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01-08-19

NFCC responds to key Government consultations on the Building Safety Programme

The National Fire Chiefs Council (NFCC) has submitted responses to Government consultation papers: ‘Building a safer future: proposals for reform of the building safety regulatory system’ (Ministry of Housing, Communities and Local Government) and ‘Regulatory Reform (Fire Safety) Order 2005 Call for Evidence.’ (Home Office).

NFCC has made it clear that while the Government consultations are important and welcomed, there remains a long way to go before the system is ‘fixed’. The NFCC Chair Roy Wilsher said: “There is no silver bullet and there are a myriad of issues that still need to be fixed. “I urge Government to grasp this opportunity to address the root-and-branch issues in our building regulations and ensure that a tragedy like the Grenfell Tower fire never happens again.”

The NFCC responses have been informed by an extensive consultation within the NFCC, with Fire and Rescue Services (FRSs) across the UK and with partner organisations. This has been led by the Chair of NFCC Protection and Business Safety Committee, Chief Fire Officer Mark Hardingham and the NFCC Building Safety Programme Team.

A broken system and the need to fix it:

Roy Wilsher said while the proposals in Building a Safer Future are a good start, we are two years on from the Grenfell fire and there remains a lot more to be done to ensure the safety of the built environment.

NFCC is seeking changes to regulations which currently allow buildings to be refurbished many times without any improvement to fire safety standards. A case in point was the total refurbishment of Lakanal House following a multiple fatal fire, which overlooked opportunities to improve the fire safety for the building, like fitting sprinklers, despite significant investment in the refurbishment works.

“NFCC are calling on the Government to fix this by introducing trigger provisions to require improvements to fire safety standards when there is a major refurbishment or change of use. We have highlighted this in the past and are disappointed that the change has not already been made.” 

It is crucial, to avoid the creation of a two-tier standard of safety, that the right incentives are in place to ensure compliance and a focus on safety. A new regime for a narrow set of buildings will only create incentives for people to build more medium and low rise buildings within the current broken system. Equally there are lots of other buildings where vulnerable people sleep, where we want to see more controls.

“We are concerned current proposals and scope will be seen as ‘job done’, responding specifically to the Grenfell tragedy, but not also taking the opportunity to properly address the much wider problems.”

“NFCC remains concerned about the pace of remediation for buildings with highly combustible cladding. Part of the delay for this has been the lack of a clear legislative framework to deal with these buildings.”

“All building work must be open to scrutiny under the new regime to ensure compliance and avoid perverse incentives. Clients should not have the ability to choose their own building control body. The system needs to incorporate a holistic understanding of risk, including the vulnerability of building occupants. The planning, construction and design side of the new regime should have a wider scope, to ensure care homes, specialised housing, hospitals and prisons are built correctly to begin with.”

A key concern is the opportunity for ‘gaming’ hard parameters such as trigger heights. NFCC has previously called for a review of trigger heights and how they interact within the design guidance.  Currently, there is a gap for protection of buildings between 11m and 18m.  Front line equipment carried by services is primarily fit for external firefighting and rescue up to 11m in floor height. If a height threshold must be used, NFCC suggests 11m may be more appropriate than 18m.

Mark noted “ADB needs significant strengthening around the use of sprinklers, firefighting access and facilities, and consideration of the needs of vulnerable persons, especially in specialised housing.”  

Roy said a challenge was “the lack of detail on the form of the proposed national regulator which made it difficult to respond to some questions. NFCC supports proposals for national coordination of a number of the functions proposed, but it is our view this should be supported by local delivery through existing regulators.”

Finally, increased demand for protection skills needs to be addressed.  HMICFRS are reporting that protection work was under-resourced in many of the FRSs inspected.[1]  There is a skills shortage in fire safety skills and knowledge, for instance fire engineers need a long time to train and become competent in their role. Any additional burdens must be properly resourced, and a new national regulator could put additional strain on an increasingly small pool of people; this skills gap needs to be planned for and addressed.

Notes:

The NFCC’s full submissions to ‘Building a safer future: proposals for reform of the building safety regulatory system and ‘The Regulatory Reform (Fire Safety) Order 2005 Call for Evidence are available to read.  

 

[1] https://www.justiceinspectorates.gov.uk/hmicfrs/wp-content/uploads/fire-and-rescue-service-inspections-2018-19.pdf

https://www.justiceinspectorates.gov.uk/hmicfrs/wp-content/uploads/fire-and-rescue-service-inspections-2018-19-tranche-2.pdf

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