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

6 Discussion Items 

6.1 Introduction

6.1.1 This section summarises issues the might influence the establishment of a hub, and the operation of a hub, should it be formed. 

6.1.2 Material in this section draws upon research previously conducted, as well as developed during this project. As such, this section is summary in nature, with reference made to supporting documentation.

6.2 State of Fire Engineering Practice 

6.2.1 The situation with fire engineering in Scotland was explored in 2016 (Meacham, 2016). The principal finding was that some aspects were working well, but some gaps existed. From limited discussions in 2018, it is suggested that the situation has not significantly changed, although progress is being made toward recognised professional qualifications. The following are a few pertinent summary points from the 2016 report.  

6.2.1.1 Due to the lack of a prescribed qualifications system, there is a wide range of competency in fire engineering community. This leads to a range in quality in projects, uncertainty in terms of what level of reliance on expertise of fire engineers is appropriate, and how / at what levels reviews should be undertaken. The lack of students undertaking fire engineering degree programs contributes to this situation.

6.2.1.2 There is a lack of consistency and clarity in the application of fire engineering approach(es). While flexibility is a hallmark of a function-based regulatory system, it should be expected that appropriate means / methods of engineering be applied, and where a standard, guide or code of practice is used, it is followed in its entirety to a level appropriate to the project. There are numerous indications that this is not the case in Scotland. 

6.2.1.3 There is a wide range in the quality of designs and associated documentation. This is in part a function of the lack of qualifications and consistent application of fire engineering guidance, but it is also an attribute of the building regulatory system, which could state more clearly the expectations of design reports and level of documentation required.

6.2.2 Each of these issues has a fundamental impact on how well the application, and the verification, of fire engineering designs is perceived. With a lack of clarity on qualifications and competency, verifiers are not in a position to simply accept designs, as the case may be if a certification system were in place. With variability in the application of engineering tools and methods, it is difficult to understand which are appropriate, and which may not, and under what conditions. With a lack of documentation, making such judgments on the applicability of designs is difficult. Together, these factors lead to significant uncertainty, variability and delay in the verification of fire engineered designs.  

6.3 Diversity in Application of Engineering Tools and Methods 

6.3.1 The diversity in the application of fire engineering tools and methods is a concern that was identified in past research on the situation in Scotland (Meacham, 2016; 2017), as well more broadly (e.g., Beard, 2005; 2005a; Rein et al., 2009; Meacham, 2013). 

6.3.1.1 With respect to engineering methods or approaches, challenges include incomplete characterisation of the problem to be solved, incomplete consideration of the fire and life safety issues within the context of the overall building design, incomplete adherence to comprehensive guidance, lack of consideration for sources of uncertainty, variability and unknowns, and incomplete consideration of the operational state of the building as compared to ‘ideal’ (design) conditions.

6.3.1.2 With respect to engineering tools, particularly computational models, challenges include variability and lack of data, inherent uncertainty within the model / algorithms (i.e., model uncertainty), uncertainty regarding the limits of applicability of the model (i.e., range of validated operation), and variability of the users. 

6.3.2 With respect to engineering methods, while it is understood that each fire engineered design is individual, the approach to undertaking the designs do not have to be individual, and in fact should be consistent. This is the reason that codes of practice and guidance documents such as BS 7974, BS 9999, the SFPE Engineering Guide to Performance-Based Fire Protection Design, the International Fire Engineering Guidelines, and ISO 23932 exist. The level of application and extent of data and information provided may vary, but it is unclear why the approach needs to vary. 

6.3.3 With respect to application of engineering tools, in particular computational models, guidance exists as well, including the SFPE Engineering Guide, Guidelines for Substantiating a Fire Model for a Given Application (SFPE, 2011). 

6.3.3.1 The Guidelines for Substantiating a Fire Model for a Given Application (SFPE, 2011) establishes a methodology with specific steps to review the suitability of a fire model for a specific application including:

• Define the problem of interest
• Select a candidate model
• Verify and validate the model
• Address user effects
• Documentation.

6.3.3.2 The methodology is summarized in the Figure 6.1 below as excerpted from the Engineering Guide.

Figure 6.1: Process Diagram for Substantiating Use of a Fire Model

6.3.4 While challenges exist, guidance exists to help address issues in the application of tools and methods.

6.3.4.1 As noted above, the reason that codes of practice and guidance documents such as BS 7974, BS 9999, the SFPE Engineering Guide to Performance-Based Fire Protection Design, the International Fire Engineering Guidelines, and ISO 23932 exist. The level of application and extent of data and information provided may vary, but it is unclear why the approach needs to vary. Better adherence to guidance will improve the situation.

6.3.4.2 To provide even more consistency, especially for ‘simple’ fire engineering designs, one suggestion from 2016 was that the fire engineers might consider development of a Scottish equivalent to the New Zealand C/VM2. There were some comments received in 2018, principally from verifiers, that a move in this direction would still be useful. It is noted that the Australian Building Codes Board (ABCB) has in 2017 developed such a verification method, which has been out for public consultation in early 2018. As in New Zealand, views on the verification method range from strongly for to strongly against. It is likely that changes will result based on the public consultation. At this point in time, there is no decision on the final version of the verification method or its implementation status.

6.3.4.3 Regarding documentation, in addition to guidance in such documents as BS7974, BS9999, etc., there are guidelines available from other countries, which might serve as useful models. One example is the Institution of Professional Engineers New Zealand (IPENZ) Practice Note 22, Guidelines for Documenting Fire Safety Designs (available for download from https://www.building.govt.nz/assets/Uploads/building-code-compliance/c-protection-from-fire/Fire-safety-design-guidelines/pn22-documenting-fire-safety-designs.pdf). 

6.3.5 Guidance also exists on review of fire engineered designs. One example is the SFPE / ICC Code Official’s Guide to Performance-Based Design Review (SFPE and ICC, 2004). There is also a standard in development in the Nordic countries, prINSTA/TS 952, Fire Safety Engineering — Review and Control in the Building Process (Standards Norway, 2018). Consideration should be given to development of a similar type of verification process for Scotland, as this can help increase consistency in fire engineering designs as well as in the verification of such designs. 

6.4 Qualifications and Competency

6.4.1 Challenges with qualifications and competency related to development and verification of fire engineered designs has been broadly addressed in previous studies (BSD, 2015; Meacham, 2016; 2017; 2018). Excerpts from the cited reports can be found in the annexes to this report. Along with resource challenges within LAVs, this is one of the primary motivators for consideration of a central hub for assisting with the verification of fire engineered designs.

6.4.2 Specific to the potential formulation of a centralized hub for review of fire engineered designs, a critical issue will be identifying and utilising personnel who meet or exceed the qualifications, competency, experience, and ethical expectations of the market. As discussed otherwise in this report, personnel should have demonstrated qualifications and competency in their area of expertise, which is broadly recognised and accepted by all stakeholders. These persons should have demonstrable experience with fire engineering in complex buildings. This does not mean exclusively fire engineering experience, but extends to holistic designs, systems integration, verification and related issues associated with such buildings. 

6.4.3 Likewise, these persons should understand and be able to work with and address the multifaceted issue of complexity in the design process, such as presented in Section 4: 

6.4.3.1 Considerations associated with the complexity of tools and methods used for analysis and design of systems and performance.

• The sophistication of methods of analysis (in particular, computational tools, such as computational fluid dynamics (CFD), finite element (FE) software, and computational evacuation software.
• The integration (or not) of the various software tools in adequately assessing the holistic performance of a building and its systems. 

6.4.3.2 Issues associated with existing construction, including the following:

• Integration of new construction into existing built environment (in particular within dense urban environments).
• Sophisticated ownership or tenancy issues associated with the integration of new construction into existing, including boundaries, pedestrian flows between spaces, and user responsibilities (e.g., systems / space maintenance).

6.4.3.3 Attributes of the design and procurement processes that introduce complexity into the building design and verification process.

• Systems in which there is a not a single, clearly defined ‘responsible’ entity for the design, which assures that the building and its systems are appropriately integrated and implemented in the final operational building.
• Systems in which there is no requirement by designers / engineers to assure that the ‘as-built’ building and its systems meet the design strategies and associated requirements. 
• Systems in which there are few requirements for inspections, testing and commissioning of systems, and other such measures to control quality during construction. 
• Systems in which ongoing maintenance and proper operation of the building and its systems are not routinely audited for compliance with the design strategy. 

6.4.3.4 In considering the complexity of systems (including buildings, which are complex ‘systems of systems’), and the associated reliability of the systems in delivering the expected performance when needed, the extent of interrelationships and dependencies is important.

6.5 Classifying ‘High-Risk’ and ‘Complex’ Buildings 

6.5.1 The issues of ‘high-risk’ and ‘complexity’ are largely addressed in Section 4, including some considerations for classifying such for Scotland. In addition, Annexes D and E provide some exemplar approaches to how risk and complexity can be incorporated into a matrix type approach for the purpose of correlating qualifications and competency requirements to the risk and complexity associated with a building or design.   

6.5.2 As is noted elsewhere in the document, with respect to defining ‘high risk’ buildings, it is suggested to consider development of a ‘risk group’ concept for all Scottish buildings, new and existing. Critical factors including such items as hazards associated with the building / building uses, occupant numbers, characteristics and vulnerabilities, and the types of fire protection schemes which may be applicable, given the fire, building and occupant characteristics. It is suggested that the effort can start with consideration of the various risk definitions / characterisations in the Technical Handbooks, and through an analytic-deliberative process, develop risk groups and associated factors for Scotland. 

6.5.3 With respect to dealing with ‘complexity’, it is suggested to craft guidelines based on factors outlined in Section 4 (several of which are repeated above), which includes a ‘complexity matrix’ such as presented in Annex E, and illustrating how such a matrix could be a structure for decision-making.