On the 1 October 2013 The (Miscellaneous Amendments) (Scotland) Regulations 2013 came into force. As a result, The Buildings (Procedure) (Scotland) Regulations 2004 and the Building (Forms) Scotland Regulations 2005 have been amended to take account of this change in procedures.
Under these amendments Fire Safety Design Summaries (FSDS) must now be provided with completion certificates relating to the construction of, or conversion to, new non–domestic buildings, including extensions to existing buildings. The information must be entered in Part II of the Building Standards Register.
Fire Safety Design Summaries mean information relating to the design and construction of the building, and the services, fittings and equipment provided in or in connection with the building, which will assist in the operation and maintenance of the building for fire safety purposes.
The regulations apply when the application for a building warrant is submitted after the 1 October 2013. The ‘relevant person’ must submit a Fire Safety Design Summary (FSDS) with the completion certificate. In most cases, the ‘relevant person’ will be the building warrant applicant or their duly authorised agent. The local authority verifier will check the FSDS for accuracy prior to accepting or rejecting the completion certificate. (See Procedural Handbook for more guidance).
Once a non-domestic building is complete and occupied it can be difficult to establish fully what fire safety measures have been incorporated in the building or what assumptions have been made by designers in respect of the fire strategy of the building. The information could be described as ‘hidden information’ that cannot easily be established by an examination of the completed premises.
Therefore, the intention of this new procedural requirement is to provide the FSDS and make it available to the owner or occupier, dutyholders, fire risk assessors and enforcing authorities. The information will help identify and document what fire safety measures have been incorporated into the building and what fire safety design assumptions have been made. This will also be of benefit to those responsible for operating and maintaining the building for fire safety purposes when the building is occupied.
To help with the recovery of the information, the FSDS requires to be held on Part II of each local authority Building Standards Register, a copy should also be retained by the owner as the FSDS is an important legal document.
The information is particularly valuable where the design of the building does not follow the guidance in Section 2: Fire of the non-domestic Technical Handbook. For example, if the escape routes have been designed on the basis of occupancy load factors different from those stated in the Technical Handbooks, they may no longer be appropriate if the number of people was to increase significantly. Another example could be where an atrium has a restricted fire loading in its base and it is essential that this is recorded so that the building owners, occupiers, dutyholders, fire risk assessors and enforcing authorities are aware of such a restriction.
What information should be provided
The information provided should be proportionate and effective for the building concerned. To assist in the subsequent recovery of information and that a consistent approach is taken the standard FSDS Form should be adopted.
A blank template form and two completed example forms:
It is intended that these forms will assist building warrant applicants or their duly authorised agents to meet the regulations.
Simple buildings - Many buildings are of a size and design that the fire safety measures provided are simple, obvious and understandable. The information provided on the FSDS form together with the information submitted as part of the building warrant application should be sufficient to satisfy the regulations. Therefore the form must be provided in all cases.
As each building project is unique, it is not possible, to exhaustively list the required information expected to be provided. The list below may be taken as indicative of the type of information that could be provided:
- a list of design parameters that are the basis of a fire safety strategy (for example number of exits, travel distance, occupancy capacity, compartmentation etc.);
- whether the evacuation strategy is based on simultaneous or phased evacuation;
- alternative approaches - identify any parts of the building design that does not follow the guidance in Section 2: Fire of the Technical Handbooks (Appendix A of ‘A simplified approach to alternative fire safety strategies’ provides further useful information on design considerations);
- a description of any smoke-control system(s), including mode of operation and controls;
- a description of any fire detection and alarm systems;
- a description of any suppression system installed, including isolating valves and control equipment;
- any provisions incorporated within the building to facilitate the evacuation of occupants with sensory, cognitive and/or mobility impairments;
- details of facilities to assist fire-fighting and rescue operations;
- a list of design assumptions where they rely on the fire safety management of the building (BS 5588-12:2004 for more information on managing fire safety);
- Reference to any specialist reports, etc. held on Part II of the Building Standards Register on which information is based, e.g. fire engineering report.
Drawings of the building layout can help compliment the information provided on the FSDS form. The level of detail required will vary with the building complexity. In some cases the normal design drawings will provide sufficient information whereas in more complex buildings, bespoke FSDS drawings should be provided. Marked up drawings with key fire safety information will allow interested parties to quickly establish the fire safety measures incorporated in a building. Typically, the type of information recorded on the plans might include the number of exits, travel distances, occupancy capacities, compartmentation, separation, escape route enclosures, cavity barriers, self-closing fire doors, fire dampers to ventilation ducts, fire shutters, automatic fire alarm and detection systems, smoke heat exhaust ventilation systems, emergency lighting and automatic fire suppression systems.
Shell and fit out building warrants
When a new building is the subject of separate shell and fit out building warrants, the final fire safety design of the building may not be known at the completion of the ‘shell’ stage. As a completion certificate will certify that the building complies with the building regulations, a FSDS will be required at the shell stage completion. While the level of detail provided may be limited it should still reflect the main fire safety factors that apply and any assumptions made in the fire safety design.
Although a FSDS is not required for alterations, where there are variations from the original fire safety information, it would be best practice for an updated FSDS to be submitted at the fit out completion. This updated FSDS for the building could then be entered in Part II of the Building Standards Register.