Fire Strategy

[Mercy Adeniji]

Morning Guys, I hope you enjoyed the bank holiday like I did, we recently created this fire strategy document to help with the creation of fire strategies. If there's any topics/content on fire safety you would like me to post on here please let me know.

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Fire strategy documents

Limited information is available on developing a fire strategy document. Mike Sopp provides guidance on how to develop a fire strategy, the competency necessary to complete it and what the content should include.

Introduction

The UK fire safety regime continues to evolve, with new legal responsibilities, regulatory bodies and systems all recently being introduced.

This adds to the already considerable legal requirements that are being met through a complex standard specification framework and/or, increasingly, fire-engineered solutions.

Post-Grenfell there is more focus and legal duties on ensuring that fire safety is taken into consideration through a building’s whole lifecycle.

One process that is being utilised to assist in this is the development of a fire strategy document. However, how such a document develops is still subject to differing interpretations and challenges.

Fire strategy purpose

BS9999 Fire Safety in the Design, Management and Use of Buildings. Code of Practice defines a fire strategy as a “set of fire safety objectives and the measures to be taken to meet those objectives”.

In practical terms, the above definition does little to put into context the purpose of a fire strategy document. To address this, reference can be made to the guidance document Building Regulations and Fire Safety Procedural Guidance.

This publication notes that “inclusion of a fire strategy as part of the Building Regulations submission can assist the fire safety enforcing authority in providing advice at an early stage as to what, if any, additional provisions may be necessary when the building is first occupied”.

It continues by noting that a fire strategy document:

• is an essential means of providing information and communicating with relevant parties for building designs that place a reliance on fire engineering or place management expectations on the occupier

• is a key document and can eventually be passed on to the Responsible Person along with the other relevant fire safety information required at the time of completion, as required by Regulation 38 of the Building Regulations 2010

• will assist the Responsible Person in developing their fire risk assessment for the purposes of the Fire Safety Order, and act as a record of the rationale behind the fire safety design of the finished building.

It can also be suggested that a fire strategy document will assist the Responsible Person in meeting their legal duty to manage fire safety by developing a “fire risk management strategy”, which is a “document which defines an organisation’s fire risk management system and method of implementing the overarching policy”.

Following the Hackitt Review, greater emphasis is now being placed on the provision of fire safety information for higher-risk buildings with legal requirements to provide fire safety information as part of the “Golden Thread” system and also as part of the Gateway planning process.

The latter in particular will require at Gateway 2 the production of a “Fire and Emergency File”, which may include a fire strategy document.

Developing a fire strategy

As noted above, for the person/organisation responsible for fire safety in the occupied stage of the building’s lifecycle, Regulation 38 of the Building Regulations 2010 requires the person carrying out the work to “give fire safety information to the Responsible Person not later than the date of completion of the work, or the date of occupation of the building or extension, whichever is the earlier”.

Anecdotal evidence suggests that this requirement may not always have been fully met or where it has been met, the information has not necessarily been utilised by those managing fire safety. There is also evidence to suggest that this element had not been enforced by regulators as the duty applies to information going to the “end user” without confirmation being given to building control that this has been completed.

This situation has now been rectified through amendments to the Building Regulations 2010.

Post-Grenfell there is now evidence to suggest that the Regulation 38 information (ie as-built information) is being requested from those managing fire safety when any construction works are undertaken that present a material alteration requiring building control approval.

As a consequence, retrospective fire strategy documents are being developed where the original as-built information is not available that will influence the project’s fire safety requirements.

This brings into question as to the level of competency required to develop an appropriate fire strategy document for the building under review.

For new build and refurbishments, etc fire strategy documents will evolve as the project evolves. The publication Building Regulations and Fire Safety Procedural Guidance makes reference to the Royal Institute of British Architects (RIBA) Fire Safety Compliance Tracker and how this links into the RIBA Plan of Work Stages, including the development of a fire strategy. In summary, this suggests the following:

• RIBA stage 0–4: Design phase — Concept fire strategy and design

• RIBA stage 3–4: Construction phase — Continual review of concept fire design/strategy

• RIBA stage 6: Completion phase — Pre-occupation fire safety assessment, handover of fire safety information

• RIBA stage 7: Occupation phase — Fire risk assessment/fire risk management strategy

From the above, it can be concluded that a fire strategy will have to evolve through various iterations as a project progresses and that there will be numerous stakeholders at each stage, each with differing understanding, needs, outcomes and perspectives on fire safety.

This also brings into question as to where responsibility rests for developing a fire strategy and what level of competency is required. At present there is no guidance in relation to this but as a general rule of thumb, the more complex the building involved the more competency will be required (eg for a complex building it could be completed by a fire engineer).

Content of a fire strategy

Lack of guidance also means that there is limited information as to what the content of a fire strategy should be. The now withdrawn publication PAS911 Fire Strategies — Guidance and Framework for Their Formulation suggested a number of inputs that should be considered, which include:

• management and system audit that may identify any shortfalls in good practice or breach of legislative requirements

• mandatory framework including the Regulatory Reform (Fire Safety) Order, Building Regulations, DSEAR and other related statutory instruments and Acts

• objectives setting to meet the principles set out in the Policy and to ensure the management system requirements are met

• hazard identification and risk assessment to identify and prioritise any particular risks and the action deemed necessary

• building characteristics that may impact the manner in which a fire develops and behaves

• occupant characteristics that may increase risks (eg familiarity with the premises).

The RIBA Plan of Works makes reference to the International Fire Safety Standards: Common Principles (IFSS-CP). The common principles contained in this publication can be applied to the five stages of the building lifecycle (design, construct, use, change, demolish). For each stage the publication then provides brief details of typical strategies that may be applied for each common principle.

In addition, for handover/use stage, information required under Regulation 38 can be used to inform the content of the fire strategy document. This is contained in Appendix G of Approved Document B (Volume 2) and differentiates between “simple and complex buildings”. However, there is no clear definition as to what constitutes a simple building and a complex building, which may again create issues where the end user and fire strategy developer differ in opinion on this.

Finally, where the fire strategy relates to a higher-risk building and the Gateway process, guidance in respect of the development of a Fire and Emergency File may assist in informing content of a fire strategy.

Summary

Development of a fire strategy document is not a legal requirement. However, it is being seen as “best practice” to assist in meeting legal requirements at various stages of a building’s lifecycle.

Despite this, there is limited formal guidance on how to develop a fire strategy, the competency necessary to complete it and what the content should be.

There are growing calls for a full British Standard to be developed that would inform duty holders of how to complete a fire strategy (and how to ensure its smooth passage through various stages of a building’s lifecycle).

In the meantime, other publications, such as those noted above can be used to assist in developing a fire strategy that is pertinent to the building.

Where a fire strategy does exist, it is essential that it is reviewed when significant change occurs so that the fire safety objectives and associated measures remain valid and appropriate for the fire risk profile.


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