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NEW FIRE REGULATIONS: Residential Care Premises
(LWF issue regular monthly updates covering topics specific to the implications of the new fire safety regulations on your business operation).
The New Law and Prescriptive Guidance
The Regulatory Reform (Fire Safety) Order 2005 (FSO) is now in effect, it came into force on the 1st October 2006. The Government Department (DCLG) has issued a series of eleven guidance documents covering principal building use occupations, one of these is directed specifically at ‘residential care premises’.
Key Recommendations of the Guidance Document
The guidance document proposes a series of severe recommendations that may prove difficult for existing residential care providers to meet in full. In concept, the guidance recognises a ‘protected area’ within a building compartment as a fire separated section of a building on a specific floor. The ‘protected area’ may have several bedrooms included within it perhaps served by a common corridor. The guidance recognises the concept of progressive horizontal evacuation but requires that the ‘protected area’ be evacuated within 21/2 minutes and that this is tested by fire drills. The alternatives offered to this standard include sprinkler protection, reduction of compartment occupation, increased staffing levels to achieve evacuation time, or delayed evacuation by providing bedrooms with passive protection equivalent to 60 minutes fire resistance.
Implications to Residential Care Providers
The guidance makes assumptions regarding the level of dependency of residents within residential care premises. In our experience these are unrealistic in that the majority of residents need assistance and guidance to escape even if they are not fully dependent. The intimation is also toward moving the occupation of the most dependent residents to rooms on the ground floor level, this is not necessarily realistic as residents may have contractual use of a room, or the disruption would emotionally upset individuals and their families. The level of supervision to enable the evacuation times to be achieved is also financially unrealistic as over the 24/7 period sufficient staff would need to be available to evacuate all residents within a ‘protected area’ within the 21/2 minutes. Depending on the size of ‘protected areas’ this could require very high levels of staffing. The retrofit of sprinkler systems is equally difficult to achieve and expensive, the strategy of delayed evacuation considering 60 minutes fire resistance is feasible for new-build construction but very difficult to realise in existing buildings, particularly those that are not purpose built.
What are the Alternatives?
The guidance document allows the use of fire engineering principles to define an equivalent level of fire risk management to those recommended. LWF have developed a ‘risk managed’ alternative approach that relies on nominal physical upgrade and subject to the specific building, the development of fire safety management strategies that enable sub-protected area evacuation and subsequent main ‘protected area’ evacuation within extended times subject to fire engineering proof associated with time to hazard. The alternative approach is currently being discussed with care home licensing (CSCI) and fire authorities and is considered a practical alternative to full prescriptive compliance.