous couplings, it was established there could be as much as 2 minutes delay...
In LWFs blog series for healthcare professionals, the aim is to give information on best practice of fire safety in hospitals and other healthcare premises. In part 60 of this series, the placement of fire hydrants in relation to hospital buildings was discussed. In part 61, we will look at the effects of smoke on basement levels and the use of venting.A fire which starts in a basement or involves a basement level causes...
In LWF’s blog series for those who work in Facilities Management or who have an interest in or responsibility for fire safety, we have been looking at the part Insurers have played in property protection over the years. In part 7, we discussed the role the FOC played in producing rules and regulations not only for building standards but also for fire protection products. In part 8, we will continue looking at the impact of...
In LWF’s fire engineering blog series for Architects and other interested parties in the building design business, we have been looking at firefighting. In part 25, we looked at how hydrants should be located in relation to the building perimeter and the likely position of a Fire Service pump upon attending a fire at the premises. In part 26, we continue looking at location and also the type of hydrant provided in relation to the...
In LWFs blog series for healthcare professionals, the aim is to give information on best practice of fire safety in hospitals and other healthcare premises. In part 59 of this series, LWF discussed the requirements for healthcare buildings with a hospital street and which do not require a fire-fighting shaft. In part 60, we will look at the provision of fire mains.Fire mains must be provided in every firefighting shaft, or in some instances,...
The Wohl Neuroscience Institute - Fire Safety, Strategy & Engineering
Key Facts: Client: King’s Clinical Neuroscience Institute Project Manager: MACE Ltd Designers: Devereux Architects/Allies and Morrison Approximate Size: 7,400m2 Description of the Project:...
Fire - The External Risk
When we consider fire safety, our focus is normally from within, what can we do to prevent the occurrence of fire and how we can limit its damage.Â Whilst this is the correct stance to take, we m...
Evacuation Modelling - Factor in Human Behaviour
Evacuation of buildings can be analyzed in different ways. Approved Document B (ADB) which provides guidance on meeting the requirements of the England and Wales Building Regulations with regard to fi...