Cladding Remediation Programme: Single Building Assessment specification

4 Fire Risk Assessment

4.1 Overview

4.1.1 The SBA process introduces a requirement for an FRA to be undertaken within in-scope Buildings.

4.1.2 In non-residential buildings (or non-residential areas within a building), there is a responsibility under the Fire (Scotland) Act 2005 on employers and any other person(s) with control of premises (dutyholders) to assess risk of harm from fire and to put in place appropriate fire safety measures.

4.1.3 The FRA (as part of the SBA) is undertaken to inform the SBA and achieve the aims of the Bill, namely, to identify Risk to Human Life in in-scope Buildings. Fire Safety of residential buildings is holistic. As such the condition of the internal design of these buildings, can have a direct or indirect impact on the Risk to Human Life relating to the EWS. Therefore, the SBA process will require an FRA to be undertaken to any in-scope Buildings.

4.1.4 Many in-scope Buildings will be “mixed use” and contain non-residential uses (i.e. commercial premises). Fire Safety risk within these areas has the potential to contribute to the Risk to Human Life, therefore these areas will be within scope of the FRA undertaken as part of the SBA process.

4.1.5 The FRA undertaken as part of the SBA is not part of the Fire (Scotland) Act 2005 requirements and is a separate, onetime assessment completed only to satisfy the SBA. The undertaking of the FRA as part of the SBA process does not replace any requirement for an FRA under the Fire (Scotland) Act 2005.

4.1.6 A staged approach to the undertaking of the FRA is to be adopted by Assessors and this is detailed further within this specification. The Assessor must undertake a visual inspection of the common corridors, stairs, entrance lobby areas, plant rooms, non-domestic areas such as bin stores, car parks and other ancillary areas. It will be confirmed by the Assessor how many flat doors they are to inspect however this should be a suitable sample size to confirm the general standard of doors within a building. Other fire doors can be sampled during the inspection of the common areas.

4.2 Guidance To Be Followed

Residential Areas

4.2.1 In 2020 BSI released ‘PAS 79-2:2020 Fire Risk Assessment – Part 2: Housing – Code of Practice’, that came into effect on 31^st December 2020. This set out the principles and methodology of undertaking an FRA in respect of residential buildings to be followed by an Assessor.

4.2.2 The PAS 79-2 was withdrawn in 2021 where it was agreed by a steering group that it would be reviewed as a British Standard document. Despite being withdrawn, PAS 79-2 remains available for reference on the BSI website and should continue to be followed pending publication of the revised British Standard document by BSI. Once published the revised British Standard will be the applicable standard for any competent Assessor.

4.2.3 The FRA element of the SBA process will be a two-staged approach, with the second stage being required only if deemed necessary by the Assessor during their Stage 1 assessment. A Stage 1 FRA is required as a minimum for the SBA process. The two stages are summarised as follows:

• Stage 1 – The scope of the Stage 1 FRA is limited to common areas (common corridors, stairs etc.), plant rooms and other non-domestic areas of the building (if applicable). The nature of this assessment is non-intrusive. A sample of flat entrance doors are also to be considered as part of a Stage 1 FRA. A reasonable sample could be checking one or two doors on each floor, and in the instance that issues are identified during this, additional doors to the assessor’s satisfaction could be sampled within the same floor. Other fire doors including stair doors, doors into fire rated ancillary areas and doors to protected corridors should also be checked. Following this assessment the assessor shall determine whether further investigation is needed to confirm the condition of the building’s internal compartmentation. This is likely to arise when there are significant issues raised with compartmentation, fire stopping etc. in the Stage 1 FRA. If the assessor undertaking the Stage 1 FRA determines a Stage 2 is required.
• Stage 2 – The scope of a Stage 2 assessment should be confirmed by the Assessor but could include further intrusive inspection to be undertaken within the common areas or, if deemed necessary, further inspection to be carried out within the flats themselves, noting the suitability and proportionality of the risks. The Assessor should consider deficiencies which could lead to a fire potentially spreading beyond the flat of fire origin, and exacerbating EWS risk.

4.2.4 While the Stage 1 FRA is a non-intrusive assessment, it is expected that the Assessor will conduct a reasonable quantum of inspection into accessible areas such as service risers, ceiling voids and raised access floor voids (where applicable) for any compartmentation issues. The Assessor shall demonstrate that they have made reasonable efforts to gain access to these areas.

4.2.5 The Scottish Government’s ‘Practical Fire Safety Guidance for..’ document series covers guidance for a number of different building types, including a document focusing on ‘Existing High Rise Domestic Buildings’. In the absence of existing fire safety information, the Assessor may use this document to make an expert estimate of the existing fire strategy elements present in the building and then look to confirm, or negate, these assumptions whilst undertaking an inspection.

4.2.6 Annex C of this specification document provides a template for the SBA FRA element which should be utilised by assessors.

Mixed Use Buildings

4.2.7 Some in-scope Buildings may have more than one use (e.g. a commercial area, typically on the Ground Floor.)

4.2.8 As part of the FRA of the SBA, these non-residential areas are required to be assessed. This should be undertaken in accordance with the Scottish Government document ‘Fire Safety – existing non-residential premises: practical guidance’.

4.2.9 However, given the focus of the SBA will be on Risk to Human Life of the occupants of the flats within the building, this should also be the focus of the FRA of any Commercial, Office etc. area, in relation to of how a fire in these areas would affect the residential premises in the building. Therefore, the focus shall be on, as a minimum:

• Compartmentation between residential and other uses of the building;
• Fire load within these the non-residential areas;
• Fire load proximity, both internally and externally to the EWS;
• Existence of a communal fire alarm system, or a type of alert system, between the different use areas as a means of warning residents of a fire scenario;
• Type of fire alarm system present, frequency of inspection, maintenance and testing.

4.2.10 The Assessor should use their expertise to add any further information which they feel relevant to the FRA, which may potentially impact the Risk to Human Life of occupants in the residential areas.

4.2.11 The SFRS should be contacted during the process of commercial area assessment. They may be able to provide further information on any previous FRAs undertaken on the premises, or outcomes of any audit activity by Protection Officers, which could add to the information gathered by the assessor.

4.3 FRA Steps

4.3.1 The below steps have been devised to bring a level of consistency and provide a structured approach to FRAs across Scotland for the purposes of SBAs. These steps shall be followed by the Assessor.

First Step – Obtain Relevant Information

4.3.2 In this step the Assessor is expected to make reasonable efforts attempt to obtain as much information as possible relating to the premises and their occupants (including any staff, and their roles and responsibilities, in the instance where staff are present on site). It should be understood whether the building has had any previous fires and the severity/extent of these (i.e. have historic fires remained in the area of fire origin or have they spread?) Any fire strategy information and architectural drawings (floor plans, elevations etc.), when existing, shall be obtained at this stage.

4.3.3 The Assessor can contact the building control department of the Local Authority to attempt and retrieve any information which they may have.

Second Step – Fire Hazard Identification

4.3.4 In this step the Assessor identifies any fire hazards present within, or in close proximity to, the building and uses their expertise to determine if there are any existing measures for the elimination, or control, of the fire hazards which have been identified. In residential buildings this is typically done via inspections, but information can also be gained through staff or managing agents, if they are in place. The Assessor should consider existing information obtained from building standards, operation and maintenance manuals (O&Ms), and existing health and safety files to determine whether there are any measures in place for mitigation, or control.

4.3.5 A fire hazard prompt list is provided in Annex B of PAS 79-2.

Third Step – Assess the Potential of Fire

4.3.6 In this step the Assessor takes, primarily, the information gained in the Second Step (alongside any relevant information obtained in the First Step) and determines the likelihood of a fire breaking out and spreading through the building. This step’s focus shall be on the condition of the building’s internal compartmentation i.e. flat separating walls and fire doors, stair walls and doors, risers and common corridors, all of which should be fire rated.

Fourth Step – Determine Fire Protection Measures

4.3.7 In this step the Assessor determines any fire protection measures that are available within the building with a focus on the protection of the building’s occupants in a fire event. This is primarily determined during the inspection stage.

Fifth Step – Obtain Related Information Regarding Fire Safety Management

4.3.8 This step typically involves discussion with any personnel that may have knowledge regarding the fire safety management (e.g. Registered social landlords, flat owners, a management company, etc.) and examination of existing documentation. Any discussions and analysis of documentation shall be recorded in the assessment.

Sixth Step – Assessment of Likely Consequences to Occupants

4.3.9 In this step the Assessor assesses the likely consequences to the building’s occupants in the event of a fire. The assessment considers the assessor’s opinion of the likelihood of various fire scenarios, the extent of injury which could occur to the building’s occupants, and the number of people that could be affected during the fire scenario. The Assessor should also consider any disabled occupants, and the impact on consequences that may affect them escaping from the building.

4.3.10 The Assessor is to base this assessment on the information founded in Fourth and Fifth Step, but will also take into account information obtained in First Step.

Seventh Step – Assess the Overall Fire Risk

4.3.11 In this step the Assessor evaluates the at the fire risk and make an expert decision on whether the risk is tolerable or intolerable. The fire risk is assessed by combining the likelihood of fire and the potential consequences of said fire as shown in Table 1 below, taken from PAS 79-2, which depicts an example of a matrix of categories of likelihood and consequences which can be used in the assessment of fire risk.

Eighth Step – Detail Out Remedial Actions

4.3.12 In this step, if the outcome of the assessment in the Seventh Step is not a ‘tolerable’ Risk to Human Life, the Assessor shall formulate an action plan in order to reduce the Risk to Human Life to a ‘tolerable’ risk level where possible or suggest actions that may mitigate for the risk if it cannot be reduced.

4.3.13 Even if the Risk to Human Life is assessed as ‘tolerable’, the Assessor can still recommend minor improvements to the building in regards to fire safety measures and/or protection. It is recommended that any action plan advised by the Assessor is undertaken to improve life safety of occupants, this will be issued to dutyholders to consider.

4.4 FRA Potential Issues

4.4.1 When undertaking works on existing buildings it is common that fire safety information is either not existent or unavailable for the purposes of assessment. In the event that there is no fire strategy in place, key information may not be available for an Assessor, including:

• Details of the alarm and detection systems;
• Evacuation Strategy;
• Compartmentation Strategy;
• Details of the smoke ventilation systems;
• Details of the firefighting systems.

4.4.2 The Assessor shall make a reasonable effort to obtain this information from the health and safety, or operations and maintenance files which would have been required under Construction Design and Management (CDM) regulations (at the time the building was constructed).

4.4.3 Due to the legal basis of ownership in Scotland, there will not be a single ownership interest in a high-rise domestic building (equivalent to the English freehold interest) separate from the interests of individual flat owners. Accordingly, an Assessor may not be able to contact a single responsible entity to obtain relevant information.

4.4.4 The Fire Safety (Scotland) Regulations 2006 apply to non-domestic premises and generally do not apply to individual flats, or to the common areas of blocks of flats. The requirement under the regulations to ensure that the common areas and any facilities, equipment and devices provided for the use by, or protection of firefighters, are maintained in an efficient state, efficient working order and in good repair is an exception and does apply to high-rise domestic buildings. However, the expectation is that residential owners will not have any significant fire strategy or fire systems knowledge that would be of use to an assessor although this should still be investigated prior to the assessment.

4.4.5 In the instance where fire safety information available is lacking for an Assessor to determine the relevant fire safety provisions in the building, they shall use expertise to gain as much information about the building from their inspections and use their own experience to determine elements which could be present, from a fire protection and systems point of view, within residential buildings.