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

7. Impact assessments

The consultation asked whether there could be potential impacts or implications from the proposals in the consultation on equality groups, island communities, and business and regulation.

Equality impact assessment

Q26. Are there any proposals in this consultation which you consider to impact or have implications on equality groups? Please provide any comments below. If selecting yes, please specify which of the proposals you refer to and why you believe specific groups will be impacted?

Almost three quarters (73%) of respondents who answered Q26 felt the proposals would not impact equality groups, though 9% thought they would, and 18% were unsure.

Around two fifths of all respondents commented at Q26. The most prevalent themes were that there is no impact on equality groups and positive implications for equality groups.

No impact or no negative impact

A few respondents commented that they were unaware of any negative impacts on equality groups from the proposals in this consultation.

Positive impacts for disabled, older and vulnerable people

A small number of respondents highlighted possible positive impacts arising from the proposals. It was suggested that the changes could help protect those who are older, disabled, or more vulnerable by providing more time to escape fires. One respondent noted that direct engagement with disabled people could improve understanding of their specific requirements, e.g., the width of doors needed for wheelchairs.

Two respondents outlined perceived positive impacts from the proposals, but did not specify particular groups that would be impacted. However, they also commented that limiting fire spread could provide additional time to evacuate fires, and sprinklers could support those who are unable to leave rooms when a fire starts, thus increasing fire safety.

Other comments

One respondent expanded on why there could be negative impacts.

“Human and Organisational Factors principles are not applied in higher risk building assessments to a similar standard to that of the Major Accident Hazards Sector then people with 'Additional Needs' could be adversely impacted by these proposals. Current proposals do not fully address the potential for human error in the design, construction, commissioning, operations, and inspection and maintenance of Safety Critical Elements/equipment thus exposing people to risks greater than the ALARP level.” - Individual

Business and regulatory impact assessment (BRIA)

Q27. Do you think that any of the proposals in this consultation have any financial, regulatory or resource implications for you and/or your business (if applicable)? Please provide any comments below. If selecting yes, please specify which of the proposals you refer to and why you believe financial, regulatory or resource implications will be impacted.

Views were mixed on whether the proposals would impact businesses. Among those answering Q27, 30% felt they would, 39% felt they would not, and 30% were unsure.

One quarter of all respondents left a comment at Q27. The most prevalent themes were potential impacts on the workforce and increased costs.

Impact on workforce

Some respondents highlighted potential workforce impacts arising from the proposals. Various comments, each made by one or two respondents, included:

• Learning and development requirements to ensure verifiers are up to date on changes to standards and guidance, as well as more specialist training and associated costs for architects.
• Administrative registration costs for fire risk assessors if there is a move to registration for all UK assessors.
• Replacement of the BS 476 impact on the passive fire protection sector.
• The need for appropriately skilled installers and assessors.

Increased costs

A small number of respondents noted potential increased costs associated with the proposals. These include increased construction and building costs, increased fee income, and financial implications for the increased need for specialist consultant input for building conversions. However, one respondent commented that if significant costs are incurred, it may be because the property has not compliant with existing regulations and therefore needs more substantial upgrading.

Other comments

Two respondents commented that the proposals could result in increased demand for support to achieve compliance and regulatory clashes, namely, between these recommendations and requirements of Listed Building and Conservation Area legislation.

Concerns with the cost-benefit analysis

In addition, some respondents repeatedly raised concerns with the cost-benefit analysis referred to in the consultation document on AFSS systems in conversions of traditional buildings to hotels. These respondents provided detailed comments on the cost-benefit analysis, particularly at Q1, Q4, Q10, Q27. To avoid repetition, these comments have been consolidated and presented here.

Certain assumptions on which the cost-benefit analysis was based, or its conclusions, were challenged. Assumptions queried included, in no particular order:

• The cost-benefit analysis for BS EN 12845 fails to consider potential trade-offs when sprinklers are installed, such as reduced fire resistance requirements, increased compartment sizes and extended travel distances.
• The costs for pumps in the system were based on Ordinary Hazard 3 rather than Ordinary Hazard 1 supply, resulting in an overestimate of costs.
• Underestimated costs of damage in conversions, as they are based on mid-market, not upper-market, costs. It was felt that such properties were more likely to be upper-market.
• The total fire, smoke and water damage areas of ‘non-traditional’ hotels in the cost benefit analysis are twice that of a traditional hotel, given the associated commentary suggested modern built hotels were safer and more robust.
• Water supply costings for a hotel sprinkler installation to EN 12845 appeared more suited to an industrial building. In contrast, lighter installations requiring less water, like a hotel, would not incur such excessive costs.
• That there is a difference in benefits for a 40-bedroom hotel compared to a 20-bedroom hotel, despite the cost-benefit analysis assuming no difference.
• It was felt that if the assumptions were corrected, there could be a case for applying BS 9251 to hotels, as they would show that the benefits of installing BS 9251 sprinkler systems outweigh the costs, or that findings would then be positive for systems designed to EN 12845.

Other points raised on the cost-benefit analysis included:

• The need to undertake more research or widen the search for appropriate data on which to base the analysis given the data pool of hotel fires resulting in fatalities is very low.
• To revise the section on multi-occupancy social housing being placed in a commercial to flat conversion, for instance, as it: seemed to run counter to the premise of applying AFSS into blocks as a finding; was perceived to over-estimate maintenance costs and; did not take account of wider costs if there was a fire, such as the social costs caused by displacement of tenants.
• The examples did not seem relevant or appropriate because BS 9251 only recommends sprinkler systems for certain building types, and BS 9251 would not align with use for hotels, which could cause issues with certification.
• A need to revisit the analysis to ensure comparisons made are technically correct due to the lack of a definition for small hotels in the analysis, or that small hotels could be included in the analysis.
• Clarifying ‘ongoing maintenance costs’ with a real-world example or compared with the maintenance costs of electronic fire detection and alarm systems.

Island communities impact assessment (ICIA)

Q28. Do you think that any of the proposals in this consultation would lead to, for example, increased costs and/or impact island communities significantly different from its effect on other (if applicable)? Please provide any comments below. If selecting yes, please specify which of the proposals you refer to and why you believe financial, regulatory or resource implications will be impacted.).

One third (35%) of those answering Q28 felt the proposals would not impact island communities, compared to almost a quarter (24%) who thought they would. The remaining 41% were unsure.

A quarter of all respondents left a comment at Q28. The most prevalent themes were an increased cost burden for island communities, benefits for remote communities and infrastructure challenges.

Increased cost burden

Some respondents highlighted that costs in island communities could increase as a result of the proposals. Greater costs for island communities than those on the mainland were highlighted, especially given that there may be a lack of local specialists, e.g. fire suppression installers. Additional costs were thought to occur in island communities for maintenance, adding fire safety measures, sourcing materials from the mainland, and converting buildings to hotels. However, one respondent expressed the view that costs for the proposed measures should not be greater for island communities, except for additional transport costs.

Benefits for remote communities

Two respondents highlighted that because remote locations can be further away from fire and rescue services, fire safety improvements will be of greater benefit to islands.

“The natural isolation of islands from other geographic areas means it is more challenging to supplement fire services resources due to the transport challenges. Therefore, fire service resources required to safely fight a hotel fire will be more limited and more difficult to provide and maintain on an island. Therefore, the provision of fire suppression systems in hotels will be a greater benefit to the islands, where a fire will be suppressed or extinguished prior to the arrival of the fire service and as a result conditions will be safer for firefighters responding, allow more time for occupants to safely evacuate the premises and require less resources to resolve.” – British Automatic Fire Sprinkler Association

Infrastructure challenges

One respondent highlighted potential infrastructure issues, specifically those related to the water supply for automatic fire safety systems in remote locations.