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Changes to Regulations
The changes to the regulatory framework in the response to the Grenfell Tower tragedy have been slow to say the least. Any improvements noted to date have largely been in the new build sector, with more emphasis on tested products and third-party certification of contractors.
Unlike new builds, older developments with pre-existing smoke ventilation systems have seen little to no change in regulatory requirements. This means that ventilation systems with major defects remain undetected and continue to pose risks to building occupants. One such incident was the New Providence Wharf fire, during which the building’s fire alarm and AOV systems did not operate properly. This left residents trapped in their flats with firefighters having to carry out rescues.
Last year, CROSS produced a damning report on the testing of smoke control systems. The report highlighted major faults in ventilation systems, some of which may have been there since handover. This indicates that there is a serious and systemic lack of competence in the testing and maintenance of smoke ventilation systems. The report calls for those responsible to ensure that testing and maintenance is only carried out by competent persons – something we passionately advocate for as well.
What regulations are going to change for smoke ventilation system maintenance?
Our belief is that things are about to change drastically as the new regulations start to take effect, in particular:
The Fire Safety Regulations (England) which came into force in January 23, requires additional monthly checks of firefighting equipment including smoke control, in high rise residential buildings. Tests must be recorded, be available to tenants of the building, and any defects found must be reported to the fire and rescue service within 24 hours.
The Building Safety Act brings in a wide range of changes, however the most significant for our industry is the need to register all high-rise residential buildings and produce a Building Safety Case for each. Registration started in April 23 and must be completed by the end of October this year. The Building Safety Case will identify all measures in place in the building to cater for an incident and their suitability and condition.
Presently, many owners of buildings have little understanding of what systems they have, what their performance should be, how they are tested, and if they meet the appropriate regulations. Unfortunately, many of the companies maintaining these buildings are not much better informed. This needs to change.
As we begin to enter a new era of proper testing and verification of fire safety systems, it will become clear who has been glancing over safety requirements. To use Warren Buffet’s famous quote, “only when the tide goes out, do you see who’s been swimming naked”.
Why is Competence important and how to prove it
Competence is the word of the day and evidencing it will be increasingly important for companies that want to remain in the fire safety industry. The CROSS report we previously mentioned, states:
“There are no schemes available for checks on the competence of companies that carry out maintenance of smoke ventilation systems, so there is no way for facilities managers to ensure that their systems are being maintained by a competent engineer.”
Whilst there are no schemes specifically for maintenance companies, certain certifications can be applied to their competence. For example, the IFS SDI 19 scheme can be applicable to competence in both maintenance and installation. Given that that the scheme is based on the requirements of BS 7346-8:2013 (Components for smoke control systems. Code of practice for planning, design, installation, commissioning and maintenance) it covers some of the main competencies involved in smoke ventilation system maintenance.
BS 7346-8:2013 at a glance
BS 7346-8:2013 provides a roadmap for successful delivery of a smoke control solution from design through to handover and maintenance and it can be applied to all system types. The code defines the key processes to be managed, identifies roles and responsibilities for them, and offers clear guidance on performance requirements and documentation to be provided. Evidence of compliance is required throughout the lifetime of the project and there are useful templates for areas like handover and performance testing.
Moreover, clause 9 covers maintenance and servicing in some detail and should be the template that all companies in this field follow. One area in the code that warrants particular attention is clause 9.3 Non-routine maintenance. This clause includes the requirement that a special inspection of an existing smoke control system should be undertaken when a new organisation takes over maintenance of the system. Clause 9.3.1. goes on to detail what a special inspection entails, which includes system design performance development where no suitable records exist.
What is a Special Inspection?
In simple terms, the special inspection entails:
- Identifying the performance requirement of the system as installed e.g., extract 4m3/s from each lobby on detection of smoke
- Assessing whether this is appropriate
- Testing to this requirement
- Reporting on defects with recommended remedial action
A Special Inspection is the best opportunity to give the client an honest appraisal of their current system and to bring it up to standard for the safety of people using it. If you take on smoke ventilation system maintenance without completing this step, it could be considered that you are endorsing the system and you may be liable for future prosecution under the Regulatory Reform Order.
More than just that, defects will come to light either way as new checks to comply with the more stringent regulations are performed.
How to provide compliant smoke ventilation system maintenance
Our advice is to begin the process of completing Special Inspections on all contracts and ensure that defects are documented with proposals to resolve any faults. If you are not a member of the IFS SDI 19 scheme, investigate how you can join and begin the process as soon as possible.
After all, if you don’t know the performance objectives of the system, how can you test it and sign it off?
Failure to carry this out not only puts you at risk, but also risks the lives of the building occupants.
Apart from protecting the lives of building residents, the other upside of Special Inspections is that they often open room for more work. It is common to uncover defective or non-compliant products that require replacement, and this can be a useful source of revenue. You are duty bound to report faults and make recommendations for rectification and building owners are likely to want them swiftly resolved when there is an official record.