BIM4Housing – Presentation and workshop with the National Fire Chief’s Council-20220914_110203-Meeting
RICHARD I’ll start off with a bit of housekeeping. If you put a question or comment into chat, we’ll record this meeting and then produce a highpoint document (minutes) and points made in the chat will be included there.
GEORGE giving some context to the meeting. We had a pre-meet yesterday and Ashley sensibly asked the question ‘why BIM?’. The perception of many people is that BIM is about 3-D modelling, but actually the whole premise of BIM4housing and also the UK BIM alliance is that BIM is about better information management. To that end over the last few years BIM4housing has set up a number of different stakeholder groups that are interested in certain elements of the process and asked them what could be improved with better information. As a result of that we formed workstreams, one very serious one of which is Fire Safety.
I think a lot of the industry has not realised that we are now in a regulated industry. The Fire safety Act is obviously the driver for today. We’ve also got the Defective Premises Act which requires a different set of information had has significant implications for both landlords and contractors. And also, we’ve got the Building Safety Act, which is a different set of regulations again. One of the challenges with that is that we’ve also got other priorities that landlords are having to deal with (energy performance certificates, carbon reporting, decent homes, leaseholder protection).
We formed a workstream a couple of months ago which looks at the specific information needed to satisfy the fire plans for the 23rd of January. Gerda are producing clean, clear PDF documents that can go in a premises information box, but a challenge is that you can’t add to them, they are not editable.
I also chair the Golden Thread Initiative (asset and survey information group), we’re trying to determine what information is needed to satisfy the golden thread. As part of that process we’ve overlaid the new Gateways - and the Gateways aren’t just for the design and construction process, they’re an ongoing gateway where a building insurance certificate has to be added and fire is an important element to that (but it’s not just fire).
Within BIM4housing over the last 18 months we’ve had different subject matter groups come together to give us their knowledge of what information do we need for AOVs, fire doors, dampers etc. Principally the process that we’re taking is that if we know, from an asset management point of view, where a door is in the building and it’s performing in the right way from a normal maintenance POV we can also add additional information to it like safety and carbon. So, the principle there is better information can then deliver value for different aspects.
He refers to a document shared on screen. Here we have a basic asset management plan, but we’ve got the fire compartmentation on it and we’ve also got the fire doors. The point is that what we can do is present that as a simple plan for different people to be able to interpret in different ways. We can drill into the detail and also see whether the key properties are covered. The important thing is to be able to have things which we can add to.
Another challenge we’ve got is we’ve got terminology which is conflicting e.g. NBS alone have got 3 different ways of describing fire rating. There’s also a number of other data sets, including the new Fiery. There’s a number of ways that fire rating is being described, we need to get some degree of consistency and this is why we need things to be machine readable because if we actually look at what we are having to cope with, for building regs alone there are 800 references to standards and at the moment everybody has got to manually read them. We want them to be machine readable so we can avoid a lot of that complication.
Even if we’ve got good data sheets from manufacturers, those manufacturers have a number of different ways of describing fire rating. Humans can read those, computers can’t. Then we’ve got the same complexity with the test certificates. With that whole process you’ve also got to look at things in terms of ‘field of application’ to make sure that particular door is the right door in that particular wall. We’re finding that designers are having to sign NDAs to get that information.
It may be that we can rely on competent installers but in this particular example (an inspection done by a main contractor of their project) only 20 out of 89 doors passed the inspection (22% did not pass).
Within BIM4housing we’ve been bringing together subject matter experts to look at what data is needed for different purposes and then using that to then add classification and structure and domain expertise so that we can then use those on an ongoing basis in software. One of the examples of that, we’ve been advised by the HSE that what we’ve got to do is look at asset information from a POV of what’s it doing, what risk is it mitigating.
We ran a session at Digital Construction Week a few months ago where we had a particular set of examples (18 metre building, student accommodation). We had a spatial model, we identified that a fire could break out in a kitchen and generate smoke and looked at not just how individual assets but systems could actually protect against that. So the compartmentation, smoke control and detection systems. We were able to say to mitigate the spread of smoke we need compartmentation, list the assets that we need and this is the information we might need about those assets to ensure that they are going to perform properly.
At the in-person event at DCW we had 40 or so people at different tables that we’re representing manufacturers designers, operations teams and landlords. If you want to get involved, we have sessions coming up in the next few weeks. One of the things we need to do is take the guidance that is coming through, we’re interpreting the guidance from the documents. This is the sort of information, which is being required, not necessarily to deal with the legislation, it’s the code of practice which is the best way of doing it.
What we are trying to do as BIM4housing is to interpret that into a set of simple levels of detail (bronze, silver and gold) so that we can then encourage supply chains to actually be able to deliver back high-quality well-structured information that can then be built upon. It’s that building upon that the golden thread is so critical on. We’re working with a range of major different players in this area to make sure that they are willing to deliver the quality of information that’s needed to be built upon.
RICHARD introducing Matt Hodges-Long, founder of TrackMyRisks and the progenitor of today’s meeting having hooked us up with the Fire Chiefs Association.
MATT HODGES-LONG Thanks to Sandy and Ashley coming along from the NFCC today to share their latest thinking and their consultation. As a data person and really focusing on the document and file management end of this process and not the actual production of any of the underlying content but the how to organise it once you’ve got it and keeping everybody informed that needs to be informed, that’s my end of the spectrum.
Starting off with my guiding principles: the reason we are all doing this is to save lives, that’s ultimately the driver for everything that we do. Another key principle to work with is always around a single version of the truth, I get worried from a data perspective POV when I see multiple versions of the same piece of documentation flying around, whether that’s contracts being batted back and forth or compliance information.
Where there is a possibility of different versions of the truth to be out there and I think that’s very clear in the context of today’s conversation e.g. updating floor plans that George mentioned but making sure that the different stakeholders have got the latest version and how you actually manage that process.
Transparency: actually understanding does something exist, does it not exist, when did it change, who’s accessed it - all of those things that in my world are really important in terms of understanding how the nature of a particular document or artefact flows through the world from creation to replacement at some point and how that ties into the golden thread discussions.
Flexibility. George mentioned the different regulatory environments (who knows whether there will be others). We need to make sure that we are future proofing, so we’re not actually building something specifically for fire safety regulations and then missing the boat when it comes to the building safety act etc. so we to be able to point different stakeholders at different parts of our single version of the truth.
Hopefully it won’t get to this but this information could well become evidential, so whether that’s just from a regulatory visit or whether it’s actually after an incident, all of a sudden, we flip from a management system into provision of evidence. If you’ve got a discrepancy between your management system, or a lack of management system, you’ll find it very hard to deliver the evidence that is required when or if that’s called upon.
The other key point for me is keeping things as simple as possible. We can all look at a wonderful, automated AI future but the reality is we are a few months away from the fire safety regulations kicking in, and there is a requirement to share information. So I think this is very much an iterative journey towards what hopefully in the future will be largely automated, but at the moment we’ll probably start off with quite a lot of manual intervention and maybe (whenever possible) with as little duplication as possible.
Practical considerations. I think there are 43 fire and rescue services/authorities, so we need to think about meeting each of their requirements and how we interface with their systems that they may or may not have that may or may not be in the process of being re-platformed (like e.g. London). We really do need to think about information security. Back to the evidential point, we’re providing or submitting what could become evidential information but is also information that will be operationally relied upon by the fire services. we need to make sure that that transmission of information from one organisation to the other is as secure as is humanly possible.
Data integrity, we need to make sure that we are not describing the same building in 12 different ways. There have been discussions around postcodes, around UPRNs…there’s different ways of trying to describe the same physical thing in space, we need to be mindful of that. We need to think about the scale, we’re looking at about 13,000 buildings initially in terms of the enhanced data sharing. That’s an awful lot of buildings, sharing and manipulation of data, and a lot of double, triple, quadruple keying if we’re not careful.
Funding. There is a distinct lack of funding both on the RP side but also within the fire services and the Home Office. I mentioned to the guys in the NFCC the other day I’m quite surprised there isn’t some kind of licence or registration fee for an RP to pay to fund some of this activity, as far as I’m aware that isn’t there at the moment so that is driving a little bit of dysfunctionality. There’s a lack of clarity at the moment about some of the finer detail that’s emerging, we just need to understand that we don’t have all of the answers at the moment. Today is very much about bringing everybody together to share ideas and help shape what some of that additional clarity might be.
A point about secure information boxes (previously known as premises information boxes). I have concerns around those. The first thing to remember is that they are analog, they can’t talk to you, self analyse, or tell you if they’ve been levered off the wall, they are just a metal box. So we really need to think about how can we make that network of information boxes reliable. Will the crews rely on the content, how do they rely on the content. We need to think about the location of them, how we describe where they are in space. It should be obvious but it may not be - wouldn’t it be good if we could actually understand where they were? I’m thinking along the lines of what 3 words there to describe their actual location.
Content Management is a challenge. The underlying content of the secure information box could well change on a fairly regular basis. If that box is screwed to a wall 8 feet up, if people can’t find the keys, if it’s not built into a management process, there’s a significant opportunity for the content of the box to fall out of sync with reality. So we need to think about that and how we do it in 10s if not 100s of buildings within a portfolio.
We need to think about the Time lag and this falls into two aspects. One is the time lag back to
content management of an underlying artefact changing and how long it takes to actually
propagate that change on paper into a box on the wall in a building that may not have a
manager. But also the time lag of a call coming in and waiting for a crew to get to site, find the information box and then start analysing the information. so therein lies a lag of which some of that lag could be reduced by the information that’s been shared with the Fire and Rescue service electronically before, but perhaps not all. And then the other key point, sort of where I’m coming at this from, is that if you need to get the assurance around the content of a an analog box, you need something to compare it to.
And as we are talking here about electronic information and we will be producing this information on digital systems, it seems sensible to me that we have a digital twin of the analog box. So we have the digital box and we have the analog box and those two things should match in terms of their content. It’s just something sort of leave the group with to think about.
So what have we done to respond to this whole situation? A couple of things that we’ve done, we set up fairly soon after fire regulations were published an online resource centre, if anybody wants a free invitation you can contact me and I’ll get you invited to that. We’re trying to track fact sheets, the guidance, anything that is sort of official. Also, if anyone has any additional artefacts that they would like to put in to there (as long as they are coming from an official source) send that to us and we’ll get that put in and we can simultaneously invite all 500 people to access that new piece of documentation.
That’s response number one, response number two is very much playing around with soak testing our platform. Some years ago we created the Building Safety Register, there are just over 3,600 buildings that are on that register now. Each one of those buildings has some form of logbook information about it, it might be a copy of an EWS1 certificate, a fire risk assessment, might be a lot of information. They are all organised and searchable within the register, they’re all related back to UPRNs etc. This is where we’ve been testing a number of ideas, one of those is around a digital information box network.
This is operational in the sense that you can’t actually read any of the content, it’s all security controlled. There’s an opportunity to throw all of these buildings onto a map and to be then able to interact with the content that is held digitally. If it was the information box content, in theory that could be accessed by fire and rescue services and other stakeholders in the event of an emergency. If there’s anybody on the call who would like to chat about this in more detail and think what could we do this as a pilot I’d be happy to take you through that.
RICHARD question via chat: The first one, George, is from Darren Baird - The biggest challenge you will face is when the data is captured it will need to be integrated into housing management software systems.
GEORGE No, absolutely, that’s exactly what we’ve been doing. The importance of the structuring of the information is that we are creating it in a machine-readable format that then can be used within any software application so we’re trying to keep that absolutely agnostic.
RICHARD question via chat: Debbie - What about traceability to the requirement in a standard or regulation for example?
MATT If it’s regarding traceability of the documentation that’s uploaded, from our perspective we activity log absolutely everything. We know who put an artefact into the environment, who replaced it, changed the date etc. In terms of the fire safety regulations that’s the key point about the traceability of evidential information provided to the fire service - who provided it, were they entitled to do that, are they are responsible person, or is it just a resident who randomly thought they could upload something for fun.
GEORGE answering the same question on the traceability the golden thread traceability that he may be referring to, that’s something that we can cover separately. It’s very much that type of traceability of the information itself so that we can track whether things have been done and also whether the data is being collected properly is something that we are covering.
RICHARD introduces Sandy Thomson and Ashley Mather from the National Fire Chiefs Association.
SANDY (ALEXANDER) THOMSON Thank you for giving us the opportunity for us to share with you our proposals on how to best share information that is required by the forthcoming fire safety Act. Myself and my colleague Ashley Mather are both part of the service delivery improvement team within the protection policy and Reform unit of the National Fire Chiefs Council. The NFCC is the professional voice of the UK fire & rescue service. Our dedicated staff have come in not only from the fire and rescue services but also from other areas of the public and private sector.
Each fire and rescue service has its own sovereign identity within England, Scotland, Wales and Northern Ireland. There’s a total of 47 separate fire & rescue services across the UK. Our aim is to drive improvement these UK F&R services whilst supporting strong leadership. We strive for continuity and best practice in all the work we do and as such each F&R service subscribes as a member of the NFCC. We aim to work together and everyone offers up sector-led solutions.
The PPRU area was initially founded out of the Grenfell tragedy where it was apparent,
following the findings of the inquiry, that the fire sector were not as efficient as shared in learning
and best practices that could have been. Therefore, we have now developed a highly skilled team of fire professionals, including fire engineers who sit on British standard boards review and influence new government guidance and legislation, and deliver new learning and guidance to all of the protection functions within each fire & rescue service.
Then, after passing through Parliament last year and the Fire Safety Act 2021 was implemented on 16th May 2022. The Fire safety England regs arising from it were laid before Parliament on the 18th May and will take effect as of the 23rd of January 2023. The regs are legislated under Article 24 of the Fire Safety Order, the power to make regulations about fire precautions and their purpose is to implement the majority of those recommendations made to government in the Grenfell Tower Inquiry phase 1 report which require a change in the law.
These regulations will make it a requirement and law for responsible persons of residential high-
rise buildings to provide information to Fire and Rescue services which will assist them to plan
and, if needed, provide an effective operational response. Some of you have maybe seen this graphic representation of the requirements of the regs before, which show the various legislative requirements for an RP depending on the height of the building in question.
In general, the regs will encompass all residential buildings with two or more domestic premises
and common areas. However, the legislative requirements for those of 18 metres and seven
stories and more will be far more onerous in line with the additional risk the height of the building brings and within the list of requirements listed it is the need for to digitally upload specific information.
These requirements set out within Regulation 7 and 11 of the regulations by which the RP
is required to forward specific information electronically to their local Fire and Rescue service.
Now Regulation 7 is under the lifts and essential firefighting equipment and (reading from the regulation), 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 practicable, report the fault to the local Fire and Rescue authority by electronic means and report the rectification of the fault to the local Fire and Rescue authority by electronic means when it has been rectified.
Regulation 11 is provide provision of documents to the fire & rescue service authority
And responsible person in relation to the high-rise residential building must provide a local Fire
Rescue authority by electronic means, with the document specified in Regulation 5, the design and materials of the external walls and regulation 6 with floor plans and building plans.
Our initial concerns centered around the lack of guidance within the draft Article 50 guidance for
the regs about how and what detail this information should be passed through to Fire and Rescue
service Article 50 guidance, basically the guidance the government must produce when
producing new regulations and that will be available shortly. With no clear guidance there were concerns of the responsible persons carrying out large data dumps on fire risk services to fulfil their legal obligations under the new regs, leaving some Fire Rescue services with large amounts of documents to trawl through to find the relevant information or quite possibly not even receiving the actual specified information required which would aid in their operational plans in reducing risk of tackling an incident in a high rise residential building.
So the scope of our work after consulting with the Home Office, we have taken on a role to
produce a suite of templates for the capture of specific information for each regulation, and also
produce Clover non Article 50 guidance where appropriate. Our goal is to produce a format that
all RPs could easily understand and upload the required information in a quick easy format
and one which all Fire Rescue services can set up. This will give RPs a consistent experience
whichever Fire & Rescue services they make contact with. It will also give each fire & rescue compatible and relevant information in line with the desired objectives of the regulations and the
So what are our limitations? Well, we haven’t been given any budget, the short time frame we have until the regulations become live, which is in the 24th of January next year. Now utopia would be that all English Fire Rescue services would have a common digital platform in place to be able to gather all this information. However, unfortunately that’s not the case. So we’re trying to develop templates for 43 different Fire Rescue services across England, all with varying needs associated with the new regs and all who have varying software and risk information platforms in use already with different ways of how they move important risk information around their services.
Shares document on screen ‘Potential Workflow of Information’. Now this will give you an insight of how the information you would be supplying would be used by a Fire and Rescue service depending on the internal systems available to that fire and rescue service. This is where the challenges for each of them will be highlighted as much of this work will have to be done manually, although there are a few services currently looking and manually of overheard a few services currently looking at developing a platform which will do most of it automatically.
Now I’m gonna pass you over to Ashley, who will go through what the templates we’ve put
forward and the proposed test website and he will be consulting with you shortly how
we’re going to do this. And just a note, we do see us as an interim solution for some Fire Rescue services, especially London and other metros. London for instance, has over 60% of the buildings are in the scope and some fire rescue services are already building your own platforms to receive this information and to move efficiently to move efficiently around the service. So while we encourage this, we’ll be asking each of them to be using the same sort of Bank of questions so
we get continuity across the sector.
Also, with some of the larger housing providers a more bespoke solution with your local Fire
and Rescue service to initially gather the information, especially on the external wall design and
reports and the required plans may be an option for you.
ASHLEY MATHER, I want to show everybody what we have proposed. The NFCC, we aren’t a fire service, in the future when the regulations go live, we will not be collecting any data from anybody. However, the fire services are what we’ve put together is a dummy webpage so fire services and RPs can perhaps visualise how this system around information sharing might look going forward.
From each fire & rescue service perspective there will be some technological limitations to our suggested solution, ultimately, they’ll probably want systems that are fully embedded and integrated into their existing systems, but from a functional perspective we’re happy we’ve got a day one solution that should satisfy the needs of all stakeholders should the FRS choose to adopt this solution. This is very much a suggested solution, and certainly the smaller fire services that haven’t got too many high-rise buildings on their patch should probably work with the longer term.
There’re three elements around the information sharing. On the website we’ve got an example of what each fire service could look like including the branding. regarding the flaws in the building plans it’s a very basic level…recognising the limitations of what we’ve had to work with e.g. no money and no software, we’re not actually proposing anything beyond fire services providing a dedicated email address where RPs can send the plans to. However, we do recognise the need to provide some guidance around that, so matters such as the electronic sharing plans, file tabs, file sizes, if the local fire service has a clear expectation (or indeed limitations based on their IT) they’ll need to set them out for the RPs to refer to. For example, the IT systems that London use (at least on the trucks) they can only accept JPEGs. It will be down for the fire service to specify the technical side of the files being sent over.
Going back to guidance about floor plans, earlier we referred to the code of practice for the provision of premises information boxes in residential buildings. The announcements for the regulations this summer was due to commence in January next year sounds like a really quick turnaround, it’s coming shouldn’t really be a surprise, given it formed a key recommendation of the Phase 1 report of Grenfell enquiry.
Ashley shares on screen a ‘Code of Practice’ document. Not long after that NFCC in conjunction with FFIA, we put this together. The FIA are a fire protection trade association in the UK, no direct relationship with the NFCC but as organisations we share similar values as we try to promote best practice in fire safety and standardised approaches across the country. This particular one, we can see it clearly from the two sides of the fence, from the fire service wanting to receive information that is relevant, detailed enough and useful for them and then the RPs and building owners trying to collate that information together.
This we published last year. Premises information boxes are exactly the same as secure information boxes referred to in the regulations. The requirements and perhaps the expectations of this best practice guide do go over and above what’s set out in the regulations. We’ve no intention at this stage to provide what in effect would be a watered-down version that meets the very minimum requirements of the regulations. Appendix A of the guide provides a lot of information on the building plans.
Some of the terminology is slightly different, the orientation plan closely aligns with the building plan referred to in the regulations. There’s a lot of information on there as to what would represent the best practice in regard to the quality of the information that’s provided on the plans, the level of detail. This guidance has been out for over 12 months now and there’s no intention to anything else that perhaps aligns it more closely to the very specific requirements of the regulations. For building owners, that’s the starting point, if you want to do the bare minimum then you’ll just have to refer to the regulations. That’s all we’ve got around the building plans, ultimately it will just be an option to submit an email.
Moving on the wall design. I don’t know how many people have seen the draft guidance that went out in support of the new regulations. It included a template at the back which was one method of suggested form and how the information required on the design and materials of external walls will be provided. From the NFCC perspective, the very simple open-ended question around provider information on external walls was very open-ended. Concerns that the quality, the relevance, the level of the detail of that information provided could vary considerably for the reports that are coming in and we wanted to take an approach that perhaps standardised that by asking perhaps a more closed set of questions. That does come with its own challenges and that’s part of the reason why we’ll be going out to consultation with this.
To reiterate, the Fire Safety Act has already clarified that the external walls will fall under the scope of the fire safety order and accordingly, based on the level of risk, information on the level of risk created by the walls should be in the fire risk assessment for your building anyway. Depending on the nature of the construction, if the fire risk assessor isn’t able to draw conclusions on the level of risk accurately, he may suggest the need for an additional fire risk appraisal of the external walls. The outcomes of that appraisal would then be fed back into the fire risk assessment. Risk appraisal is what is possibly going to be referred to as the PAS9980 reports going forward. Ultimately, all that information on design materials of external walls should be captured and known. And if it’s not because you’ve not got around to your more in-depth survey so, be it, but it’s a requirement so must eventually be done.
From the NFCC’s perspective, although we consider the information that’s required on the walls, that record required by regulation 6, to be different from the risk appraisal of the external walls, some very early consultation with housing providers raised some concerns that they felt that requirement/obligation under regulations could be fulfilled by simply sending over that full report. From our side that caused alarm and concern - fire services don’t want that level of information; it would be very onerous then for the fire service to go through those reports and extract the information we need. There’s also the risk that that could be misinterpreted. So, that’s why we’ve proposed a more simple structured form that we hope can capture all the detail that we need.
As an IT solution what we’re proposing is the use of Microsoft forms, these are all going to be hosted on the respective fire service websites. Really, whilst the IT solution may ultimately vary from fire service to fire service what we’re really trying to get across is the benefit of everybody (building owners and fire services) we really are trying to standardise that question set.
Regarding the External Wall Report, let’s look at some of the more focused questions. We captured some basic information on the building owner and responsible person and from a fire service perspective, one of the issues we had with a suggested wall report that was in the draft guide was it tried to put a label on the level of risk of the building (high, medium or low).
Whilst we accept that needs to be part of the fire risk assessment for operational crews, there’s a fire service. Actually the risk of external fire spread potentially varies considerably over the elevations of a building. You might have large portions of non-combustible, low risk construction with pockets of high-risk flammable material that’s a hazard and the fire service would need to be aware of. So just capturing low risk and not actually an overall statement of low risk without capturing where the pockets of risk was our concern. We tried to put together a form that looks at the walls in a more discreet manner, where we’ve got different methods of construction on different sections of wall.
The question set was initially very large. We tried to be honest and fair about what information we’re gathering and for what purpose. That purpose is really to inform the operational response, it’s not really from a regulatory side in terms of our inspecting officers wanting to know the make-up of your walls, it’s what is that overall risk and can that be interpreted by the troops on the ground in the event of a fire. I’ll go through a couple of quick examples so you can see how…we’ve created this form in a way that hopefully if you’ve got low risk buildings the level of information that’s provided is minimal and with high-risk buildings we’ll ask for more information.
A large number of you will have low risk concrete traditional masonry buildings and the risk of external fire spread is very low. Here’s an example, external walls using traditional masonry materials with no finish over the top, there’s no other wall types, and that’s really beyond information around wall features and attachments very much form part of the overall wall design.
Again, only asking for information if we feel that those balconies and wall attachments contribute to fire spread. That’s really all the information asked for, a low-risk building with no additional fire risk appraisal, no additional measures. And there is just some information…just to capture the information for the person completing the form. That would be submitted and the person submitting the form would get a confirmation email.
We’ll look at some non-standard non-traditional wall construction. It’s not built using traditional masonry and I think we do recognise…one of the reasons where we will be consulting is where there is perhaps confusion in meaning of these questions about the information we’re trying to capture. We’re talking here about more modern methods of construction, so looking at wall systems rather than a traditional wall. This is where we start getting into more detail, but we’re only asking for information that should already be known. We’re very warty building owners have been asked these questions many times before but this may be the first time we’ve been mandated by legislation to provide that record.
The external facing wall material, let’s call that ACM, but as an RP we’ve done our report and surveys, we’re satisfied the ACM is not the flammable stuff, we’ve satisfied ourselves that the sections of wall when considering the insulation…that they aren’t contributing towards fire risk. Again, from recognising what the crews need to know, that’s about it. But let’s say we’ve got a with some timber on there that’s actually got different type of insulation behind it which actually is going to contribute towards fire spread, and that’s where we expect that more information to be provided. We can provide as many different discrete wall types as may appear in your building, but once we get to the end we then go back on track with the standard questions, provide details on the attachments and highlight where they are going to contribute to fire spread.
These are the questions that we are explicitly required in the regulations themselves, so the question around the overall level of risk of fire spread due to the design of the walls. That highlights that we could have a low-risk building that’s got combustible materials on there in pockets where overall risk is low, and that’s what we’re trying to differentiate against. And again, the mitigation message is a specific requirement of the regulations themselves. You’ll be able to all have a play with these forms. One thing we’ll certainly say, as well as asking for information/ getting your thoughts on the questions being asked we’d encourage you to try with real buildings (you don’t need to name them) but from our side we can see then what that information is being captured: is it the information that we think we’re asking for? Are we getting what we expect? Is it useable and useful? Because if it’s not we’ll have to change it.
We’ll move on from the walls to the faults and the repairs. The information is quite as set out in the regulations around the equipment that is covered and we’re proposing two similar forms that can be used by building owners RPs to report details on the faults in their buildings. A similar structure to the previous form. The seven types of equipment that are covered by the regulations are set out there, it’s about gleaning the information that we think that can be used to help and inform the fire service. For example, we’ll pick the fire detection and warning system.
For some of these questions we’ve thrown in a very simple high-level question that just provides a bit more information on the system in question e.g. with a fire alarm system you might jump straight in there with information about the fault, but actually it’s quite pertinent to frame the nature of that fault: is that fire alarm used to alert occupants? Has it got sounders or is it a silent alarm just to support the protective measures? The standard page that exists for all the faults regardless of what equipment you are reporting the fault with information of the nature of the fault, its location, and we’ve also put in there an estimated time scale for repair.
Again, we acknowledge that’s not required by the regulations themselves and it won’t always be known by the person reporting at the time. It’s there to inform operational crews but if we had a fault e.g. the sprinkler system in your building was going to be down for a period of weeks or months that’s going to inform a regulatory response as well. The fire services might then choose to forward that on to the inspecting officers, so if you know you’ve got an issue that’s going to be fixed quickly, I’d suggest that helps all concerned.
Regardless of the equipment of fault we’ve got a couple of questions in there around mitigation. The key one (though it’s a very unlikely scenario), if part of the mitigation for the sprinklers being down means you may have to implement a temporary change to the evacuation strategy, that really changes things so there is a mechanism in there to capture that information as well as an option to provide details of any additional mitigation measures that you may take. And then we’re back down to the information about the person completing the form. We’ve tried to put a disclaimer in there around the person completing this report is acting on behalf of the RP. if you’re a member of the public you should be speaking to the RP themselves or if you do want to report to the fire service there are different channels to do that.
Upon submission of the fault report when you submit it asks for an email, that will send an email out as a confirmation with a reference number. Once your fault has been repaired, we can come back to the same website and you can enter and use that full reference number when you then report that rectification of the fault. it won’t be a requirement if you lose it but, again, it’s really about trying to align any repairs with the faults themselves.
We’ll be conducting a formal consultation within the next couple of weeks so they’ll be available to all. We’re consulting with fire services and housing providers. ALEXANDER THOMSON responding to Richard’s question about how members of housing associations etc. can get a look at it: We can easily do one of two things - we can send it to yourself direct and you can pass it around….
ASHLEY The rectification of the fault, it’s all about really just trying to align that repair with the original fault. You might report a slightly different address, the description you provide of the equipment or just even an input area, so we’re just trying to put enough information there to satisfy yourself that we can line up the repair with the fault. So again, just capturing whether you’ve adjusted the mitigation measures and once it’s submitted, you’ll get a confirmation email. That is the extent of what we’re proposing, as a quick summary, so we’re really consulting and we will be going out there to try and identify the suitability of the forms themselves from an IT perspective. We certainly try to get an understanding of the questions being asked. Whilst we were looking at feedback on the questions themselves the actually people trying to use these forms to provide data so we can actually make some decisions based on the information we actually get from them will also be used to further inform any finalisation before we actually fire this out to all the fire services.
RICHARD We have a number of questions. Paul White asked what is meant by essential firefighting equipment? does it include sprinklers and smoke control systems?
PAUL WHITE It has been covered in the chat and I think it came up on one of the slides.
RICHARD Paula Chandler asks should there be a section related to modifications by the tenant or landlord? And would this, where it might impact on the integrity of the building? ASHLEY MATHER I can only assume that’s in relation to the plans…or the walls. In both instances there is a requirement to make sure they are up-to-date where those modifications are being made that are discernibly outdating that information that’s been provided already the expectation would be that an updated version has been provided. I don’t think there’s anything that sets out what is different from the old one needs to be highlighted. Obviously, I think that would be useful accompanying information when the information is provided to the fire service as it helps to understand what’s changed.
GEORGE One of the things I think Paula is referring to is within Bim4housing we’ve been running roundtable workshops on most of these situations and it’s very clear that it’s often tenants doing things, without realising that they are compromising the integrity, that can have an impact. So if that’s happened it does need to then be recorded so that until it gets resolved. It’s particularly important in terms of internal compartmentation. ALEXANDER THOMSON Hopefully any kind of new work done on any of these buildings will be picked up by the building safety regulator going forward as well.
GEORGE Yes, if it’s formal, but what we’ve found is, for example, people will put letter boxes or cat flaps in, or if someone redecorates their flat and they paint the front door that can compromised the integrity. So people do things by mistake and that can have an impact. ALEXANDER THOMSON There’ll be further guidance coming out within the Article 50 guidance about checking fire doors as well so a lot of that should be covered within the additional guidance.
SAILESH PARMAR My first question is around the accuracy of the floor plans that would be uploaded to the FRS pages. Yes, obviously there’s a responsibility for the business or the client to make sure they are up-to-date, but I think the world we live in (in terms of the construction industry) things aren’t always as they appear to be. That’s the first challenge I think we’ve got from both ends; how do we confirm that and do we think that’s going to be a robust enough system in place to ensure you’ve got the most accurate information about the buildings in terms of floor plans.
ALEXANDER THOMSON I guess that’s kind of down to you as RPs to ensure that’s correct, really. Ultimately, we can’t go out and check every building that comes through to check on the floor plans. These plans will be arriving at the forefront of an operational incident a lot of the time and while, yes, through visits familiarisation visits it will be checked at that point, as we know some plans which are in place already are very detailed architectural plans which are not of any real use in an operational incident. That’s why we go to the FIA guidance on how these plans are put in place.
I’ll be honest with you, while the government have a real digital agenda to have these plans available digitally to us, in essence I would say the vast majority of services would be picking the plans out of the premises information box, the A3 laminated copies, and using them at an incident because most services will not have the digital software to use an effective plan on a laptop etc. whatever the requirements are going forward that hardware isn’t really in place yet. So currently the most important thing is that hard copy is up-to-date in your premises information box. You go through the guidance of having at least two copies of laminated A3 size plans available and that will be a far greater advantage as we stand right now. As we go forward with the digital program and services, the digital side is being driven by the government without the financial backup up to make it so.
GEORGE the critical thing here that speaks to what Sailesh is talking there, a lot of the reason you end up with information that isn’t correct is because you’ve got fragmentation in terms of the way it’s done. E.g. the fire plans may have been done 3 or 4 years ago, subsequently additional work has been done but the fire plans haven’t been updated. We need to get to what we’re trying to do with the collaboration within Bim4housing is have it so that it goes into a set of information which can then be presented and printed in lots of different ways according to the different stakeholders.
We’ve got a combination here, Sailesh, not just of the fire plan, it’s also the building safety register…it’s the other drivers, including decarbonisation for example, because a lot of the activities that are going to be carried out are probably going to be around energy and therefore if things ar changing within the building we need to have ways of automatically updating
the information. As Matt said earlier, what we don’t want is the wrong version of the plan because that is dangerous.
MATT HODGES-LONG I know today is talking about RPs and fire & rescue services, but there’s another key stakeholder in all of this which is the information sharing with residents. When we’re looking at evacuation plans, which would include floor plans etc., there is another reason for this to be up-to-date. I guess if you give them a plan of a building that doesn’t reflect reality, I would imagine a lot of residents are going to be straight onto you anyway saying ‘why have you issued this, the fire door isn’t there anymore=, it’s moved’. So, although today we’re focusing on 2 of the 3 stakeholders there is a 3rd one that we deliberately didn’t bring into the conversation today because it would just confuse the whole…maybe it’s a topic for another session, George, but for today just think that there are multiple recipients of that information that you guys are going to be putting together and sharing.
GEORGE What I would also say is that I see this as being an initial meeting that we can then run additional session over the coming months which will allow us to share the knowledge that we are experiencing. I was talking to a Local Authority last week who are just producing very simple Excel sheets using the cells to designate the apartments and the common areas, they are not producing drawings. They’re doing this because they don’t have the budget to be able to do proper plans. That obviously has got limitations, but I can understand why they are doing it. It maybe adequate for the purpose of making sure you’ve got something which is up-to-date.
DARREN BAIRD From my POV, dealing with a lot of housing providers predominantly in the North-West there’s massive confusion over the extent of the extent of the external wall where the phrase of ‘2 dwellings or more’ - being pedantic, that could apply to a terraced street. We’re getting enquiries from ground or first floor blocks of flats, a little bit of plastic or UPVC in between the 2 windows, the clients asking do we need to do a PAS9980 report on a block of flats, I don't think there is enough clarity out there to say to RPs yes or no, and we’re experiencing that on a daily basis.
ALEXANDER THOMSON One of the slides I put up was a graphical representation of what areas these regulations cover, which is in the chat (see addendum), and hopefully that makes it quite clear that it’s for design materials of external walls in the context of these regulations it’s only for buildings over 18 meters or several stories.
DARREN i get that, but what I’m saying is you’ve got clients that are wanting to exercise due diligence where they’ve got buildings that are under 18 meters, I understand that, the threshold, but they’ve still got something on the wall that may contribute to external fire spread and the answer is what do we do? Do we get an expert to determine what that is, do we just take it off. I’ve got clients with waking watches on 4-storey deck access blocks of flats with a rendered system on the wall with an external wall insulation that is potentially combustible. they’ve had a 9980 report done and there’s a waking watch in place at £10,000 a week - that’s what’s going in on in reality with RPs out there. We need to nip that in the bud, get some clarity out on that.
TOM SPENCER picking up on Darren’s point, there’s a real problem with this, particularly where you’ve got leaseholders who are trying to buy and sell properties in buildings that have got some sort of cladding system on, whether that be small or large area. The risks decision tree on the risks website is misleading lenders and valuers when going out to these properties and making their assessments and coming back to landlords and owners of buildings and asking for additional information on buildings that are not in scope. it’s causing confusion against the guidance that has been given by the government. There’s a whole raft of issues with information around cladding systems and what’s on a building and where it should or shouldn’t be asked for.
DARREN I totally agree, what tends to happen is that comes back to the risk assessor almost to decide - well. we’ve had this report, the RP says this, what do we do, and the FIA guidance…unless I’m a qualified engineer or chartered, we’re not allowed to comment of the performance of an external wall. The whole thing sees a bit of a mess. Yes/ there’s clarity on there on your 11 meter and 18 meter buildings, but it’s the ones that are below that that we desperately need further clarification and guidance for RPs. If they’ve got, literally, a 2 X 2 meter piece of plastic in between the ground and first floor windows what do they do. Because, strictly speaking, I’m not allowed to comment. So the RPs can get someone to investigate what that timber cladding is they’re taking it off. Or, worst case scenario, waking watch is going on. It’s just crazy, it’s a waste of everybody’s money.
GEORGE One of the challenges here, it’s very similar to what we’ve got with the golden thread, that is the regulator is looking at things from the POV of the industry explaining to them why is that building safe. They won’t be prescriptive in terms of saying this is how you make it safe. I don’t think we’re going to get explicit information, it’s up to the industry to actually come up with solutions and that’s what we’re trying to do here, getting the community to say what does good look like.
ALEXANDER THOMSON from my perspective it’s really about competency in the sector that comes through risk assessments of the external walls. A lot of people out there are defaulting to risk averse and we’re ending up with waking watches on buildings that probably shouldn’t have them at all. The risk assessment should be taking the whole building into consideration and what’s in the building, not just the external walls. There’s a lack of understanding as Darren said, that probably needs clarification from the government on certain areas around that.
ASHLEY i believe there is separate guidance coming around to support fire risk assessors on making basic assessments on these smaller low-risk buildings. It’s probably not going to be a silver bullet, I think we’re still going to confusion once that’s out, but there is certainly stuff being worked on that really should have been out already, recognising that the fire safety act is already up and running now, but it’s taking until then for that need to be recognised.
MATT From an information sharing perspective that’s a requirement from the 23rd of January, that’s when the clock starts at the latest point. We were talking the other day about fire doors, my understanding is that the go live should be on or before 23rd January 2023, is that right?
ALEXANDER THOMSON The regs go live on the 23rd and we discussed the 12-month thing for some of the elements of it. All RPs should be ready to be making arrangements to start processing that information to local fire services from that point. We’ve encouraged fire services to start consultation with the larger housing providers within their remits to gather this information because we understand what we are proposing here will not particularly be…there’ll probably be quite a workaround for some of the larger housing providers with numerous properties.
But, we’re not saying to the fire services…talk to your local fire services, consult with them about how you want this information to come through. it maybe if you’ve got quite a lot of premises within that sector you could gather the information in a different way. What we’re trying to do with the question banks and everything is to get that consistency. it doesn’t matter what fire rescue service you go to; you’ll be having a similar experience in what you are getting asked for and what information they are expecting from you as well.
JAMES We’re all talking in this whole Building Safety Act and the regs all about specific heights of buildings (11 or 18 meters). One thing everybody seems to be forgetting here is we’ve got something out there called CDM regs. The CDM regs are a mandatory set of legislation that have been out since 1994. Now, the CDM regs basically take the height of the building clean off the table, so nobody seems to be understanding this and bringing this to the table because risk assessments, even as it says construction, design and management, it’s the management side and design that when you look at principal designers and principal contractors It talks about all known risks and designing out of all known risks. So when you look at that point, then the 11 meter and 18 meter rule goes clean off the table, that’s where the rules go that
if you look at. My comment is, has the people actually agree that the CDM regs are not being taken seriously in terms of this whole thing to do with heights of buildings and risk assessments?
GEORGE We’re on the case with that, James, if you want to message me afterwards, I can introduce you to Steve Coppin who is a CDM specialist.
RICHARD asks Matt and George to briefly finish off the meeting.
MATT I’ve put my contact details in the chat (see addendum), this is just a thank you to me from the NFCC for coming, being so open with us and for over a hundred people joining the call (which is amazing) at a couple of days’ notice. Thank you.
GEORGE From my perspective, I’d like to use this as a baseline for us to move on. If you’ve got any ideas that have come out of this, what we’ll do is transcribe the information and distribute it. we’ll pick out form there some key topics that we can actually follow through with and we’ll run some sessions over the next few weeks or months. We think that collaboratively we can address these things.
RICHARD Excellent, excellent. We will be in touch with everyone. You’ll all receive video links, transcriptions and all the presentations, everything, a complete package. So I would just like to say thank you, Sandy and thank you, Ashley. Excellent. I’s been very, very valuable. Thank you very much indeed.
Emma Burton : We are getting Gerda pans in Visio so you can amend.
I mean plans!
Ian Cavanagh : 22% compliance of fire door installations is much higher than the average we witness.
Debbie : Matt what about traceability to the requirement in a standard or regulation for example
Darren Baird : The biggest challenge you will face is when the data is captured it will need to be integrated into housing management software systems
Paul Hayles : SIBs need to be stored in the cloud and physical.
FRS should be doing familiarisation visits and make their own record of where it is
A good start would be a file naming convention so that SIBs are unique
Simon Reeves : Are premises information boxes and secure information boxes interchangeable terms for the same thing? If so we have two terms knocking around, the aim being standardisation and hopefully reducing jargon.
Paul Hayles : I feel the physical SIB is not for the local FRS rather any supporting response
Yes I believe the move has been to end on secure info boxes as a better description.
sounds like FRSs' will get a lot of information about broken lifts
Richard Hennelly : Will there be a central contact centre to provide such information?
Paul Hayles : that is an excellent question
Sailesh Parmar :
- With the Fire Regulations coming in January 2023, do we actually think we'll be ready and is there a grace period? How does this coincide with the requirements of the BSA - Golden Thread?
- Are there plans for a standardised national system/software or businesses use whichever system/software achieve the same objective?
James : Is the "RP" the same as Building Safety Manager?
Paul Hayles : if the BSM has the ability to deal with any matters arising
Omar Amin : A request to set up a secure central submission platform for relevant documents was made as part of the G15 response to the EEIS consultation.
Neil Wilmer : Regulation 7 - can you expand on the requirement for lifts which asks us to check "lifts for use by fire fighters" which is then expanded and states "firefighting lifts as well as fireman’s lifts" . Is it your view that all lifts need to be checked or just those that are firefighting lifts?
Ashley Mather : The regulations refer to firefighter lifts and evacuation lifts only
Fisher, Mo : ADB June 2022 amendment coming into force 1st Dec 2022 refers to SIB
Matt Hodges-Long : PIB is a trademark owned by Gerda. Perhaps this was the reason for Govt going with SIB?
Richard Hennelly : Even now apart from LFB, we find it difficult to supply information to FRS due to file size/security restrictions.
Darren Baird : There really needs to be some clarity around what level of info needs to be shared where there are "2 or more domestic premises" as defined under the FS Act. i.e., in respect of EWS or RP's will be sharing info on domestic houses where there are 2 or more dwellings with small areas of UPVc under windows or sections of timber cladding.
Paul White : What is meant by essential firefighting equipment? Does it include sprinklers and smoke control systems?
Paul Hayles : That would be in ADB
Paul White : I mean in terms of this requirement, there should be a list.
Neil Wilmer : Read
Definition of “essential fire-fighting equipment”
What the regulations mean by “essential fire-fighting equipment” includes both equipment provided in buildings to fight fires and important fire safety features and facilities. The regulations provide a clear list of what a Responsible Person will be required to check. These are:
- lifts for use by fire fighters
- evacuation lifts
- inlets for dry-rising mains
- inlets for wet-rising mains
- outlets for dry-rising mains
- outlets for wet-rising mains
- smoke control systems
- suppression systems
- fire detection and fire alarm systems including any detectors linked to ancillary equipment such as smoke control systems (in the common parts),
- evacuation alert systems
- automatic door release mechanisms linked to fire alarm systems
Responsible persons will also be expected to report on any damage they discover during checks to the firefighting shaft during construction activity or by any other activity, such as vandalism (removed doors, smashed glass or other failure that allows smoke spread).
Darren Baird : This is an urgent clarification IMO.
Alexander Thomson :
Paula Chandler (RDD) : Should there be a section related to 'Modifications' by Tenant or Landlord as this could impact the integrity of the building safety also.
Ana Matic : Who is providing training for the RPs and the Fire Service?
Paul White : Smoke control systems are essentially passive waiting or an alarm input. If not tested they will not show a fault! Look is like we should have auto testing built in...
Will Perkins : Yes Paul - that needs to be the direction of travel for smoke vent system product manufacturers
Sailesh Parmar : I think there will be challenges with "As Built drawing plans" and what is "actually built". This will be challenging to both sides. So, Accuracy will be in question constantly.
Paula Chandler (RDD) : Looks like a logical starter for ten but seems light IMO when we consider that the Stage 4 Technical Design should be complete ahead of start on site. Are there any definitions as to what constitutes a full Stage 4 design and the extent of deliverables that should be made available for review by the authorities (i.e., Fire Strategy, details of PFP/BWIC, integration of all CDP etc.)
Mike Smith : Hi Ashley Mather can you just clarify that a PAS 9980 report will satisfy the Wall information?
Paul Hayles : probably the outcome and something to link it to the 9980 process.
Darren Baird : Traditional masonry construction? You can't always tell? what about brick slip construction etc
Paul Hayles : agree we are conducting in depth surveys and traditional construction is a simple term
Sailesh Parmar : When receiving the external wall info, will this lead to operational crews carrying out SSRI's and producing Op's plans? Or is this simply data collection?
Alexander Thomson : Hi Sailesh, it shouldn't do unless the information provided is highlighting a building that is not already deemed high risk. This information is for Operational crews to identify quickly areas of external walls which present a higher risk during an incident.
Buckingham, Roy : If App Doc B will refer to this terminology then the FIA CoP for PIB's will need to be changed to reflect this and fall in line to avoid confusion.
Sailesh Parmar : Also, how do you anticipate businesses provide information on walls when they are remediating walls, so for example, would you want exiting initially, then the remediated version after? Will the FRS's ensure that the information is updated?
Darren Baird : But we are seeing 9980 reports being done on a rendered EWS with an EWI in place. RP's are confused over the level of detail required where they have EWS that are not ACM, HPL or similar high risk EWSs
Ihsan Hoque : This will require some structuring and training in HA's repairs team.
Omar Amin : Can/will this be extended to include vulnerable resident information (PEEPs/PCFRAs) under the Emergency Evacuation Information Sharing consultation proposals?
Alexander Thomson : This is currently outside the scope of work with regards to these regulations. However, as the work develops on Simultaneous Evacuation strategies then this may well be a solution.
Mike Smith : Ashley Mather is the test page up and running as would be great to complete some dry runs.
Alexander Thomson : Hi Mike, yes it is. The consultation will be out to you all, hopefully by the end of next week. You will be encouraged to try some 'dry runs'. Hopefully the experience will be straight forward, but we are aware of its limitations if you have multiple buildings to report on.
Paul White : If you find a fault with a smoke control system, do you report it yourself or advise the RP to do it?
Matt Hodges-Long : Not included in the Regs but I would include the SIB (Content and Condition) in the monthly management check and report it if it will be out of action for more than 24hrs (not sure if FRS want this but it seems like an omission)
Christine Milling : Are you going to have to complete a form to say a fault has been fixed
this is the link to the forms, can just google it and it comes up
Alexander Thomson : Hi Kelly, the formal consultation will include a survey for reply so can I ask that you wait until you receive this (hopefully by the end of next week) to make any comments, thanks.
Matt Hodges-Long : I can upload the consultation to the resource centre so that will go to 500+ RPs and Consultants.
Sailesh Parmar : Also, are we duplicating information here, the DLUHC/NFCC carried out with the HRRB project and the ongoing governments via council to collect info on HRRB's? Can this information not be shared back to the FRS's?
Somayya Yaqub : Do the FRS have the necessary technology and training for it's staff. To date the technology available across the FRS has / does vary vastly with some still using paper copies / plans.
Matt Hodges-Long : Sailesh Parmar lots of duplication unfortunately. Hence me whingeing about Single Source of Truth all the time
Paul White : having looked at the list of essential equipment provided above. It is not specific, but would it include items such as fire dampers which are there to maintain compartmentation in ventilation systems. It would be good if it did.
Mick Totty : FRS should be conducting familiarisation visits on all high risk buildings.
Debbie : Will the new ministers change the lack of investment decision to support digital agenda
Dave Williams : on the risk categories we currently use a 5x5 matrix for FRA's; Acceptable, Tolerable, Moderate, Substantial and Intolerable. This could be an idea for your forms rather than High, Medium and Low.
Pete Paton : More than happy to participate in follow up sessions
Richard Hennelly : fire safety regulations only cover in-scope with internal communal areas, however fire safety act doesn't so this is correct it provides a grey area about external wall for 2 or more dwellings as can be seen to include houses, the guidance is not clear as just says it up to RP to decide?
We wouldn’t normally have a FRA if no internal communal areas so could create a lot of resources if we need to assess EWS with 2 or more dwellings as being in scope.
Darren Baird : yep that's my point. Need clarification ASAP
Omar Amin : The government has underlined responses to building safety should be Proportional, Practical and Safe
Debbie : How will that guidance be reflected in competence frameworks for risk assessors?
Pete Paton: How long will the consultation on the question bank be open for (mindful that the 23rd Jan isn;t moving)
Alexander Thomson : Hi Pete, we plan to send this out after the 20th Sept and will be looking for a return by the 21st October, so we can finalise our proposals to FRSs by the beginning of November.
Richard Hennelly: New guidance for 11m-18m for PAS9980, step 1 process for risk assessors in pipeline, provides a more balance proportionate to risk approach, in the main competent fire risk assessors should be able to assess risk, don't need fire engineers in the main who from experience are risk adverse anyway and benchmark against modern fire safety design standards...