Centralized hub for verification of complex fire engineered solutions in Scotland: feasibility study

Broadly, yes. At this stage in the development of fire engineering, there is not enough self-discipline in the market or resources for LAVs, so a hub could be helpful, especially in high-risk and complex buildings. A hub can foster better communication and become a tool for better understanding educational needs to help all actors in the system. In the long term, moving to self-certification would seem a good target. 

Broadly, yes. The market is ‘atomized,’ characterised by a large number of very small firms, and resources are not enough to go around. A hub could help facilitate sharing of knowledge and information, and provide a coordinated and holistic review of fire engineered designs of buildings. 

Uncertain. The function and structure of the hub is unknown, so difficult to assess. The real needs of the LAVs is also unknown. Perhaps a bigger issue is focusing on qualification and competence within the fire engineering sector. 

Broadly, yes. The concept is appealing if it can help reduce time for approvals. It would also be appealing in helping to provide consistency in approval throughout a project and across the country. 

Broadly, yes. A hub could be helpful in developing consistency in verification, and in demonstrating that safe buildings are being designed and constructed. Given the shortage of fire engineers in Scotland, few go to LAVs, so the verification capabilities can vary widely. It can be a reasonable short-term step along the way toward developing a certification scheme for fire engineering, which seems a reasonable long-term goal.

Broadly, yes. Given the resource limitations in Scotland, a hub could be beneficial as technology changes and specific expertise is needed in the verification process. It could also help deliver consistency across the country in approvals, and in interpretations of ‘sustainability’ with respect to fire. 

For complex and ‘one-off’ projects, a hub could be beneficial, as long as it does not interfere with the existing verification process. Many projects seem too small to warrant review by a hub, so building up LAV capacity would be of great benefit. 

Broadly, yes. The SFRS Fire Engineering Group largely serves in this capacity now, helping LAVs that are under-resourced, as well as providing the statutory consultation. Any such hub would have to be properly resourced with clear processes and procedures.

The decision-making structure needs to be clear. In practice some LAVs use the SFPE FEG more as a ‘hub’ than as statutory consultees. Need to be clear whether hub gives advice or decision. Critical issue is acceptance criteria: is the TH the benchmark?

Hub would be a resource for assisting LAVs in review of complex designs. 

The roles of the LAV, SFRS, BSD and the hub need to be very clear. The LAV is the decision-maker. The SFRS have a statutory consultee role and should not be decision-maker. The hub should not be run by BSD – there is a Views process that needs to be maintained, and the hub should not muddy the waters. Perceived and real conflicts of interest must be identified and addressed.

Keeping the function within the building warrant process seems best – keep it simple. There just needs to be clear understanding of when something goes to the hub, what it will cost, and what the timelines are. If everything goes to the hub that could slow things down. Timely decisions by LAVs should be expected based on feedback from the hub.

There were differing views as to whether the decision-making should remain with the LAVs, with most in agreement that is how it should remain. However, roles and relationship between hub, LAVs, and SFRS need to be very clear. If projects go to the hub, and then still need to go to a Views process, it just gets more costly. Fundamental issue is resourcing. If LAVs had proper resources, there would be no need for a hub. The primary role of the central hub will be to act as technical advisors to local authority building control, the SFRS and the BSD.

A hub might help foster better communication between parties involved, and help stakeholders better understand the decision-making process.

The hub should serve a supportive role to LAVs with the approval of building warrants still lying with the local authority. It would have to fit within the verification process, and rationalised with the view process. The hub would have to have a clear remit and purpose. Guidance around different levels of engineering and associated verification could be helpful. 

The SFRS FEG has beneficial knowledge, expertise and experience, and should see all fire engineered designs, regardless of whether another form of hub is developed or not. 

The extent of the ‘problem’ is unknown, so it is difficult to make a judgement on how the hub might be structured and resourced.  How, and how often, the hub is used, would influence resource needs. The ‘integration’ role is missing: the hub could help. If it goes forward, period review / audit is needed. Short-term solution. 

The hub would need expertise that has appropriate ‘T’ shape – depth of fire engineering knowledge but breadth of understanding of how it fits into and integrates with the overall design. Complexity is difficult to define, but following RIBA type approach can help to make sure critical issues are addressed.

Comments on the form ranged from under BSD to supported by the LAVs (LABSS). Fees would have to be such so as not to be a deterrent from use. Liability would have to be clarified for any participants, including entity overseeing the hub. Perceived and real conflicts of interest must be identified and addressed. Regardless of form, there would be need for appropriate quality assurance processes, performance monitoring, audits and the like.

No particular views.

Views differed on whether the hub should be something where all fire engineered designs go into – this gets to consistency, competency, and related issues, but is resource intensive. Wide range of views. Some think the hub should be operated / administrated by full time staff with the resource to meet service conditions required by industry. Others think there should be a pool of people who are rotated to minimise bias. 

It seems like the hub should be independent, with dotted line reporting to the BSD. The hub would be in support of verifiers, but it seems like it can also help the market.

It was noted that LABSS have qualified people to help out a local authority when needed as internal resource. It would be helpful to have a filter process to screen what can be done ‘internally’ and what warrants going to the hub. Two forms: permanent panel, which invited expertise as needed, or panel formed as needed. 

The SFRS FEG can provide the services as understood to be needed, but need statutory authority and should be paid for the service. Capabilities, skills, etc. can be expanded if deemed necessary. All fire engineering designs should be submitted, and should have all necessary documentation. Feedback is given to the LAV, who ultimately makes a decision.

Membership should come from BSD, LAVs / LABSS, the FE community, and SFRS, and if a suitable role exists, academia, government representative (Minister, not BSD), someone with procurement expertise, and someone with building regulatory expertise from outside of Scotland (e.g., England, Wales, Ireland).

There needs to be a coordinator who understands fire performance as part of overall building performance, with the competence to identify issues that may exist and allocate the appropriate expertise to sort the issues. A wide range of expertise would be needed, including architectural, architectural technology, fire, fire service, verifier and more, depending on specific project. Need to have holistic, integrated perspective.

Make-up of the hub should include LAV, SFRS, and FEs. Role of BSD not clear with respect to the Views process. Would be good to be involved, but cannot be in conflict with statutory role. Perceived / potential conflicts of interest with BSD and SFRS need to be sorted.

Input from fire engineers, architects, and the SFRS important. Need to have good practical knowledge as well as specific fire engineering knowledge. Academics could be helpful for review of complex models and such.  Someone from BSD would be desirable.

A qualified person to screen submittals and decide whether to send to the hub is needed. Views differed as to whether this and other members of the hub should be permanent / semi-permanent (substantially dedicated) or rotated in and out. Key attributes are expertise and relevance experience, which should be current. The hub needs to largely consist of fire engineers or verifiers who specialise in fire engineering. Range of views on numbers needed.

Need a mix of expertise. No one person knows everything. Need to have expertise in fire engineering, the tools used, how the building comes together.

Range of views. The number of people that sit on the hub would have to be relatively small so that a decision could be reached. It was discussed that the assistance offered within LABSS could essentially serve as the ‘gatekeeper’ role, helping local authorities make decisions on what can be addressed internally, providing LABSS resource where needed, and facilitating additional review by experts where deemed appropriate. Role of BSD and SFRS need to be clear and not conflict with statutory responsibilities. 

A key concern is the independence of a hub. Having a broad range of people to draw from does not guarantee independence if they are still working in the market (including academics, architects, fire engineers). The SFRS FEG is independent.

An important issue for the hub will be determining who sets the competency level for hub members, and how that is determined (i.e., not just what competencies hub members should have, but who makes judgment and appointments). It seems as if a starting point is Chartered status in the disciplines that are deemed necessary.

The IFE have a set of subjects for which competency is required. The issue is a combination of depth, exposure and time (i.e., what time is required to reach what depth of understanding across which areas).

With respect to qualifications, one size does not fit all. May need IEng and CEng and equivalent, as per project needs.

Not specifically discussed.

Wide range of views. Generally, anyone working in the hub should have highest qualification, e.g., Chartership. Expertise and experience crucial. The ‘gatekeeper’ needs to have the right knowledge, expertise and experience to know when to send something to the hub. The hub will fail if technical decisions are not made by competent persons using appropriate engineering knowledge and methodology. 

Not specifically discussed beyond needed appropriate expertise.

Verifiers have a range of expertise across the breadth of building design, which includes fire engineering in some authorities. The Section 34 letter caused significant concern, as it was open to interpretation. Needs to be clarified. All people should be a member of appropriate professional body.

Reviewers need to be adequately qualified and competent. It is not clear that requiring IEng or CEng (in fire engineering) necessarily accomplishes this. It might be too early to require such without having a better understanding of what such qualifications actually means. The SFRS Fire Engineer Group (FEG) has fire engineering expertise and computational modelling expertise to review fire engineered designs, and has the added benefit of operational experience.

Anyone (actively) involved in fire engineering work should not be in the hub.

Not discussed.

Not discussed.

Not specifically discussed.

Range of views. For the fire engineering community to have confidence in the hub, the process has to be transparent and the appointment of members to the review clear to all. There should be no ‘conflict of interest’ as the ‘target’ for all is a fire safe building. Assuming that it is not practicable to avoid any commercial or industrial people in a hub then each of the professional people in the hub need to declare any potential conflicts. A fire engineer serving the hub should not be able to review a fire engineering report prepared by their firm. Therefore, the hub’s fire engineer should not be a practicing fire engineer employed by a private firm.

Not discussed. 

Limits of service not discussed – depends on form and where housed. BSD and LAVs impartial – practicing engineers need to manage conflict, SFRS status unknown in terms of statutory role.

There is concern that there are resource limitations if one prohibits practising professionals from participating, so as to avoid conflict of interest.

A trigger for sending a fire engineered design to the hub should be any design for which the LAV does not believe that they are competent to assess. The intersection of energy efficiency and fire, and compliance with sustainability and safety Standards are topical.

Triggers difficult to define, since all buildings different, level of expertise diffuse, and complexity a function of the particular building.

Potential triggers for review could be something like risk classes (as in Eurocodes for structures), with focus on consequence if failure occurs. ‘High-risk’ and ‘complex’ designs may be drivers, but terms need to be defined.

Different risk classifications for buildings was noted as one potential trigger. Complexity is a more difficult baseline to describe. Complexity comes in many forms, and not just new build. In many cases, complexity arises out of multi-tenancy (and even multi-owner) issues, working new or renovation of existing buildings in and around existing spaces owned or managed by others, and trying to get all the pieces to fit together. The space itself may be ‘simply’ retail, but the integration of the building / space into existing can be extremely complex. Even something as ‘simple’ as alarm and evacuation zones can be a challenge.

Range of views. Difficult to understand why a hub would only be used for complex and high risk buildings: does this mean that incompetent fire design will not result in death or injury in less complex buildings? All fire engineering solutions, should be subject to hub verification. Any fire engineered solution that is out with the expertise of the LAV. Triggers might be: very tall; complex space uses and complex geometry; those that house dangerous activities; significant variation(s) to the guidance in Section 2; ‘extreme’ designs (floating buildings); extensive application of fire engineering; and use and application of computer aided fire safety design.

Complexity is a trigger, but difficult to define. High risk might be people sleeping, new technologies (e.g., CLT), high-rise, area of building, multi-tenancy, shopping centres.

The main trigger would have to be variation or alternative from Section 2 in the Technical Handbook. There is difficulty in defining what is complex. The view process has been used for single stairs, external wall systems, and similar, but these are not necessarily complex. There is already a two-stage process: the verifier needs help or does not. If help is needed, they can go out and get it within LABSS or third-party review.

One part of the challenge with the existing process is that some verifiers only accept fire strategies at the end, when work is nearly complete, instead of in the beginning, when most beneficial. There is concern that the SFRS FEG only sees part of a design in some cases, and not the full documentation. It can be difficult to assess the suitability of a design component out of context with the entire design approach. In addition, some documentation, even for components, is incomplete. There is no statement of assumptions, limitations, bounding conditions, or similar rationale.

Response time depends on the project, but should be reasonably quick (e.g., 2-4 weeks).

Difficult to determine at this point, but three months is better than three years.

The timeliness of response is difficult to address in advance, as it depends on project scope, complexity, etc.  In any case, it should be relatively fast, as that is one challenge in the existing system.

Time to approval is always difficult, but for small projects, the order of 2 weeks seems appropriate, and perhaps 6 weeks for a larger project. Having a process that provides consistency from start to finish will help a great deal.

Wide range of views. At one end, timescales should be similar to currently provided under the BSD’s ‘Views’ process. At the other end, the construction programme for the building(s) will influence time needed: the construction process could be very long, more than 10 years, with discrete multiple phases. This would need to be informed by our collective experience of typical projects, but could be in the order of: 2 to 4 weeks for small projects with limited fire engineering; 4 to 6 weeks for projects with more fire engineering; and longer times could be expected for major projects.

Not discussed.

Any hub which is set up would delay the processes if this is referred after the warrant is submitted. If submitted at an early stage this may reduce the period to grant the warrant as most of the issues should or could be addressed during the review by the hub. This would encourage architects and fire engineers to discuss at an early stage projects which deviate from the guidance.

Not specifically discussed, but it was noted that a better understanding of perceived problems with the current process is needed. Quantification of delays in the verification process would be helpful.

Government seems appropriate.

Funding should come from all (i.e., all participate to the benefit of all).

As a resource for LAVs, funding the hub could come from levies, fees, etc., but it is recognised that there can be problems with assuring funds collected as part of building control get appropriated to building control within local government.

There would be no problem paying additional fee for the centralized review if the fee is allocated to the verification process and the time required for a decision is significantly reduced.

Wide range of views. Could have several layers: (a) Scottish Government – for permanent staff; (b) LAV to self-fund contribution of own staff seconded part-time on a project specific basis; (c) project budget – for contributions from client design team; (d) all project budgets + LAVs + SFRS + Local Authorities – for general funding for the part-time members of Hubs; and (e) maybe from ‘the industry’ through a national levy.

Not sure about funding. This is a government issue to answer. Insurers have their own research and review and approval process, so not sure they would support a hub.

Funding could come from government, but could also be from fees paid by LAVs which use the hub (as collected from fees from those submitting complex designs for review). A concern was voiced that if any 3rd party contributes it could be considered a bribe.

Not specifically discussed.

There is a capacity issue. All fire engineering grads go to consulting firms, not to LAV or SFRS, and many out of country. Not that much interest by students, as they do not see fire engineering in many universities, so do not see it as an option. ‘Engineer’ not being a protected term is problematic, especially in fire engineering, since the discipline is so broad. Fire engineers are not engaged throughout the entire process – often stop at strategy. 

Every building should have a fire strategy, but all do not. Some buildings seem to be ‘over designed’ for fire. Perhaps others are in the opposite direction. Without a strategy, it is difficult to know what is being targeted, and what impact future changes might have. Overall, level of fire engineering knowledge seems to have decreased a bit, at least in architecture / architectural technology, with very little being taught is associated university programmes. 

Not specifically discussed.

The existing process is sound, the relations are good, the problem seems largely to be resourcing and time to a decision – anything new that is added should be focused on reducing time to a decision and not adding time and complexity to the process.

Wide range of comments. The persons responsible for setting up the hub (assumed to be BSD), need to develop a plan of what they want to see and have a round table discussion with all interested parties (e.g., local authorities, the fire service and fire engineers). There are benefits of a hub in the short term but concerns to its effect over the medium to long term, to such an extend it will not alter the situation where there is a lack of competence and expertise throughout the industry. Fire engineer should be involved from ‘cradle to grave’ for any assurance that systems / features installed and function as intended; however, not the procurement system in Scotland. The BSD with their many years of knowledge in the area of Certification and the setting up of such schemes, should assist the Fire Engineering community.

The hub should help the process and not add time or problems.

Various views. There are numerous problems within the regulatory and fire engineering community in relation to number and competency of qualified staff. It should however be noted that the number of fire engineering solutions that are submitted is not large within Scotland and many projects which provide an engineering report do not require one. The hub appears to be trying to address the issues with the lack of qualified staff within the local authorities and none of the issues within the fire engineering community as a whole. While the idea of certification (self-certification) for fire engineering, such as with structural engineering, is interesting, there have not been any fire engineered designs through the verification process without changes, and it would seem unwise to push too fast at this point – the market is just not ready.

While the SFRS FEG provides feedback to LAVs, they often do not get any information in return, so the SFRS does not know what final solutions were implemented. There are concerns that the procurement process isn’t working as it should, since fire engineers not involved in beginning of projects, which can sometimes lead to issues at the end.