BIM4Housing Coordinating a response to the National Fire Chief’s Council 19-10-22

ALEXANDER THOMSON (SANDY)…the consolidated building management tool that all users can use and which then feeds through the fire services and the golden thread which we are trying to achieve as well. There is a lot of work to be done but these new regs land in January and it’s a case of having a solution which can be used from the get-go. GEORGE yes, and can be added to, that’s the key thing. We’re on a journey here. I think they’ll be very few people who have actually got everything in place by the 23rd January.

RICHARD We’re here to respond the Fire Chiefs draft document which we circulated. I’ve had some written feedbacks from people which I’ll come to later on.

MATT HODGES-LONG begins his presentation. TrackMyRisks Fire Safety Regs RP perspective 19 Oct 2022 document is shared on screen. What I’ve tried to do, making an assumption that the majority of the people on the call today are responsible persons or advising responsible persons (apart from our colleagues at the NFCC). I’ve tried to look at this through the lens of an RP giving feedback on a consultation.

First thing, we haven’t got much time left, we’re now into a 3-month cycle before the regulations kick in. My central question is, from an RPs perspective, is are you ready? have you got a plan to get ready? We don’t know yet what enforcement approach is going to be applied by the fire service and that no doubt will change from fire service to fire service depending on where their priorities lie and potentially where their influence is coming from.

There was a good discussion yesterday about FRS governance and the role of the Police and Fire crime commissioners. You start bringing political emphasis into these discussions as well. The answer is we don’t know. From an RPs perspective it’s probably better if you’ve got your back side covered by the 23rd January than not. The consultation: unless the date has been pushed out there are two days left, the consultation closes on the 21st of October. So hence this is a perfectly timed call to make sure everyone has got a few hours to submit their feedback to the NFCC.

I’m looking at this from a market perspective. On the left hand side we’ve got responsible persons (13,000 buildings high-rise). On the other side of the market, we’ve got the Fire and Rescue service in their role as both regulator and operational responder. There is a requirement within the regulations for information to be exchanged between those two parties (actually one way, but NFCC are talking about a route back which is a response to the fault reports and repairs in terms of reference numbers coming back the other way to acknowledge receipt). In the middle of that is the Court service which is the arbiter of when and if all this goes wrong and needs to be adjudicated it’s going to end up at some point in a Court. The party on the left and the party on the right are going to be on opposite sides of an adversarial system.

This maybe over-simplistic, but that is the relationship, although we are talking right now in a collegiate manner, ultimately if you pursue this to the end of the line you are going to end up facing each other in a courtroom, potentially.

In terms of the feedback that we’re going to give, we’ve broken this down into four headings of Information security, data quality, Scalability and Evidential admissibility. I want to congratulate the NFCC for the work they’re doing being given kind of an impossible brief by the Home Office. I think everybody agrees the ideal way to do this would have been for the Home Office to sponsor a system for collecting information and managing that data exchange securely between responsible persons and the fire service (using the singular rather than fire services which is where we are at the moment). Set against that context this presentation is just taking responsible persons through some of the concerns that we have if we were in the shoes of the responsible person.

Information security. At the moment the forms that are proposed to be publish to the open internet, there is no validation of the person/s submitting that information over and above them putting into the form who they are. So there’s no actual secure validation that person is who they say they are. And there’s no link therefore to is that person who is securely submitting the information the responsible person or one of their nominated delegates. So at the moment this is free data and it’s in an area which is open to manual intervention or bot intervention e.g. forms being filled by machine as opposed to a person for whatever purpose. At that point there is the real opportunity for the RP to be impersonated or latterly assert that they were not the ones that submitted that information. Information security, we really need to think about that mechanism for abuse and what we’re going to do to counter that.

Data quality. In terms of the received data most of this issue is a fire service issue, in terms of the onward what do you do with the data once it’s submitted and how does that propagate into production and operational systems within the fire service. Because I’m talking about RPs at the moment I’m parking the fire service side of the equation. From an RPs perspective, if you’ve got a complicated portfolio across multiple fire service regions you may or may not receive at the moment referenced receipts for submission (e.g fault reports, repairs, submitting a floor plan). And how do you store all of that information in your own management systems and report on compliance to your board and regulators that you are meeting the requirements of the fire safety regulations.

The inconsistency of approach, for that internal reporting is compounded by multiple fire and rescue service boundaries and potentially different ways of managing the process. There’s a big issue for RPs in terms of the forms. Knowing what human beings are like with keying text into free text fields in forms it can and will lead to incorrect data being submitted. It’s not as though we’ve described the building once and the RP once and then we are appending to that operational information. What we’re having to do with the forms is put that information in every time as new and therefore every time you fill in a form you introduce keying errors which could or could not be material later on down the line in terms of how that report is then married up with other databases.

Scalability. Doing some simple math, 13,000 high-rises and let’s say there are 5 unique floor plates per building and one building plan that’s 6 plans times 13,000 so that’s 78,000 building and floor plans that need to be shared or made electronically available to the fire services and that’s before we start bringing in version control of updating either the site plan of the floor plan over time. So potentially there’s hundreds and thousands of buildings and floor plans that are going to be sailing their way via email into the various fire and rescue services and then being dealt with operationally at the other end. 13,000 external wall submissions and then we don’t know how many thousands of fault reports and repair reports that will be submitted.

What we’re saying is without integration into Business as usual management systems (so the system the RP uses to mange this in their own business) we’re then introducing a manual task that means you’ve now got to remember to go and share that new version with your local fire service. That will get overlooked. I was talking to an RP a few days ago and said ‘I went to your website and noticed all of your fire risk assessments were way beyond their expiry date’. he said ‘they’ve all been done, everything is up-to-date’ and then he realised that because the publication of the FRAs to the public on the website was a manual process somebody had forgotten to either tell the person with the keys to the website to update the site or had forgotten to make the updates themselves. That’s just 22 FRAs in one RPs organisation, we’re now talking about this 13,000 times: there will be problems.

The last thing is around evidential admissibility, this is more questions I think the courts will determine, but having been through supporting a number of clients through court cases with regulators. If we take floor plans and talk about the mechanism of sending them by email the discovery that’s required to prove what was actually sent, when it was sent, whether it was received, who received it, did it meet or exceed a file size limit for attachments. did ti send a failure message, was the failure message acted on are all points that are potentially going to be looked at by the court if the lack of floor plan was pertinent to any kind of action being brought. It’s an absolute nightmare of discovery.

As an RP how will you defend whether you did or did not submit a form and what did that form contain? The opposite side of the equation (the FRS giving evidence) is asserting something different to what you’re asserting. Again, we’ve got a potential black hole here or points of difference that could be dealt with through discovery but would take a lot of time and money rather than a definitive record of what happened. if that submission is pertinent to the defence/prosecution how will an RP defend their position? I’m talking here about the tip of the iceberg as most RPs will not end up being subject to regulatory intervention, but if you that’s the point where you’re going to want to lean on a definitive record of what happened. With the current proposal there are a lot of areas where I think, legally and evidentially, both sides could drive a bus through that data exchange.

They're the points I wanted to submit. A little plug at the end: We think we’ve solved a lot of these problems with what we’re doing in the Building Safety Register. We’d love to chat with anybody about tightening this process up but fully understand that there are other ways of solving this problem and different levels of concern within different types of responsible person going forward.

RICHARD That’s an excellent industry-wide overview. We do want to drill down into individual experiences, but before I do that are there any comments on what Matt has said so far?

ALEXANDER THOMSON I think it’s important to understand why and where these regs have come from and why they’ve been brought forward. They are the outcome of the Grenfell Tower enquiry phase 1. Although we don’t cover all of the aspects of phase 1 because the government have decided to bring back the peeps for now until they decipher exactly how they want to handle that going forward, although there is a paper out there the NFCC have done regarding that. In essence the information that is required to be forwarded to the fire and rescue service is primarily for operational crews to deal with an incident at a building. So if an incident were to occur the responding crews would that information to hand.

Obviously the digital route is being looked at but in reality most fire and rescue services will still being relying on the paper copies which you’ll be required to supply to the secure information boxes that you’re now required to put in your premises. For right now in the real life terms that is the most important area. So if we talk about integration of updating floor plans it will have to be a manual intervention because the floor plans will have to be updated within the safety information boxes as they will more than likely be the most reliable source of information for attending crews as things stand right now. Going forward, there has to be a technological advancement in how crews respond. There are already NDTs and detachable screens that they can get information from, but a vast majority of services are not in a place yet where they can use these as effectively as a laminated A3 plan in the middle of the night when it’s raining.

Following the FIA guidance which is out there regarding what should be in your X??? 19 mins 23 secs that’s really important about the outcomes of this information. Going back to the information and exchange, we have to remember whatever system we put in place fire and rescue services receive that information but right now we’ve got 43 fire and rescue services in England who all move information through their services slightly differently. So there’s a challenge there and it’s not just this regs, the golden thread policy from the government of having a fully built management system will come to a conclusion where we have similar systems probably to what Matt talked about. In my head it would be great if we had one system that all fire and rescue services used but I think that will be a challenge in itself.

ASHLEY MATHER A view point of the enforcement, it’s been discussed what that might look and feel like. The regs commence January and fire services are already discussing what enforcement might look like. Whilst it’s for each fire service to decide how where they take it, where submissions aren’t received on 23rd January I would not be expecting enforcement to occur straight away. i imagine there will be continued engagement in those early days. We should clearly be working to that commencement date, but in terms of enforcement if we take a slightly more pragmatic view the information provided isn’t putting anybody immediately at risk if its not been sent (obviously its there to inform the crews.

About fault reporting, there’s actually existing requirements to maintain your equipment. With the big scary things if they’re not done and are putting people at risk, clearly there will be consequences if they’re not done (if information is not passed over in a timely manner) and it’s had an impact on how an operational issue has played out. The starting point would be where RPs know they are going to struggle to provide this, speak to your local fire service.

MATT just picking up on Sandy’s point, the reason i focused on the electronic sharings, that’s what the purpose of the call is, what I didn’t go through was the other stakeholders. Other than the RP there are 3 stakeholders in these regulations: 1) the fire service 2) residents 3) secure information box, the analog output. The really good question which has been posted in the chat is around the inclusion of the secure information box content in terms of assurance and checking. The question is posed around integrated locking solutions that can say when a box was opened, great. There are other less technological ways it could be done

What I’ve advised people is if you are doing your monthly equipment checks anyway (the 7 points that are in the regulations) then why not add the contents of the secure information box as point 8 (informally), open the thing and look at it. You need to double check the analog printed content against its source. Where you’re pointing back to is if you’re looking at the digital version of the contents is ‘version 8’ that you’ve got in your digital repository, is ‘version 8’ printed and put in your secure information box, yes or no. Encouraging RPs to think about that as a process with all of their other checks would be good, but it sin’t a regulatory requirement specifically (other than you might have to evidence an annual check of the information box).

ROY BUCKINGHAM Expanding on what Matt just picked up on there with regards to the information that’s contained within the secure information box. That information obviously  needs to be kept up-to-date and managed, but how do we verify that information is up-to-date and in the box because if there is no auditing of somebody accessing the box how do you know that if even if the latest version has put in there somebody else hasn’t accessed that box and removed it? How do we know that the person who says on their system/records that they are going to update that information physically actually do that?  You could have a worst case scenario where somebody clicks on their system to record the fact they are going to change that information and then for some reason it never actually reaches that destination and therefore the information hasn’t been updated.

it occurs to me that after an incident there could be a requirement, particularly if there was a fatality, of an inquiry that somebody may need to be able to prove that the info the fire and rescue services had on site at the time of the emergency was up-to-date at that moment in time. It occurs to me there needs to be some kind of auditing and I feel the current ways that secure information boxes are managed on site, there is no way of verifying that information is accurate and up-to-date at the time it’s accessed. there are ways of doing it and achieving it and the code of practice that highlights the overall requirements for a PIB does have the ability to allow that but it also has the ability to allow a key to open the box that actually cannot be verified as being the only key available because the way it’s written at the moment it will allow potential duplication of keys, so there is no way of managing those keys in circulation.

GEORGE in response to Roy. One of the things mentioned to me is if the different secure information boxes have different keys for security purposes that can be a nightmare for the fire authorities because have they got the right one. From a practical perspective perhaps it almost has to be like a skeleton key that can open any of them. i guess one is a security issue from an information security perspective, the other is the practical side of it hunting around to see if they’ve got the right key.

ROY The need to manage who has access to those keys is important and simplifying how those keys have access to those boxes is extremely important. All 47 fire and rescue services could have a single key, whether it’s mechanical or electronic, that accesses every single SIB in the country. But it needs to be secure and not easily duplicated because we already have incidents reported by Local Authorities and housing Associations where the current fire and rescue service standard keys used to access are too readily available and causing anti-social behaviour etc. It’s then discussed whether Gerda is the only provider of key systems. There are alternative providers of key systems and I would add that a mechanical key can’t be audited, so we come back to that how do you manage who has access to the box and how do you know information has been updated and changed.

RICHARD I’ll curtail that as we need to focus on the purpose of this meeting which is looking at our response to the National Fire Chiefs Council’s provisional…I’ve had a few written feedbacks, one from David Poat who heads up Bim4housing’s development group. He has a couple of questions perhaps for Sandy to answer. In terms of external wall types, for each wall type do we need to include what percentage of the building the wall type covers? The other point is that at the bottom fo one of the pages there is a text box for more information, but this isn’t on each page and  I think it should be.

ASHLEY if there are some questions missing on the form, apologies. Regarding the part of the question about providing more information, that should be consistent throughout so it’s possible that’s been missed on the draft. regarding the percentage of any particular material that makes up a wall, recognise that is something that is explicitly asked, that’s really part of what this consultation period is for so we take that on board. Actually what we want to be able to do is if the information has been provided on a form when you get to the building you can interpret that and translate it to the building you’re seeing.

That might be one means of capturing that, if we’ve identified a combustible material when we get to that building we need to know where it is. Actually providing a percentage coverage might be one way of helping to identify that. In the final question set I do envisage some more guidance or a little bit of framing. I’m wary from previous requests of information on this you can get caught up in trying to provide the percentages, so that might be one way of doing it but I expect a little bit elaboration on the question to try and assist in understanding where the different bits of the wall are located on the building.

RICHARD if you’re looking at an emergency document that is a laminated plastic sheet of paper that firemen will access in a state of emergency I suppose you have to be pretty selective of what you’re putting on it because you don’t want to search through for the critical information you need right there.

ASHLEY Exactly. if you’ve got two materials and it’s a 50/50 split or 100% of one material that question still has to become slightly less relevant. If we’ve identified a very highly combustible bit of material (but it only represents a low percentage) that’s when you can start interpreting that. I think we were wary of asking questions for questions sake. There will certainly be occasions when that understanding of how much a particular material covers within a wall will be relevant. You can expect that to be captured in the final revision of these templates, to do it in a way that’s easy to understand and enter.

RICHARD Let’s dig a bit deeper into the actual content of the document. Roy, you sent quite a detailed response through to me, would you like to raise some of those points now? particularly around the tenants.

ROY This is in relation top the templates and the response that I provided on the consultation. More to do with the faults report application really. The only fault application related to a door is in relation to the auto-release or electrically hold open doors that are triggered to release and auto-close on activation to create that compartmentation. But what about other faults with fire compartmentation doors that may result in a fire door not being capable of providing compartmentation? Perhaps the fire and rescue service need to know actually an area of a building may be compromised because of the failure of the compartmentation.

ASHLEY There is a certain reality to that one in that it’s not required to submit that bit to the fire service. I take your point actually around the fire door checks that are required to be completed, there’s no requirement to submit the record of the checks that are required to complete on the fire doors to us as well, so that one is not on there. Arguably the one around auto-release is of little value because if they don’;t work they default to the closed position anyway, so I struggle to see how that one will manifest itself in an issue that needs to be considered. But the scoping of the faults is very much dictated by the legislation.

ROY Your requirement is for the auto-release actuation to work, that is something you’re asking for faults to be reported on. But the one point that wasn’t highlighted on that, it mentions about doors which are held open and auto-close to provide that compartmentation, what it doesn’t identify is that many of those doors may be locked doors that have to release on activation of the fire alarm to allow escape. The general consensus is all about the fire compartmentation and limiting the spread of fire, but there seems to be a complete omission of any requirements form an escape perspective e.g. are the escape routes available? Are the hardware that allows people to escape through the buildings functioning and allowing people to use those escape routes? if you’ve got a tall block with two escape stairs you need to know that both of those escape stairs are available and open for people to access. If one of them isn’t because of some failure of the hardware that should be something that you should want reporting on.

ASHLEY I suppose it comes back to the intention behind these regulations is to support the operational crews and their responding. It’s clearly framed in that way, the items that are reportable on are under the umbrella heading of essential fire fighting equipment. Clearly some of those have direct implications for the safety of those escaping. None of this takes away any of the existing requirements to maintain and look after the means of escape, I think it’s trying to pick out the ones that are going to directly effect us as a responder. I take your point on board. At some point you have to draw a line under what information you send to the fire service. Time will tell the extent, how many thousands of fault reports will be received. The more equipment that gets covered by that, the more equipment that gets covered by that the more burdensome it becomes. What do we do with it? I suppose it's that acknowledgement.

ROY The one point I want to add to that is obviously (and Grenfell was an example of this) in some of these tall rise buildings there’s a X? 41 mins 19secs policy, we now have a requirement for ECs in these buildings which will change that so the ability for somebody to alert the occupants that they then need to escape, it’s kind of tied in with that. To me you need to know that people can readily escape through available escape routes. And almost by omitting it from the requirements for the information you’re almost saying to RPs that’s not important. To me, there’s 2 elements of fire safety that are important: one is restricting and stopping the spread of fire and the other is getting people out of the building. The safest place for any person in a building in a fire is outside of the building.

PAUL WHITE My thoughts are do you have to report the active systems, so the smoke control system is not working - surely you need to know that because that’s aiding in fire fighting. Your sprinkler system is not working, you should need to know. This is very important. The issue is that this then becomes public domain. Matt’s presentation was interesting in the fact that all these things are now declared (and they may well be used in court against you after the event) but the key other point is there’s going to be questions about why wasn’t it fixed. I know that’s nothing to do with this, the point is this evidence is going to be very clearly there and its not necessarily going to be followed up. Certainly I would think that reporting faults e.g. smoke control systems, sprinkler systems, maybe fire damper systems, surely they’re down to being reported. if they're not could someone tell me what the reference is to be reported please.

ALEXANDER THOMSON The answer to that is yes they are. Its fire fighting lifts and essential fire fighting equipment which includes smoke extraction and sprinkler systems etc. Especially a smoke control system which potentially would have a major effect on means of escape. Also, to what extent is it faulty. This is when you’d need to have a competent person whoever is looking at it from your perspective to then assess how does that effect the fire strategy for the building and therefore what mitigation are you going to put in place to overcome that whilst that system is out of place.

PAUL WHITE Smoke control systems alone, if anybody is actually realising they are having to report this, you’ll be inundated on day 1 because there’s a load of systems that either people don’t know and they haven’t maintained and if they do go to look at them they’ll probably find they’ve turned them off. ALEXANDER THOMSON There you have it then. So we have a number of live systems in potentially a lot of buildings which are not maintained properly. Yes, it might be really burdensome for a lot of people to begin with but ultimately that’s what we’re trying to get to, a place of competency and that buildings are safe.

PAUL HAYLES if  I’m responsible for an AOV I don't check it everyday, ti will get checked periodically as part of our planned maintenance FRAs etc. Then we find there’s a fault. We have a fixed time period where we have to have that fault fixed and now we’re telling the fire and rescue service by electronic means, there is definitely going to be a lag. So you could turn up at a building, attend a fire and once all the dust has settled and the details are looked at you find a broken AOV. Well you might have been the first person to discover it was broken at that incident. I’m trying to work out what use that information would be if we weren’t aware of it at the time you needed that information. So, perhaps less is more… a smaller list. The time lag could be significant.

PAUL WHITE Unfortunately your smoke control systems BS9999 you should be checking for functionality every week. If you don’t check the smoke control system you won’t know it’s got a fault because they are passive until they receive and alarm. So you can’t leave them for 3 months. If there is a fault in it and you’ve got an AOV jammed open and the fire is not on that floor it’s not going to work. So it’s a life safety system, we’ve got to bring these things to the fore and that’s part of what this is. If people didn’t realise the smoke control system in Grenfell Tower was…there was a lot of things that weren’t potentially right with it so you can’t leave things for the 3 and 6 monthly. Fire safety isn’t a maintenance issue it’s a fault, fix it.

MATT My interpretation of this is that the regulations are saying the monthly inspection items as a minimum standard activity, but it is very clearly stated in the regulations that at the moment you notice a problem in that monthly inspection, if it will take longer than 24 hours to fix that system, it has to be reported to the fire service. So if you can’t evidence that you’ve either done the monthly inspection or you’ve reported it within the specified period you are in breach of those regulations. So it has to be done. There needs to be a management system that says how do we evidence the monthly inspection, how do we report if there are failures quickly, how was that audited. Also there is a duty regulation 74 that the evidence of the monthly inspection being done has to be made available to residents.

There is a process there that all RPs have for to think this is probably in excess of what you could currently be doing already. So there is a management change to take place and that needs to be planned in within the next 95 days. From talking to a lot of RPs recently there’s probably quite a lot of detail in the regulations that have been overlooked or misunderstood. Part of the reason for that is the amount of oxygen that is being sucked from the room by the Building Safety Act has kind of let the fire safety regulations almost fly under the radar a bit in terms of management priorities.

What we’ve got to do is bring them up because that is the one that is going to hit you first as an RP. I asked this conversation at the fire conference yesterday to the panel that how do they feel about all the attention being on the Building Safety Act at the moment and what we are talking about today being underplayed, under promoted. A good thing about today is we are bringing these things out into the open.

ASHLEY A couple of observations. It’s the MOT check analogy, faults will develop over the time and the onus will be on to show when I last checked it it worked then. I don’t think you need to worry too much about potentially a fault developing before you’ve got around to doing your next routine check. There is official Home Office guidance coming out in support of these regulations. It sets out some of the expectations of what these routine checks look like.  The checks that will be required=, although we often refer to the appropriate British standard, we do recognise the BS for each piece of equipment covered by these might not have a nice tidy…a monthly check might not align with the monthly check required for those systems e.g with fire alarms, you start thinking of a weekly check. There is guidance forthcoming that should be published before the end of the year that better outlines what some of this stuff will look like and the expectations for yourself.

GEORGE Just building on what Paul Hayles and Paul White were talking about earlier, the other aspect of this isn’t just compliance with the requirement to do things either on a periodic basis or a weekly basis, it’s also the context of the safety case where actually the responsibility is the implication of that smoke system not working. The fact is if you’ve then discovered there i a problem then in the legislation you’ve got 24 hours to resolve it, or that needs to be alerted to the relevant people.

MATT Actually it says where a fault identified under Paragraph 2 cannot be rectified within a 24-hour period beginning with the time the fault is identified the responsible person must as soon as reasonably practical report the fault to the local fire service. The interpretation of what reasonably practical is will probably be for a court to decide at some point. I’d read that as within the 24-hour period of grace that you’ve got that’s the time frame in which you should report it, not 3 weeks after the event. GEORGE That’s really why there needs to be some sort of connection between inspection and being able to identify that that’s the case.

TOM SPENCER Picking up on what George said and what Paul Hayles said before, thinking about this from a practical sense I think evidence that inspections are taking place is one thing. I accept the legislation that we should be doing something and reporting something that is faulty but it does become a bit of a management nightmare in terms of making sure it’s up-to-date. Paul’s point was that you’re always a few steps behind the reality. You could be reporting something as faulty by the time someone is out on-site and completing it and you’re almost chasing your tail to say the action has been completed.

I’m struggling a bit with as to how we manage that, particularly when you’ve got different departments to deal with different things, you inherently get lags within an organisation between the sharing of information. My team do try and oversee the completion of repairs to be done within a timely manner, but that’s within our internal systems and then to have a second system or platform that we’ll have to update as well, it adds another level of complexity to the monitoring of it. I’m not against it, I’m just expressing the difficulties we might encounter should we head down this road.

RICHARD I’ve been holding a number of one-to-one meetings with Housing Associations and Local Authorities and something that is very clear, everybody is doing it differently. Not just in a different methodology, they are also doing it with a different end point. Now for some people the end point is January (do the bare minimum, this is what we’ve got to do), others are thinking we won’t get it done by January so its beyond January but at least we’re on the path. Others are thinking rather than do it twice start including within that requirements for the Building Safety Act. A number of people have suggested to me that it would be useful to all of us to actually see some sort of comparison of the different methodologies that people are using, to see the pros and cons and which works, why is it working best. is it a question of marrying together 2 or methodologies and see which works.

GEORGE on work he is doing with Tower Hamlets. We’ve got 2 or 3 different clients that are doing it in different ways. The approach that we’re taking with Tower Hamlets is to take their existing information, because they’ve got floor plans for some of their buildings but they’re not confident that they’re of the right level. He shares a Tower Hamlets Homes spreadsheet on screen. They’ve give us a spreadsheet of 75 blocks, there’s some basic information in there about the number of floors, height of the buildings and the number of dwellings. We’ve just uploaded those into Active Plan. This now is the same information that was in the spreadsheet but it’s now in the database and integrated with google maps so they can see where the assets are.

What they can also do is use the normal functionality that’s within google maps (this is just using an API to connect to things). if we look at the attributes, it has carried the attributes through from that spreadsheet. So fi there is any other metadata that is being collected that now is in what we call a data container that can then hold that information. We’ve tied up with some surveying companies that are able to do this type of thing. This very expensive device, if you have the surveyor come in and do this it’s actually generating a point cloud which can then generate the floor plans. So the floor plans that we then generate are very simple floor plans, this is what can go into the information box, But then we can import those into Active Plan and these are now interactive containers that we can add information to.

Tower Hamlets wanted 360 photos to be able to go and capture that. 360 photos have come through this process as well so they can then go and see where the assets are and they can tag the assets in that environment and then drop that back into the database so that they can actually see where the AOV is for example. You can also tie that back to your maintenance information or your inspection regime. So it’s a way of creating form almost nothing some detailed information. We’ve also had access to an apartment and we’re going to be using these as archetypes that can then be created in there as well. So that’s one way of doing things.

This is one that we’re doing for Peabody where we’ve taken the existing O&M information and we’ve made it so that it can be updated and enhanced. Here we’ve got the fire plan. We’ve taken the fire plan information which is static information (you can’t edit it or update it) and we’ve brought it into Active Plan so that we’ve now got those grouped together. The fire doors and compartmentation is now in the plan but now in a form that can be interrogated, updated. here where those fire compartments and assets are, but also the key elements there so we’re now tying that back to the fire doors. If that information changes e.g. somebody screws a pin-board onto a wall and compromises the dry lining it can be updated and then visually this can represent that.

A 3rd way of doing it, the work we’re doing with PRP. They’re creating point clouds using the survey companies, they’re doing that for the safety case. But once the safety case is done that can then come into be managed going forward. Here’s a particular door example and again it can be managed externally. So that’s a way that the information can then be used so it’s not just a dead end of the fire plan, it’s a matter of being able to re-use what you’ve already got and building  on that.

RICHARD There are other people on the call that I’ve spoken to who are also doing the scanning. Are you going down the same sort of route that George is showing us? Is it different? How is it different?

TOM We’re doing something very similar to what George has shown there. A contractor we’d used, for various reasons mainly around procurement, we had to go out and to tender for someone else. But basically we’ve got the bones of it which is the visual representations of our buildings which is like your google maps, so we can virtually walk through our high-rise buildings and we can put certain tags onto different assets within that building. it doesn’t do the plan drawings that you’ve shown there but it certainly has that capability. You can link through you can have stand-alone information, you can even link through to training videos for how to test emergency lighting etc. so there’s lots of capabilities we’re looking at using it for.

RICHARD Explain to me how this relates to the little box in the wall that the fireman comes in, uses his magic key to open and get the information he needs right then because the building is on fire.

GEORGE From my perspective what we’re doing is you’ve got the coordinated information and you can produce and plans any information that you want as PDFs which can then be laminated. The danger at the moment I’m concerned about is people just producing a fire plan and somebody then creates another plan for another purpose (maybe the safety case or general maintenance) and it doesn’t get kept up-to-date. It needs to come from a coordinated information set, as Matt said earlier.

TOM We’re also using it to manage the building better, so when you refer to that little grey box, we’ve got hundreds of little grey boxes across one bock and we don't know what  half of them do. We can probably figure it out but trying to describe one grey box over another grey box is very difficult. So we can put a physical tag on it in a virtual system to say ‘it is this’.

MATT I wanted to change the subject. There is a bit of feedback I forgot to add into my presentation. This actually came up in some worked examples where we were looking at real buildings. The regulations talk about informing the local fire and rescue authority. if you’re in the middle of Hampshire that’s very easy, if you’ve got a building on the boundary quite often it’s not logically obvious. We looked at one post code where the first 4 letters of the code brought back 2 fire services, it was only when you put the final 3 characters in that you get to the correct one. We stumbled across a now defunct chief fire officer’s look-up tool which isn’t up-to-date but is a part of the feedback.

There is a risk that responsible persons are going to be contacting the wrong fire and rescue service. i’d hope that wrong service would point that out to the RP to say ‘this isn’t Hampshire, it’s Berkshire, can you speak to them’. There’s a flag for anybody that\’s got boundary based buildings or is working across multiple fire areas and might not necessarily know their portfolio intimately that that’s something everybody has got to resolve, just making sure that you’ve got your schedule of buildings versus the correct fire and rescue service.

RICHARD Paul White and Roy Buckingham, from your comments earlier on, from what Tom and George have just said does that allay your fears at all that that is available to do it in that way?

ROY I don't see how the digital information correlates to insuring the accuracy of the information in the information box on-site. We can create a task for somebody to physically change that but how do we record it’s been done. And also, yes we can use that to evidence the fact that perhaps the electronically controlled exit doors are functioning and have been checked but again there are limitations on that given that it’s not a topic that is specifically being asked for.

LUCY CRAIG i mentioned in the hat about the competence of the people checking it, we talk about the scope of complexities in the building, i think there’s going to have to be 3rd part people helping those people producing reports and evaluations and that’s obviously layers of cost that isn’t necessarily allowed for in operations management of the buildings. And then not maybe for this forum but we’ve discussed quite a bit (Paul White is part of the work that we’re doing) in my organisation was about how do you get to a point where you’ve got a competent system that’s designed because it’s all very well having those components in there but are they right. Again, that goes to the layer of complexity, it’s about the responsible person.

ANDREW HOLLEY Just bringing us back to what the NFCC are asking for which is tell us what your buildings are like so when we turn up in a fire we know what to do, and that should be full term, most of our buildings don’t change regularly, we don’t have to worry about suddenly a wall disappearing - we know when those things are happening and we can update them in reality to match the plans. But generally these guys want to know what the building is like, where are the issues. So they want to know first of all what the building is permanently like, so we fixe a load of plans for that, and then separately which is a different thing. So that permanent stuff goes in the PIB and when things change on the building we’ll change them in the PIB too.

When something happens on the maintenance side of things we inform them that that bit of kit is not working. That’s the point of these regulations, it’s not to go into every little detail about every little thing, these guys are putting a fire out, they don’t need to know details about the maintenance regime. This is not a test of our maintenance and management systems to be proved in court. This is to give information for when the fire brigade turn up to a building and they don’t know anywhere near enough stiff, it’s to give them information they’ve never had before like ‘fire alarm panel says flat 6 is on fire - where’s flat 6?’’Oh, it’s that one because this picture in the PIB says so. On the way they can get the info up electronically and above it is a load of cladding, that’s what you need to worry about. That’s what its all about. We do need that minute detail for the golden thread separately, but these guys need the bigger picture.

MICK TOTTY On the point that Andrew just raised, as an expert operational officer the crews should still be going out and doing familiarisation visits on these buildings. So its not necessary down to the RPs to make sure everything is in place. CreWe used to go out to the high-rise buildings monthly to familiarise ourselves. And if they are on borders one of the stations I worked at was the border of West Midlands and Warwickshire and we would invite Warwickshire over because they could be turned out on a PDA. The fire services are not as responsible but partly responsible to make sure they are fully aware of where everything is within that building.

The onus should not solely be on the RP. i know a lot of cases where crews aren’t going out, they haven’t got time to go out and do familiarisation visits. Well I’m sorry but this has to be planned in as part of their routine work. The same as the maintenance. If RPs are reporting that so and so is not working this information is not going to get down to the crews. I noticed on some of the comments that we could have codes for the fire service so that when they turn up they an open the box with a code. We were never allowed to do that under GDPR. That’ another little thing that is going to get in the way.

ALEXANDER THOMSON I don't know where you’re getting that from, Mick, there’s plenty of codes out there for appliances which have code seal open doors etc. Your point about familiarisation visits of high-risk buildings, absolutely the crews should have some sort of plan. Some boroughs in London will have literally hundreds of these blocks so the reality is that each fires station may not have a full working knowledge of your building. This is why these regs have been put into place because in the outcomes of the Grenfell inquiry under requirements which the industry came up short in certain areas and this is one of the outcomes. these have been put together from a number of sources as a requirement. Especially for high-risk buildings there will be familiarisation visits but in reality there is not probably the time for many stations for full familiarisation of every block in their area so these requirements are very much required.

RICHARD that’s the reality, isn’t it. There may well be some responsibility on the fire service but that doesn’t in anyway lessen the responsibility on the buildings themselves. There’s no get out there, guys.

ANDREW The guys can do familiarisation but they can only see what they can physically see. So our information is telling them stuff they can’t see. They look at a bit of kit and go, what’s that made of? We can tell them. You’ve got to remember this information is designed to be reacted to as a fire starts or maybe by a control crew if it’s developing and they want to dig a bit more detail. Most of the time you want short sharp information so in TXEH we have a sheet of information for the fire service and I get all that information on 2 sides of A4. It says what fire alarm and AOV systems I’ve got, where the dry risers are, where the hydrant is. if you can’t read it in 2 minutes it’s too much information.

MATT A quick question for NFCC. In terms of extra information to the FRS, one of the regulations is around the responsible person’s contact details and other key contact details to be placed in the secure information box. Given the discussion and the time lag on keys and access it seems sensible to me that that would be something you would share electronically with the local fire and rescue service as well. If an RP wanted to share that information would that be received or would it just be ignored because it’s not within the regulation?

ASHLEY I suppose actually it’s a question on forms for the walls and we’ve asked for it on the plans as well so that everyone can just align the information they’ve got so. i think generally any fire service would be welcome to be told who’s in charge of that building. But that specific bit of information is captured on the forms that are fulfilling the other elements of this anyway.

RICHARD i’m going to be continuing with my one-to-one meetings throughout on an ongoing basis. Something that has been suggested is that we actually do small meetings, 4 or 5 people, rather than the 60 or 70 people in this meeting, Not everybody gets to talk (not everybody wants to talk). With a more personal meeting i think people are a little bit more relaxed and a little more open. So we’re going to be doing that and looking at different approaches, how we are all getting on basically on an ongoing basis. I want to close off with Ashley and Sandy; you’ve now heard from Bim4hosuing, was that helpful?

ASHLEY Very much so. ALEXANDER THOMSON (Sandy) Yeah, very much so. ASHLEY Will you send in perhaps a single collective response?

RICHARD What we do, everything in the chat will be included in the chat which will be a highpoint document of this meeting (which has been recorded) which you’ll receive along with a full transcript and the video. So anything that has been said and written on this meeting, plus the stuff I had through before the meeting, you’ll get a package through with everything.

GEORGE I absolutely agree that having smaller groups, maybe over the next month or so, is a really good idea. is it worth putting a date in the diary for maybe a month or six weeks for people to actually have this collective experience again? RICHARD Yes, OK, six week from today, that’s around the 2nd December. On that basis I’m going to send you all out invites for 6 weeks time approximately and you’ll be hearing from em for little group meetings and one-to-ones.

ALEXANDER THOMSON Just one point; please liaise with your local fire and rescue services on this as well. We’re trying to put out a general kind of way of doing this but ultimately it’s your interconnection with your local fire and rescue services which this all comes down to.



Roy Buckingham

Given how important it is for the information to be available in the Secure Information box and how important it is for this to be regularly updated. Additionally, if required as evidence following an incident we may need to know the information was not changed subsequently. Therefore, I believe that there should be auditing of access to the secure information box. to identify who has accessed and when. This is possible with the locking solutions defined in the FIA PIB Code of practice standard for the PIB's. With a suitable integrated locking solution, the process of ensuring the physical info is updated could be achieved by auto creating a task that has to be completed by the RP, which can then be verified by the use of a key to open the PIB.


Maybe those in primary authority schemes can assist

Ellamae Fullalove

Maybe part of NTCs

Bex Gibson

Could QR codes be utilised?

Linking to up-to-date digital information, rather than relying on hard copies?

Lysa Nicely

Issue with QR codes is they would either be accessible to all and or the FRS would have to register and have the App

Ellamae Fullalove

We’ve got some PIBs inside the building, makes no sense to me as inside the box, inside the block is info on how to gain access. They are FB padlocks. Can’t see them trying to gain access, and they’ve just broken in before!

Is there any guidance as to whether it should be a document box or Gerda?

Bex Gibson

It could be linked to an open website / with basic password the same as the code for the box?

Somayya Yaqub

Fobs would be best instead of keys. The codes can be changed as necessary, and you have an audit log of who has access the box. If issues arise then change the code instead of reissuing the keys.

Mark Sanderson

Hold the keys in a key safe on the exterior of the build. code sent to fire service with electronic documents

Tom Spencer

We have used SIB's with keypads and are accessed via a unique code, why do they have to be keyed?


Jarek Wityk

Regarding limiting authorised access to keys, the UK Power Network (UKPN) seem to be doing good job with the access to the High Voltage (HV) Sub Stations

Matt Hodges-Long

Perhaps a session on the management of SIBs would be a good idea.

Omar Amin

Gerda is not universally carried by all FRS. It is simply the most readily used in the industry (in general)

Tom Spencer

I agree, we were told many years ago by our local FRS that at the time they didn’t hold Gerda keys and therefore for us to install Gerda boxes would have been an expensive and unnecessary thing for us to do

Roy Buckingham

fobs are not necessarily the answer the most commonly used RFID solution is mifare and this is easily clonable. Electronic keys can be remotely managed and updated and are higher security and can allow management of other applications mechanically where audits are not required to manage costs. An access control system could be costly to install on a PIB

Alexander Thomson

From a Fire Service perspective, the thought of having multiply keys for potential hundreds of boxes on various fire appliances is not practically achievable.

Ellamae Fullalove

Also, something to be said about wall mounted maps etc

You can get a lot of essential info on two A3 wall mounted sheets (bar the peeps!)

Jarek Wityk

Let’s not forget about failure of Mains Supply (Electrical) both the Standards and Life Safety, when the form listed Mains I thought its exactly about that, but when I checked the forms its about wet and dry risers ?

Without the electrical supply most of other services will fail unless supported by UPS or Generator – so I think Life safety LV Distribution should be included as minimum

Matt Hodges-Long

Jarek Wityk the reporting duties are point in time, systemic risk in HRBs will be picked up through the safety case regime under the Building Safety Act. It’s all weirdly disjointed

Ashley Mather

Sprinklers and smoke control systems are explicitly covered by the Regulations

Matt Hodges-Long

Listed in Regulation 6 section 7 of the Regs


Christine Milling

One aspect is there being faults reported. You will have to also follow up when systems are fixed

Matt Hodges-Long

There is a duty in the regs to report faults and repairs Reg 7 (3b)

Lucy Craig

These system are complex. This assumes the weekly checks per system are being done by competent person - RP. I can’t see how this RP can cover all these systems and their complexities.

Paul Hayles

British Standards are not mandatory

Paul White

But they are best guidance available

Matt Hodges-Long 

The Fire Regs in effect call for a BSM type role in my view

Paul Hayles

for some buildings I would agree

Saz Siddique

We have a similar system as AP - to develop the Golden Thread for all our buildings 18m and above. All components are asset tagged so we have the repairs history. This is liked to safety case.

Christine Milling

One aspect is showing the asset and floor plan. Maybe you should work back from a notification to the fire service and work back to the activity involving the asset which has identified a fault

Bex Gibson

We are scanning our HRB to feed into floor plans/elevations. In the first instance, this will deliver the requirements of the FSA in Jan, and also into the remediation projects. We've asked the scanning team to also locate all fire safety equipment onto the plans

Matt Hodges-Long

Roy, assurance checking the SIB content is no different to checking another analogue firefighting system. I would record the check as evidence and that should be subject to audit.

Ellamae Fullalove

Roy Buckingham

if an escape route is not available for use this could change the approach and actions when implementing an evacuation using an EACIE, they may need to evacuate earlier for instance to allow more time for occupants to exit

Ellamae Fullalove

We had similar as A4 on the wall, following an LFB audit they asked them to be A3

Saz Siddique

We have x2 sets of plans. Plans fitted on each floor showing the fire exits, call points etc, flat numbers etc - for residents / visitors. In the PIB we have a more detailed floor plans for the FRS includes all the location of the components / shut off valves etc.

Lysa Nicely

Can you share your provider who designed please

Saz Siddique

We have a PEEPS summary, so we don't breach GDPR

Tom Spencer 

Yeah, us too. We have a coloured coded summary of the block indicating where there are residents who potentially couldn’t get themselves out. This allows our local FRS to focus their attention on these residents should they need to in the event of an emergency.

Ellamae Fullalove

Shows they found them helpful at least

There’s nothing in the guidance saying stuff should be visible or mounted so I think this should be a set layout for what’s on the wall, what’s in the box

Roy Buckingham

the inclusion of PEEPS in a PIB also has implications from a GDPR perspective and the need to protect access to that data

Matt Hodges-Long

Legal liability sits with the Responsible Person in law, not with the FRS

Mark Sanderson

Fire Safety trumps GDPR on a legal bearing gone through this matter already

Saz Siddique

Hi Lysa - we asked our FRA assessor to develop the floorplans. We subsequently check them by going on site and checking they are accurate

Lysa Nicely

Thank you and the design of the plan , are they internally made and or made by and external provider

Saz Siddique

The plans are external - send me an email I'll provide further details.

Omar Amin

The information set out in governments EEIS consultation is very basic so as to not contravene GDPR

Paul Hayles

I'm certain I will be shot down - but this is a national issue (FRS) and so we should all be giving similar products that they can use - less is still more as long as they can use it - then complexity can come later

Christine Milling

Could Fire Service hold a couple of joint visits with RP representative. They would be able to figure out what a 2-page information sheets for the RPs building might need to look like

Saz Siddique

We have a list of all our GERDA boxes and the keys. Our FRS have been notified of the keys required.

Ellamae Fullalove

We use a peeps floor table plan with rag rating/ symbols (in the box not on the wall of course)

But I wonder if there could be a secret rag rating that only LFRS  know how to read if it were a visible doc  and so they can see it as quickly as possible

Ashley Mather

Apologies, Please don’t use the above link, use the link provided below instead

Clare Williams

6 weeks, meet again, sounds good.

Ashley Mather

To remind you, the consultation closes on Friday

Stephen Ackee

Little group meetings would be good if the group was more applicable to regions.