Building regulations - proposed review of fire safety topics: analysis of responses

6. Call for evidence on current standards

The consultation proposed undertaking further research and evidence gathering to inform policy on three areas – the BS 476 national classification, Battery Energy Storage Systems (BESS), and car parks and electric vehicles.

BS 476

The removal of the national classification BS 476 has been suggested following the introduction of the Harmonised European Standards for Reaction and Resistance to Fire in the Technical Handbooks. Scotland is considering alignment with England through removing the dual system of testing and classification by removing BS 476 for Vulnerability of roof coverings and Resistance to fire.

Q23. It is proposed to undertake further research and gather evidence to inform the policy. Please confirm any evidence, contribution or initial comments that would help towards this.

Three quarters of all respondents left a comment at Q23. The most prevalent themes were support for this approach, that it is good to align with England and that more work or consultation is needed on the topic.

General agreement

Several respondents expressed support to the proposal. Reasons given included:

• Tests are outdated, and manufacturers no longer test to the BS 476 standard.
• Support for a five-year transition.
• European standards were more definitive and easier to understand.
• Removing reference to fire resistance classifications would reduce market distortion and improve general levels of safety.
• It would see the final removal of the national classes for reaction to fire, and address confusion caused by the ‘low risk’ reaction to fire classification.

Aligns with elsewhere

Alignment with England, the UK or Europe was highlighted by several respondents as a positive outcome of the removal of the BS 476 standard. Respondents noted that this may help to create greater consistency, that there are already existing areas of alignment such as cross-UK building companies, and it may be easier to understand.

More work and consultation are needed

Some respondents commented that more research, evidence gathering, consultation and work on the proposed removal of the BS 476 standard is needed. Suggestions for what this should focus on were made by one or two respondents. These included: fire door maintenance, testing and standards, vulnerability of roof coverings and industry groups to work through proposed changes.

“There should be consultation with the fire door industry regarding the removal of acceptance of BS 476-22. Because of difference in measurement of temperature between the BS test and the European test, it is my belief that perfectly good fire-resisting doorsets that pass the BS test would need to be re-tested and could marginally fail, resulting in unreasonable costs for the industry.” - Individual

Possible issues and challenges

Perceived issues and challenges with the proposed removal of the BS 476 standard were raised by some respondents. These highlighted:

• Potential failings of fire-resisting door sets by following the European test.
• Impractical timescales for vulnerability of roof coatings, with a suggestion to have a transition period that aligns with fire resistance testing.
• A view that complete removal will not be straightforward.
• BS 476 standard is still used, such as for legacy projects.

Suggestions

One respondent suggested adopting a new technical assessment standard which would cover areas outside of the European classification system. Another suggested work undertaken for the Health and Safety Executive on roof installation which could be shared with the Scottish Government.

Battery Energy Storage Systems

An increase in the use of BESS installations is expected because they are effective in storing energy from renewable technologies. The consultation paper notes that battery fires are low-frequency but have high impact and, therefore, it proposes further research on BESS in domestic and non-domestic buildings to inform future policies, such as around compartmentation and early warning of fire.

Q24. It is proposed to undertake further research and gather evidence to inform the policy. Please confirm any evidence, contribution or initial comments that would help towards this.

Almost two thirds of all respondents left a comment at Q24. The most prevalent themes were general agreement, comments on risk, and suggested evidence.

General agreement

Many respondents agreed with the proposal to undertake further research and evidence gathering to inform domestic and non-domestic building policy regarding battery energy storage systems (BESS) and associated fire risk. Comments highlighted that further research is sensible and essential for developing evidence-based guidance. Respondents noted the increased use of renewable and sustainable energy technology systems, including BESS, and the importance of considering fire risk and providing guidance.

Risks and suggestions for minimisation

Several respondents raised concerns about BESS risks and made suggestions to minimise these risks, which could be addressed through the proposed research. A range of perceived risks were raised, including the risk of thermal runaway, short circuits, component faults, overheating, chemical leaks, explosions, toxic gases, and fire.

Suggestions for mitigating risks included having fire-resistant enclosures, ventilation, sprinklers including water mist, and considering BESS location. The need to develop regulation, guidance, a robust emergency response plan, implementation of safety measures, and an increased understanding of the hazards was also noted.

Disagreement was also evident, with a few respondents querying whether the frequency of BESS-related fires is higher than suggested in the consultation paper, that one metre away from buildings is insufficient, and that external buildings should not be exempt.

Suggested evidence and areas for research

Some respondents suggested existing evidence that could be considered. Suggestions were made by one or two respondents each:

• SFRS guidance.
• Paper published by Cross UK titled ‘Fire Safety concerns with lithium-ion batteries aimed at Owners and occupiers of facilities, local authorities and fire and rescue services’.
• PAS 63100 recommendations.
• Fire Industry Association guidance.

Areas that some respondents felt required more research included:

• Compartmentation, resistance, battery separation, venting, suppression, early warning in fire and other fire protection methods.
• Artificial Intelligence (AI) battery fire detection systems.
• BESS use within buildings.
• Solar PV panels and fire risks.

Car parks and electric vehicles (EVs)

The consultation paper proposed commissioning a literature review on global car park fire safety relating to electric, hybrid, and other forms of alternative energy vehicles to inform guidance and policy.

Q25. It is to proposed undertake a literature review to inform the policy on car parks and particularly in relation to electric vehicles. Please confirm any evidence, contribution or initial comments that would help towards this.

Almost two thirds of all respondents left a comment at Q25. The most prevalent themes were general agreement, suggested evidence, and the need for updated policy.

General agreement

Several respondents agreed with the proposal to undertake a literature review and research, expressing a desire to know more about whether there is a greater fire risk in electric vehicles (EVs) than combustion engine vehicles, and that undertaking research to inform policy is a sensible approach.

Suggested evidence

Some respondents noted evidence that could contribute to the literature review. This included:

• Existing research on fitting sprinklers to limit fire spreading between vehicles within carparks, from the European Fire Sprinkler Network.
• Arup technical paper T0194.
• Steel Construction Institute’s Non-Contradictory Complementary Information (NCCI): PN005 Fire Resistance Design of Composite Slabs and P359 Composite Design of Steel Framed Buildings.
• Ongoing research and literature reviews by OFR Consultants, including around structural fire resistance requirements and sprinklers in car parks containing EVs.
• Bedfordshire Fire and Rescue Significant Incident Report in the Luton Airport Carpark, published March 2024.
• Review requirements in the National Fire Protection Association standard 88 on sprinkler systems in automated car parks and related 2010 BRE research.
• UK and Australian government published guidance on carparks.
• International Council on Clean Transportation approaches to mitigate EV fires in enclosed spaces.
• National Fire Protection Association research on modern vehicle hazards in parking structures and systems.
• National Research Council Canada literature review on the parking of electric vehicles.

Policy needs updating

Some respondents highlighted the need for an updated car park policy, particularly for EVs. They highlighted the growing number of EVs and EV chargers and potential fire risks associated with them, making policy updates timely. Updates could include fire protection strategies for modern vehicles in parking garages, consideration of the construction and design of car parks, and policy specifically for EVs in car parks. Respondents also noted examples of fires in car parks, such as the 2023 Luton Airport car park fire.

Aspects to consider

Aspects to consider in the literature review were suggested by some, including:

• The increased weight of EVs for existing carparks.
• Likelihood of fire spread between cars for both EVS and internal combustion engines, and the thermal loading on the structures.
• Installation of sprinklers in open-sided car parks.
• E-bikes parked in public or domestic settings.
• Mitigation of risks associated with EV batteries and electric chargers as ignition sources and fuel contribution. This includes the installation, inspection, maintenance, monitoring systems, training, awareness and fire safety measures.
• Car park design and fires, including consideration of the fir loading of modern vehicles, EVs, Liquified Petroleum Gas (often called dual-fuel) vehicles, and risk of fuel fires from plastic fuel tanks.
• The role of local authorities in maintaining and repairing EV charging points in ‘adopted’ car parking sites, which was perceived as not cost-effective.
• Potential for policy conflicts, such as differing requirements of local authorities compared to road planning agencies.