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BAFE submission to the Buildings Regulations Review
Tuesday 24th October 2017
In addition to the Fire Sector Federation submission, BAFE has also written to Dame Judith Hackitt with recommendations for the the Buildings Regulations Review regarding fire safety. BAFE's submission can be read below:
What is BAFE?
BAFE (formerly British Approvals for Fire Equipment) is the independent, not for profit, registration body for third party certificated fire protection organisations across the UK. A national independent register of quality fire safety service providers. Established in 1984, there are now over 1260 companies, many of them with multiple scheme registrations, who are certificated by UKAS accredited certification bodies to our competency schemes. We also register over 1300 extinguisher technicians who have successfully demonstrated competence.
Our main competency schemes cover the design, installation, commissioning and maintenance of fire detection and alarm systems, the same modules for emergency lighting systems, the service provision for portable fire extinguishers and, of high importance with current UK fire legislation, certification for organisations that provide Life Safety Fire Risk Assessment services.
BAFE recommends that the Review of the Building Regulations and Guidance should include:
1. The Regulations should be strengthened and clarified to enhance requirements for whole building resilience, as well as enhancing the life safety risk elements. The development of new building materials, greater reliance on digital technology within buildings, coupled with new methods of fire detection and suppression, places greater needs for regulations to be applied and enforced by competent organisations and staff. As stated in the FSF submission, Approved Document B is ‘not an easy document to use’… ‘Yet there are no defined competencies for the use of the document and its guidance despite the range of user groups having increased as the built environment becomes more congested, more complex and demanding’.
2. The requirements of Regulation 38 should be consolidated to ensure that new buildings and, over time, existing buildings have a full record for the occupier/responsible person of how the building is protected. Only by this means will a full and proper fire risk assessment be possible. This requirement is also vital where there are alterations, refurbishments and changes to use, which are often overlooked and not incorporated in the overall fire protection of the building.
3. Third party certification of fire protection provider organisations should be made mandatory, backed by detailed requirements based on national standards accredited by the Government appointed body UKAS. This should naturally include products and materials used in fire protection, but should be significantly recognised to include the related services provided by organisations and staff (including SMEs and micro businesses) of fire risk assessment, system design, installation, commissioning and crucially ongoing maintenance. Without these appropriate skills the best products will not be adequate in situ to perform their functions to protect life and premises.
4. Specifically the critical function of fire risk assessment, whilst remaining the ultimate responsibility of the ‘responsible’ person, should be carried out and regularly updated, especially where there are alterations to the building by a demonstrably competent person within a certificated or accredited framework, especially in the case of higher risk premises – including medical and care facilities, homes of multiple occupancy, educational establishments, high rise premises and commercial/industrial premises with significant risk factors.
The Scottish Fire and Rescue Service recently included the following in its guidance for fire risk assessments:
“Both the Scottish Government and the Scottish Fire and Rescue Service recommend that duty holders who wish to contract the services of external fire safety risk assessors verify that the assessor is competent in fire risk assessment. One way of verifying the competence of an individual assessor is to select the assessor from a list of competent fire risk assessors maintained by a professional body or a UKAS accredited third party certification body. Another way is to use the services of companies, including sole traders, that are third party certificated under appropriate schemes operated by certification bodies that have, themselves, been UKAS accredited as competent to certificate against such schemes. The benefit of company certification is that the certification body monitors the quality of the certificated company’s work and confirms that there is a system for management of quality within the certificated company.”
BAFE third party certificated, registered organisations range from the largest providers to many SMEs and sole providers, all of whom have made the same commitment to quality and demonstrating their competence, based on regular, independent auditing. These organisations operate in all parts of the UK.
BAFE is run by a Board of independent Directors, drawn from across the wider fire industry and related industries and a Council, made up of key organisations in the sector. The Executive and staff are based at the Fire Service College at Moreton in Marsh, Gloucestershire.
Our aim is to enhance and develop competence across the fire sector, through third party certification, working with a wide range of expert bodies and specialist organisations. All schemes are based on current UK and European standards, together with industry best practice and are monitored and reviewed on a regular basis by expert groups.
We work closely with a range of fire bodies including Trade Associations, Certification Bodies, the NFCC/CFOA and SFRS in Scotland, and as a founder member of the Fire Sector Federation we endorse the content of their submission, particularly with regards to the needs for additional competency and compliance measures.
We currently respond to public sector and OJEC tenders for fire related services (over 1000 responses in the last 5 years) and whilst there has been a significant increase in Procurement specification of third party certificated services, this is by no means a standard requirement, nor one that is universally accepted as good practice. This is not a question of reducing competition as there are now a significant number of certificated organisations, but a general lack of understanding of the need for competence to meet Building and Fire Regulation requirements, especially if a low cost alternative can be sourced without understanding the skills required. This is especially true in the procurement of fire risk assessments.
This should be linked to the critical functions of Fire Engineering in the design and construction of premises and the ongoing skills of Fire Safety Management for property managers/responsible person.
BAFE, as an independent, not for profit body continues to develop competency schemes, but take up can be very variable based on market demand and the lack of any formal requirements. From our participation in cross industry initiatives, such as the investigation into Unwanted Fire Alarm Signals in Glasgow and the Competency Council review of Fire Risk Assessment skills, we have seen that there is a genuine desire to improve fire protection for both life safety and property protection. However without regulatory support (already existing in gas fitting, electrical installation and asbestos working) there will be no guarantee that this vital work across the fire sector will be carried out by competent providers and raises the prospect of future exposure to unnecessary risk for both the general public and emergency responders if these regulatory requirements are not enforced.
- Submission was signed by Douglas Barnett (BAFE Chairman) and Stephen Adams (BAFE Chief Executive)
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Legal obligations nationwide require the appointed responsible person for fire safety for commercial/non-domestic premises to have adequate fire protection.