Property Protection Vs. Life Safety. It has long been UK Government policy to ensure that fire legislation focuses only on matters relating to the safety of the building occupants of these nearby. In a 1994 review of fire legislation there is a definitive statement to this effect “…the law is there to protect life; property protection is a matter for the individual…” Loss Prevention Consultant Stewart Kidd questions the current situation.
Many groups, including the Fire Protection Association, the Loss Prevention Council and the insurers, then and subsequently have questioned the appropriateness, reality and accuracy of this statement which seems to be one of those ‘universal truths’ which have been accepted without question for many years.
What has happened since then in the UK?
The introduction of the Fire Safety Order in 2006 moved the burden of regulatory compliance to employers from the fire and rescue service. Claimed cost savings were supposed to be directed towards fire prevention and fire safety education This was thwarted by the 2008 which imposed massive cuts on fire service funding and manpower.
There are some who would say that the present poor standards of fire safety in buildings in England and Wales is due, at least in part, to the side-lining of the fire service and their expertise.
To summarise: The Government introduced new legislation to reduce the burdens of managing fire safety in industry and commerce from the public sector by transferring it to employers, grossly underestimating the cost impacts on that sector. At the same time, there were significant cuts in the resources which were available to the fire and rescue service. The private sector responded by contracting out its obligations to a burgeoning consultancy sector. Government did nothing to deal with the ongoing significant impacts of fires on industry and commerce remaining consistently to the view that this is a matter for property owners and insurers and taking comfort from the relatively small number of fire deaths in buildings other than dwellings.
How buildings are procured
A significant factor in respect of difficulties in taking responsibility for property protection which is invariably disregarded by Government is the way modern industrial buildings are procured. Many (perhaps most) warehouses and factory units are speculatively built by property and investment companies. When a project breaks ground, it is probable that the eventual occupier is not known – perhaps even the end use will not be clear as there is little distinction today between large single storey buildings used as factories as compared to storage occupancies. Indeed, during a building’s lifespan, it may change uses several times. Equally, the historical concept of a ‘storage building’ as a relatively benign location where there is a low level of hazard, is very different from today’s massive ‘fulfilment centres’ which are filled with conveyors, flying bridges and robots.
The need for and design of fire suppression will not only be dictated by the end use of the building but such minutiae as the type of shelving to be installed. It would be therefore impossible for a compliant sprinkler system to be installed in a speculative building – almost inevitably, the system would have to be modified when the tenant occupies the building.
Sadly, installing fire suppression systems during construction is much more cost effective than adding it to an existing building.
Abolition of local building acts
In 2012, the new Coalition government decided to fulfil one of its stated objectives, of reducing regulatory burdens, by repealing all local building acts which until that time had provided fire authorities with additional powers in respect of the fire protection of large buildings. Arguing that most implementations of the acts (which existed in 23 areas) was related to the provision of sprinklers and smoke ventilation in car parks, large warehouses and tall buildings, the Department of Communities and Local Government relied on a 2005 report from the BRE which showed that ‘Local Acts have no statistically significant impact as far as life safety aspects are concerned’.
Sadly, other conclusions in that report appear largely to have been ignored. ‘For warehouses and car parks, Local Acts are beneficial in reducing property losses’. It is equally sad that the BRE report (but not the decision to abolish local acts) predates the November 2007 fire at a large vegetable packing and storage facility in Warwickshire which costs the lives of four firefighters.
Ministers who read beyond the Conclusions would have been pleasantly surprised to read of the significant value of sprinkler protection in warehouses:
The results for warehouses can be summarised as follows:
- The risks are significantly lower with sprinklers present
- The risks (especially property and business) increase with warehouse area
- Compartment height has little influence on the risk
- For areas up to 20,000m2, the life risk with sprinklers is less than that for an area of 1000m2 without sprinklers
- For areas of 40,000m2, the life risk with sprinklers is less than that for an area of 7000m2 without sprinklers
One related issue is the huge disparity in the permitted sizes of unsprinklered warehouses.
When this is compared with other European countries, significant questions are raised, not least about the dangers which firefighters face when dealing with fires in large warehouse.
Modern methods of construction
In an attempt to speed up construction, cut costs and improve quality, there is significant interest in using what are sometimes called ‘modern methods of construction’.
One of the inevitable consequences of this approach is that the elements of construction tend to be lightweight and modular, to allow transport and lifting. There also tends to be a perspective which asks, ‘how little do we need to install to comply with the Building Regulations’? So rather than constructing fire barriers from breeze block, we find increasing use of lightweight board – or even ‘fire rated sheeting’ used as a substitute for cavity barriers. Perhaps the most significant switch in construction methods is the wider use of timber framing. While there have been a number of spectacular construction site fires in buildings of this type, it’s in the finished building that the greatest risk lies for to provide adequate fire separation, all the elements of structure have to remain intact for the life of the building. The omission of a sealing strip, an intumescent pillow or an improperly gypsum board can all lead to the rapid spread of fire and loss of the building.
Recent destructive property fires
The Summer of 2019 saw a number of highly destructive UK fires in several modern buildings. These fires (box) surprised observers not only with the extent of the destruction but the speed of fire spread. A dispassionate observer might be forgiven for concluding that in all three cases, the building design failed, and it was only a matter of luck that there were no injuries.
In all three cases we have buildings that presumably were compliant with the Building Regulations, but which failed as structures in a very public way. The impact of the fire in the retirement complex was more immediate requiring the owners to source accommodation and other care for the vulnerable residents together with longer term re-housing. AFSS – perhaps something to be discussed with their insurers.
Whatever else emerges from the debates on modern materials is that ‘just compliant’ construction would benefit greatly from integral fire suppression not only for life safety and property protection but as an additional measure to compensate for circumstances when a key passive compartmentation element fails or is damaged.
Other impacts of minimum building protection
The insurers and the FPA have long been aware of the impact of automatic fire suppression systems (AFSS) in reducing fire losses but the greatest clarity of the value of AFSS in property protection has been demonstrated in the publications issued by the Business Sprinkler Alliance. In particular two of these contain major contributions to the debate: The financial and economic impact of warehouse fires which was produced by Cebr and An environmental and cost benefit analysis for fire sprinklers in warehouses produced by BRE Global.
Other impacts of property fires are self-evident of one chooses to look at the present situation. Fires in commercial premises, even when insured, can lead to the closure of business, loss of jobs, impacts on national resilience from loss of unique design and manufacturing capability and migration of skilled personnel when a business owner chooses to take the insurance pay-out and move his factory to Ireland (Real Crisps fire, Newport, South Wales 2013) or Poland (Findus Frozen Foods fire, Long Benton, Newcastle 2009).
There can be little doubt that traditional differentiation between ‘life safety’ and ‘property protection’ are no longer valid. The widespread failures of compartmentation (both traditional and ‘modern’) must be challenged. The wider environmental, economic and human impact of fires also demands that the Building Regulations be amended to take into account the wider consequences of fire. It’s no longer enough to look at the problem and decide that this can be safely left to the insurers.
For more information, go to www.risk-consultant.com
- BRE: 2005: ODPM Building Regulations Division Project Report: Effect of Local Acts on Fire Risks
- For example, the destruction of the new University of Nottingham chemistry building in 2014.