Centralized hub for verification of complex fire engineered solutions in Scotland: feasibility study

Independent opinion on the need, appropriateness, potential structure and potential operations of a central hub for assisting in the verification of complex fire engineered designs.

This document is part of a collection

12 Annex B: Stakeholder Comments 

12.1 Academia

Is there value in the concept of a centralized review hub?

12.1.1 There is a sense that moving to a certification system, as with structural engineering, would be appropriate in the long run. However, there are a lot of questions around how competency would be determined, what ongoing continuing professional development (CPD) requirements there might be, how project work audits would be conducted, and who would administer such a scheme. For now, some type of review is needed.

12.1.2 Liability associated with a fire engineering certification scheme could also be a challenging issue. At present, perception is that LAV carries liability for ‘approving’ design. Fire engineers would have this under certification scheme.

12.1.3 A central review hub (hub) could be helpful, as there is a lack of awareness of self-limits for some practicing in the fire engineering area. There does not seem to be a ‘code of conduct’ by which engineers practice only in their area of competency. Since fire engineering is not a mature and well-defined discipline, and engineering is not a protected term (profession) in Scotland, there is considerable variability. The ethical standards do not seem to be at the same level as other engineering disciplines.

12.1.4 It could be of value since the market is small, there is a limited number of fire engineers, and the level of expertise is variable. With small numbers, it difficult for LAVs to find and hire fire engineers. Lower salaries than the private sector does not help. The situation can be exacerbated when fire engineers come in from England and elsewhere who are unfamiliar with the Scottish building regulatory system and assume the same practices as elsewhere.

12.1.5 There is value for assisting in a wide range or project types, not just ‘complex’ or ‘high-risk’ (which are undefined), since in some LAVs there is a lack of personnel with fire engineering knowledge, which can make it difficult to decide if something is a ‘minor’ deviation or a ‘significant’ change.

12.1.6 A value of the hub concept is that the creation of a stakeholder review group enhances communication and understanding between groups, which should be a good thing for Scotland.

How would you view the Role of the Hub in Relation to the Existing System?

12.1.7 In practice it seems as if some LAVs are using the SFRS in a review capacity, not just as a statutory consultee, which creates complications, since the LAV is the decision-maker, and desires of the fire service may in some cases differ from the requirements identified by the Building Standards.

12.1.8 An issue that would need to be addressed is who makes the decision on what goes to the ‘hub’ and what is dealt with locally.

12.1.9 The elephant in the room is design / acceptance criteria. At present compliance based on comparison to TH. It is assumed TH based on societal risk tolerance, but not specified. Standard of care not clearly defined. No way to determine if uniform level of fire safety is being delivered.

12.1.10 The decision-making structure needs to be clear. Who ultimately makes the decision? Does the hub make a decision or give advice?  If advice, is that enough? Ultimately the client will decide if they like the answer: if they do not, what are their options? 

12.1.11 Liability is a question under hub as well – who has liability, and for what?

12.1.12 Scotland should be open to looking at other countries, e.g., Norway, Japan, etc., to see how they have arranged things. Various models, tools, approaches may be useful.

Do you have views on a form which may be suitable?

12.1.13 The extent of the ‘problem’ is unknown, so it is difficult to make a judgement on how the hub might be structured and resourced.  How, and how often, the hub is used, would influence resource needs. It might be helpful to have someone look at the fire engineering designs that have been approved over some period of time to better define the situation.

12.1.14 In Scotland the procurement process dictates the diversity of disciplines required and associated responsibilities. In the past, the architect was responsible for delivering an integrated design. This cannot be expected anymore. The construction manager increasing plays this role, and they may not understand how the strategies are intended to fit together.

12.1.15 The concept of a ‘three-prong’ verification approach was tabled and feedback was that it could be a useful concept to explore.

12.1.16 If the hub goes forward, there should be some built in review / audit process to periodically assess what is done, how it is working, what changes might be needed, and ultimately whether it delivers value.

What make-up of membership is appropriate?

12.1.17 Membership should come from BSD, LAVs / LABSS, the fire engineering community, and SFRS, and if a suitable role exists, academia, government representative (Minister, not BSD), someone with procurement expertise, and someone with fire engineering / building regulatory expertise from outside of Scotland (e.g., England, Wales, Ireland). 

12.1.18 As a statutory consultee, the SFRS should not be part of the hub, since that might create a conflict. If part of the hub, legislation might need to be changed. The SFRS should remain involved in some manner, given their expertise and experience. 

What qualifications and experience is appropriate for members?

12.1.19 An important issue for the hub will be determining who sets the competency level for hub members, and how that is determined (i.e., not just what competencies hub members should have, but who makes judgment and appointments). It seems as if a starting point is Chartered status in the disciplines that are deemed necessary.

What limits on member service might be applicable?

12.1.20 Anyone (actively) involved in fire engineering work should not be in the hub.

What attributes of a design would trigger review via the hub?

12.1.21 This is a difficult issue. As noted previously, ‘complex’ and ‘high-risk’ are undefined, and since some LAs lack personnel with fire engineering knowledge, it can make it difficult to decide if something is a ‘minor’ deviation or a ‘significant’ change.

12.1.22 A trigger for sending a fire engineered design to the hub should be any design for which the LAV does not believe that they are competent to assess. It is assumed most will have some level of competency, but it varies based on size of authority, types of projects they see, and the like.  A major issue seems to be ‘deviations’ from the TH. Having guidance around this might be helpful. 

12.1.23 The intersection of energy efficiency and fire safety seems to be one of the biggest issues at the moment (e.g., Grenfell Tower). How to comply with Standards for sustainability and safety open to interpretation.

What order of magnitude of response time is appropriate?

12.1.24 Response time depends on the project, but should be reasonably quick (e.g., 2-4 weeks). 

How do you think the hub should be funded?

12.1.25 Government seems appropriate. 

What other issues are important to consider?

12.1.26 There is a capacity issue. All fire engineering grads go to consulting firms, not to LAV or SFRS, and many out of country. Not that much interest by students, as they do not see fire engineering in many universities, so do not see it as an option. Could be more interest post-Grenfell, but still a long-term issue.

12.1.27 The issue of ‘engineer’ not being a protected term was raised again in this regard as being problematic, especially in fire engineering, since the discipline is so broad.  

12.1.28 Another challenge for fire engineers is that they are not engaged throughout the entire process. Many just develop ‘strategy’ and do not develop detailed designs, check that the constructed building complies with design, or provide guidance for building in use. This should be considered (required) as part of a certification scheme.

12.2 Architects and Technologists

Is there value in the concept of a centralized review hub?

12.2.1 The concept seems fine. Having an integrated perspective is important. Coordination of performance in performance-based design is essential. 

12.2.2 The current situation is that some 90% of design firms are less than 10 people, with fire engineering similar, and LAVs with limited fire engineering resources. A centralized review hub could help in this environment. Ultimately, a certification scheme for fire would seem appropriate, but the market does not seem to be there.

12.2.3 The approach to projects / procurement changed in 2005. Before then, the architect had significant responsibility and oversight. With change of regulation, client has responsibility. As such, the architect is more in an advisory role now, and it is up to the client what they want to do. It is difficult to push people in a particular direction – one can only encourage.

12.2.4 Development of the hub has the benefit of sharing of knowledge and experience for the benefit of all.

How would you view the Role of the Hub in Relation to the Existing System?

12.2.5 Hub would be a resource for assisting in review of complex designs. 

Do you have views on a form which may be suitable?

12.2.6 The hub would need expertise that has appropriate ‘T’ shape – depth of fire engineering knowledge but breadth of understanding of how it fits into and integrates with the overall design. Complexity is difficult to define, but following RIBA type approach can help to make sure critical issues are addressed.

12.2.7 The RIBA Plan of Work approach (2013) provides a good model that could be followed to identify what pieces of fire engineering strategy and design need to be submitted at what point in the project to get everyone on board and to check that the design components all work together.

What make-up of membership is appropriate?

12.2.8 If the hub goes forward, there needs to be a coordinator who understands fire performance as part of overall building performance, with the competence to identify issues that may exist and allocate the appropriate expertise to sort the issues.

12.2.9 A wide range of expertise would be needed in the hub. Industry is in an ‘atomised’ state – need breadth of expertise including architectural, architectural technology, fire, fire service, verifier and more, depending on specific project. Need to have holistic, integrated perspective.

12.2.10 With respect to SFRS, they have a statutory consultee role, so that needs to be considered.

What qualifications and experience is appropriate for members?

12.2.11 The IFE have a set of subjects for which competency is required. The issue is a combination of depth, exposure and time (i.e., what time is required to reach what depth of understanding across which areas). Some work was done on this in the past – perhaps time to revisit it.

What limits on member service might be applicable?

12.2.12 Not discussed.

What attributes of a design would trigger review via the hub?

12.2.13 Triggers difficult to define, since all buildings different, level of expertise diffuse, and complexity a function of the particular building.

What order of magnitude of response time is appropriate?

12.2.14 Difficult to determine at this point, but three months is better than three years.

How do you think the hub should be funded?

12.2.15 Funding should come from all (i.e., all participate to the benefit of all).

What other issues are important to consider?

12.2.16 Every building should have a fire strategy, but all do not. Some buildings seem to be ‘over designed’ for fire. Perhaps others are in the opposite direction. Without a strategy, it is difficult to know what is being targeted, and what impact future changes might have. For example, if design based on certain systems working as intended, and inspection and maintenance not being kept up, what will be the outcome if a fire occurs?

12.2.17 Overall, level of fire engineering knowledge seems to have decreased a bit, at least in architecture / architectural technology, with very little being taught is associated university programs. With limited number of engineers, and limited resource in LAVs, the situation can be problematic.

12.2.18 Knowledge and know-how have diminished over time. Knowing what you know, and knowing what you don’t know, are important boundaries. Thinking you know, but not really knowing or understanding, is problematic. With an increasing focus on more narrow fields of study / understanding, the broader knowledge of how the pieces all fit together is diminishing. This is a big educational need.

12.2.19 To change from existing approach(es), the industry needs to see value. The development of robust details reflects an approach where the value is seen in many ways. The structural certification is similar. For fire, there would need to be clear processes, competencies, accountability and need.

12.3 Building Standards Division 

Is there value in the concept of a centralized review hub?

12.3.1 The concept of a hub in general seems like a good thing; however, what the hub would do is not well-defined, so difficult to assess value. Questions exist around whether it would be used for all fire engineered designs, or only ‘complex’ and ‘high-risk’ buildings and designs, what are resourcing needs, and how is competency of LAVs helped.

12.3.2 The need is not well-known, since there are some local authorities with fire engineering competency within the staff, and not all other authorities have the need for fire engineering competency on staff, at least on a regular basis. Perhaps a bigger issue is that some fire engineers lack appropriate self-awareness of limits, and have too much of a ‘can do’ attitude, in that if it has anything to do with fire, I can do it (even if not properly qualified or competent). The combination is problematic, and it is acknowledged that there have been issues, so the hub could provide value. 

How would you view the Role of the Hub in Relation to the Existing System?

12.3.3 The question is what do the LAVs need now (in the short term)? There is an expectation that the LAV should be able to determine whether ‘minor’ deviations are fine and when they are outside of their competency. If the focus is on ‘complex’ and ‘high-risk’ buildings and designs, that may be the highest value. However, the issue of when and how to make determination needs to be sorted. (The ‘three-prong’ verification idea was introduced and there was support for the concept.)

12.3.4 The roles of the LAV, SFRS, BSD and the hub need to be very clear. The LAV is the decision-maker. The SFRS have a statutory consultee role and should not be decision-maker. The hub should not be run by BSD – there is a Views process that needs to be maintained, and the hub should not muddy the waters. Perceived and real conflicts of interest must be identified and addressed.

Do you have views on a form which may be suitable?

12.3.5 Comments on the form ranged from under BSD to supported by the LAVs (LABSS). Fees would have to be such so as not to be a deterrent from use. Liability would have to be clarified for any participants, including entity overseeing the hub. Perceived and real conflicts of interest must be identified and addressed.

12.3.6 Regardless of form, there would be need for appropriate quality assurance processes, performance monitoring, audits and the like. 

12.3.7 A significant issue that impacts the form of the hub is the role it performs – would the hub be undertaking a decision or providing advice? If making a decision, how does that legally fit, and what are liabilities? If providing advice, how is that different from a View, which the LAV must have regard to but does not have to follow? 

12.3.8 Scope of reviews should be well-defined. Focus should be on technical issues, i.e., are the data, tools and methods used appropriate to the problem, and applied appropriately, and was the breadth of issues considered / assessed appropriate (i.e., from an holistic perspective, did the fire engineered analysis adequately address all fire safety impacts of the building as associated with the requested change). 

12.3.9 Liability is a big issue in the post-Grenfell environment, at least for engineers in England.

What make-up of membership is appropriate?

12.3.10 Make-up of the hub should include LAV, SFRS, and FE representation. Role of BSD not clear with respect to the Views process. Would be good to be involved, but cannot be in conflict with statutory role.

12.3.11 The roles of the LAV, SFRS, BSD and the hub need to be very clear. The LAV is the decision-maker. The SFRS have a statutory consultee role and should not be decision-maker. The hub should not be run by BSD – there is a Views process that needs to be maintained, and the hub should not muddy the waters. Perceived and real conflicts of interest must be identified and addressed.

What qualifications and experience is appropriate for members?

12.3.12 With respect to qualifications, one size does not fit all. May need IEng and CEng and equivalent, as per project needs. 

12.3.13 Perceived and potential conflicts of interest with BSD and SFRS need to be sorted.

What limits on member service might be applicable?

12.3.14 No discussion.

What attributes of a design would trigger review via the hub?

12.3.15 Potential triggers for review could be something like risk classes (as in Eurocodes for structures), with focus on consequence if failure occurs. ‘High-risk’ and ‘complex’ designs may be drivers, but terms need to be defined. 

12.3.16 The question of whether designs can be ordered to go to the hub should be addressed, or if only voluntary. If not used, what is the benefit?

What order of magnitude of response time is appropriate?

12.3.17 The timeliness of response is difficult to address in advance, as it depends on project scope, complexity, etc.  In any case, it should be relatively fast, as that is one challenge in the existing system.

How do you think the hub should be funded?

12.3.18 As a resource for LAVs, funding the hub could come from levies, fees, etc., but it is recognised that there can be problems with assuring funds collected as part of building control get appropriated to building control within local government.

What other issues are important to consider?

12.3.19 No particular discussion. 

12.4 Developers and Owners

Is there value in the concept of a centralized review hub?

12.4.1 The idea of a centralized review hub is appealing especially if it can help to reduce the significant time required for approvals. Almost all projects have deviations from the TH, often involving stairs, lifts, exits and more, with a range of complexity. The time for approval from the warrant application has been as long as 18 months, with a recent project taking 9 months. The challenge is on the resource side of the LAVs, with perhaps not enough staff. The fire engineering usually goes well, but the lengthy delay for verification has implications for the project.

12.4.2 Experience with the verification process is varied. Because LAVs are resource limited, it can take months to get an answer. The ‘simple’ designs (TH compliant or ‘minor’ deviation) are usually addressed in reasonable time with no concerns. It seems like complex design go into the queue and stay a long time.

12.4.3 From a project management perspective, any fire engineered design sits high on the risk register, driven largely by the unknown and lengthy time for review. The hub could potentially help with this. 

12.4.4 A challenge with fire engineering design in Scotland is that many fire engineering practices are small, do not have a broad range of experience and expertise, and in some cases do not know the Scottish system very well. This creates challenges when it comes time for approval, as well as during the design phases. New technologies (e.g., electric vehicle charging plates, driverless cars) create problems for designers and verifiers. A high level of knowledge and competence is needed.

12.4.5 In concept the hub could be helpful in delivering consistency. Knowing who you will be working with, and how decisions are made, are significant to the success of a project. With limited and distributed fire engineering resources, this could be good.

How would you view the Role of the Hub in Relation to the Existing System?

12.4.6 Keeping the function within the building warrant process seems best – keep it simple. There just needs to be clear understanding of when something goes to the hub, what it will cost, and what the timelines are. If everything goes to the hub that could slow things down. Timely decisions by LAVs should be expected based on feedback from the hub.

12.4.7 Overall, the existing process is sound, the relations are good, the problem seems largely to be resourcing and time to a decision.

12.4.8 Time for review and approval is important. Sometimes process takes a long time, with delays at LAV, SFRS feedback, etc. When LAV has time for pre-warrant discussions, that helps a lot. If the hub can help with this, it would be good.

Do you have views on a form which may be suitable?

12.4.9 No particular views. 

What make-up of membership is appropriate?

12.4.10 Input from fire engineers, architects, and the SFRS important. Need to have good practical knowledge as well as specific fire engineering knowledge. Academics could be helpful for review of complex models and such.  Someone from BSD would be desirable.

What qualifications and experience is appropriate for members?

12.4.11 Not specifically discussed. 

What limits on member service might be applicable?

12.4.12 Not specifically discussed.

What attributes of a design would trigger review via the hub?

12.4.13 Complexity comes in many forms, and not just new build. In many cases, complexity arises out of multi-tenancy (and even multi-owner) issues, working new or renovation of existing buildings in and around existing spaces owned or managed by others, and trying to get all the pieces to fit together. The space itself may be ‘simply’ retail, but the integration of the building / space into existing can be extremely complex. Even something as ‘simple’ as alarm and evacuation zones can be a challenge.

12.4.14 Consideration of the process for structural certification might provide some insight on triggers for what type of project would go to the hub. There are many steps in the structural certification process, but it seems to help move things along.

12.4.15 Different risk classifications for buildings was noted as one potential trigger. Complexity is a more difficult baseline to describe. 

12.4.16 The ‘three-prong’ concept for verification was raised. There was general support. The concern is with the middle level – the decision on what the LAV can handle and when it goes to the hub. This needs to be clear. A two-level approach might be cleaner.

What order of magnitude of response time is appropriate?

12.4.17 This may vary based on complexity of project, but should be weeks not months, as is sometimes the case now. 

12.4.18 Time to approval is always difficult, but for small projects, the order of 2 weeks seems appropriate, and perhaps 6 weeks for a larger project. Having a process that provides consistency from start to finish will help a great deal.

How do you think the hub should be funded?

12.4.19 There would be no problem paying additional fee for the centralized review if the fee is allocated to the verification process and the time required for a decision is significantly reduced. 

What other issues are important to consider?

12.4.20 As noted above, the existing process is sound, the relations are good, the problem seems largely to be resourcing and time to a decision – anything new that is added should be focused on reducing time to a decision and not adding time and complexity to the process. 

12.5 Fire Engineers

Is there value in the concept of a centralized review hub?

12.5.1 At the end of the day, the motivation is better, safer, buildings. There are some perceptions in the market that there are concerns with some buildings approved under the existing system. A hub could help. 

12.5.2 In 2005, the Scottish government brought in a ‘performance-based’ system, but did not provide adequate resources to support such a system, particularly from the verification side. The fire area is particularly under-resourced. A benefit of the hub approach is it helps in this regard.

12.5.3 Something needs to change. LAVs do not evaluate fire engineered designs in the same way, and it is not clear why that needs to be. More consistency in the market is better for everyone.

12.5.4 There is a clear shortage of fire engineers in Scotland, with LAVs being significantly under-resourced in this area. These lead to issues of fire engineering competency in LAVs – not because they do not want the expertise – they cannot find or afford it.

12.5.5 Such a hub would be of a high value for the verification of designs for projects acknowledged to be outside the normal scope of an LAV. Clearly, the continuing value would be dependent on the supply of proposals for ‘complex’ buildings and the continuing lack of fire engineering expertise in the LAV’s generally. The Hub may generate a level of consistency of appraisal that has been lacking for several years. it should be noted that before the LAV’s were given the authority to assess submissions for acceptability a central unit for all Relaxations (from the statutory minimum standards) did exist and did operate successfully. The unit served all local authorities in Scotland.

12.5.6 A hub could have value as a short to medium term solution due to the limited numbers of appropriately trained fire engineers in Scotland, it is prudent to make best use of the available resources. It is not a long term solution, as there has to be clear lines of responsibility for the fire engineering of buildings. The hub would need to make sure all users of the system were aware of its role and the function of its members so that it was not seen as a continuation of the present system of reviewing fire engineering designs.

12.5.7 The hub would have benefit in the short term, while the wider industry is forming/taking a professional approach-such as registration. The hub will not result in the required structural changes needed, manifesting in qualified competent engineers who can be trusted in the context of the building regulations.  However, the hub could help as a temporary measure to improve service, but unfortunately without wider industry controls (on who can practice), the benefits of the hub will be mainly limited.

12.5.8 A centralized hub will allow for a much more consistent approach throughout the industry. It is recognised that fire engineering is subjective and what is one person’s ‘safe’ might have another slightly nervous. However, a centralized pool will aid this as reviewers will be able to discuss the matter and come to an agreement (i.e., approve or reject). This will also help increase the level of understanding of fire engineering as a centralized group (we believe) would have a more specific knowledge base, this increasing the industry standards.

12.5.9 A centralized hub will provide more consistency with the way fire engineering solutions are processed compared with the current system where various firms are appointed to act as third-party checkers for local authorities.  At present the time it takes for some local authorities to appoint a third party checking consultant can lead to very long overall times for the fire engineering reports to be processed and approved. This can cause significant problems for many projects, which typically run on tight programmes. As numerous firms are currently appointed to act as third-party checkers for local authority building standards, there are a wide range of views and approaches that are taken to deal with fire engineering solutions. This can lead to inconsistency with feedback and with suggested technical approaches. This inconsistency and the long approvals times can lead to uncertainty with fire engineers and clients.  We have had feedback from some clients that because of this uncertainty, they no longer wish to pursue a fire engineering approaches and would rather design to meet standard code approaches even though it results in a less efficient design. That is a concern that could be addressed by a centralized hub, assuming the speed that they process fire engineering applications is better than the current system, and the approaches and technical feedback is consistent. The more consistent approach will not only help clients, but it will also help less experienced, or less competent, fire engineers to improve their technical approaches.

12.5.10 A downside of current situation is built-in conservatism – ability of the market to innovate is limited. A concern with the hub is unintended consequences – not just for building but the sector.

12.5.11 If the hub goes forward, it needs to provide good value, and who pays needs to be clearly defined.

How would you view the Role of the Hub in Relation to the Existing System?

12.5.12 There were differing views as to whether the decision-making should remain with the LAVs, with most in agreement that is how it should remain. However, roles and relationship between hub, LAVs, and SFRS need to be very clear. If projects go to the hub, and then still need to go to a Views process, just gets more costly. In the end, just meet the Technical Handbook.

12.5.13 The hub formation needs to be central and have agreed mix of people. Need to minimize tensions between groups and foster collaborative relationship. Need to remember that ultimately the hub is to benefit the end user – the market – roles, responsibilities, decisions and process all need to be clear. 

12.5.14 Fundamental issue is resourcing. If LAVs had proper resources, there would be no need for a hub. Under the current situation, wide range of approaches to deal with gap, from a very few having internal resource, to 3rd party, to hesitancy to approve fire engineered designs.

12.5.15 There is some concern of friction between LAVs and the SFRS. However, the LAVs have the verification authority – SFRS provides input as a statutory consultee. 

12.5.16 The legislation for standards of building direct the LAV to be the most important authority. Therefore, the relationships need not be demonstratively different to the current situation. That is that the SFRS act as consultants to the LAV, on request, and the BSD are contacted for advice on the interpretation and application of the published guidance. If further advice is needed on specific issues the LAV is able to buy-in the necessary expertise. This expertise may be available from a range of ‘experts’ and the LAV may need advice on the selection of an adviser/consultant. The hub may have contact with experts in fire safety engineering and the LAV would be advised to make contact with the Hub for assistance.

12.5.17 The continuing use of performance-based designs, has put additional strain on the resources of regulators. The system has been introduced without sufficiently trained personnel being in place to undertake or review it. The formation of a central review panel will allow Local Authorities still to have the control to grant building warrants in their geographical area and have confidence that a fire engineered solution put forward is appropriate. The SFRS currently are supporting many Local Authorities in fire engineering by reviewing submitted designs on behalf of the Local Authority.  This is outwith their current role and is a potential conflict of interest with their role under the Procedure Regulations, a review panel would still allow the SFRS to contribute to the review of a proposal but allow them to focus on the fire fighting and rescue aspects. BSD’s role should be to facilitate the process by ensuring relevant qualified personnel are involved in the process to enable a rigorous review to take place. As the guardians of the building standards system they can then disseminate the findings allowing a consistency of procedures to develop. The output from any review would need to be treated appropriately by local authorities and not just be ignored. The Local Authority Verifiers must have regard to any decision given when determining the building warrant application. The review panel would also recheck (send back) to Local Authorities applications that should be within their capability.

12.5.18 The local authorities, fire service and BSD would be technical advisors to the hub as their primary role unless they are appointed as a technical reviewer (on the condition they are qualified), specifically on matters relating to firefighting, procedural issues, and building regulations.

12.5.19 A centralized hub should have specific specialist knowledge and be afforded the funds for training in this fee, if this is not provided it is difficult to see how exactly things will change (without training the same problem exists, it just has a new face). It would be our view that the hub would be a centralized approving body for fire engineering, not your typical approving authority. Having actual fire engineers in this position, removes the need for the Fire Service to be treated as third party reviewers and, therefore, allows SFRS to resume a consultation role. BSD may be the home of the hub or the hub would need to be totally independent from BSD. BSD would provide a great base for the hub and could be completely independent from the local authorities, this also provides the hub with direct access to BSD’s background knowledge to the Technical Handbooks guidance. What needs to be defined in the approval authority of the hub (i.e., can the hub be an approving body or is the hub a third-party reviewer which recognises and agrees with the fire engineering solution without also having the final say on approvals.

12.5.20 The primary role of the central hub will be to act as technical advisors to local authority building control, the SFRS and the BSD.

Do you have views on a form which may be suitable?

12.5.21 Regardless of final structure, the hub must be adequately resource to deliver on the intent, or it will not address the challenges currently faced. There needs to be a clear process. All LAVs, fire engineers, SFRS, etc., need to buy in and follow the process. The process needs to be transparent. Basic documents like a process flowchart would be helpful.

12.5.22 With respect to service in the hub, a qualified person to screen submittals and decide whether to send to the hub is needed. Views differed as to whether this and other members of the hub should be permanent / semi-permanent (substantially dedicated) or rotated in and out. Key attributes are expertise and relevance of experience, which should be current.

12.5.23 Scotland is small. One might ask why there needs to be 32 local authorities. It could be that a central hub for all verification functions would be an efficient option.

12.5.24 The hub means different things to different people, as it is currently undefined. It could be one location, or perhaps focused on the largest authorities (Glasgow and Edinburgh), with different expertise or functions in each, or other. 

12.5.25 The hub should be something where all fire engineered designs go into – this gets to consistency, competency, and related issues. There should be a clear review process and the verification decisions need to be clear.

12.5.26 The hub should be somewhat removed from individual LAVs, until they have needed resources. It would seem that LABSS could form / support a hub. SFRS has a big role. BSD is conflicted out because of the Views process.

12.5.27 There are many actors and linkages. At the centre will be the coordinator. The coordinator would be capable of deciding on the members of the team that would make up a specific hub. Decisions about the need for a traffic engineer or a structural engineer or a smoke control designer or a fire safety engineer would be made by the coordinator. Each ‘expert’ would be represented by a segment. The level of expertise of each individual would then be represented by the circumferential bands. Any one of the people in the hub could be a technical person from an LAV, a private consultant, or a government official.

12.5.28 The hub should be administered by BSD. Who on receipt of a referral would determine its suitability and notify the applicants accordingly. If a referral is accepted, BSD would appoint appropriate persons to review the project depending on its nature, (complexity of calculations CFD etc.)  They would keep under review a ‘pool’ of suitable experts that they can call upon.  The fire engineering personnel would be rotated to prevent the appearance of bias.  The Institution of Fire Engineers (IFE), Scottish Branch, could be contacted by BSD for assistance in identifying suitably qualified and experienced personnel when the fire engineered design or building is sufficiently unique, for example tall CLT buildings.

12.5.29 The hub should operated / administrated by full time staff with the resource to meet service conditions required by industry, the unit must be responsible for service and be sanctioned if not fulfilling its obligations, otherwise there will be no change from the service provided to date from local authorities.  The unit should not be thought of as an add on to building control or the fire service, but an independent professional organisation able to operate without prejudice from the wider industry.

12.5.30 A hub would either need to operate as a body which reviews fire engineering solutions and has its own employees with specific training, or the hub acts as a pot of third party reviewer from consultancies and each consultancy has to undertake a certain amount of reviews (per number of CEng staff operating in Scotland). Either way there are cost implications involved that would result in an increased fee for local authorities or fire engineers (i.e., a hub-subscription fee).

12.5.31 The hub should be group of individuals with experience in both fire engineering design and verification, ideally from a range of backgrounds. This group should have the expertise to deal with any fire engineering solution proposed and have the tools and the resources to process them quickly. The individuals within the group should not change on a regular basis and they should aim to provide a consistent approach to dealing with the applications, both technically and procedurally. To avoid a conflict of interest, the fire engineer should not be a practicing fire engineer employed by a private firm.

What make-up of membership is appropriate?

12.5.32 With respect to service in the hub, a qualified person to screen submittals and decide whether to send to the hub is needed. Views differed as to whether this and other members of the hub should be permanent / semi-permanent (substantially dedicated) or rotated in and out. Key attributes are expertise and relevant experience, which should be current.

12.5.33 A hub would need to be flexible in many ways. It has to have expertise and competency in many areas, including fire. It needs to have a coordinator to decide what it is about a design characterizes it as needing to be reviewed by the hub personnel. There needs to be access to a wide range of expertise and skills, from CFD analysis of a specific issue to how that fits holistically with the building design and operation.

12.5.34 The role of BSD is unclear – some suggest BSD should facilitate the process, much like when the Government reviewed all such submittals in the past – while others are concerned that going through BSD will introduce delays, not to mention the potential conflict with the Views process. There was a view that, as it is now, all submittals should go to the LAV, who then decides whether to send it along to the hub, which would help reduce delays.

12.5.35 Assuming that support staff are available then one ‘expert’ in each of the necessary sectors could be sufficient in number. Note that there could be several hubs in operation at one time. A pool of expertise would be sensible from which to populate an appropriate hub. It is suggested that 20 people from all appropriate backgrounds could be selected initially. This number to be added to or subtracted from as the system develops. Some training on analysis and assessment may be necessary for the coordinators – probably the only full time paid post.

12.5.36 The hub would need to include representatives of the Local Authority the SFRS, BSD and fire engineers. The numbers of each would be as follows: 2 appropriately qualified building standards personnel, 1 from the authority in whose geographical area the works are proposed and 1 member from another Local Authority; A member of the SFRS fire engineering unit and if desired an attendee from the geographical area where the works are proposed; 3 fire engineers, 1 whose fire engineered solution is being discussed and 2 fire engineers from a ‘pool’ of suitably qualified fire engineers, (BSD would need to run and maintain such a list, which would need to be publicly available); The list of fire engineers would include consultants, academics SFRS and building standards personnel, with experience in specific areas; BSD would be able to support the meeting with the resources that they required, but it would be expected it would include the technical author for fire and administrative support.

12.5.37 It is hard to say, but would need to be specific to the requirements of specific projects. A variety of technical staff may be needed for a project – both a fire safety engineer and structural fire engineer may be required for projects, and on other projects none.  It is important that the competent engineers and technical advisors are held professionally responsible for their work, unlike the present system where the approval authorities take no responsibility for their actions.  Without this, the system will fail and be seen effectively as trial by committee - something that cannot be accepted by a professional body. This could be mitigated by the adoption of a professional registration system.

12.5.38 The hub needs to consist of fire engineers or verifiers who specialise in fire engineering. It cannot be made of a pool of people without fire engineering training otherwise it will be ineffective. The exact number of representatives is difficult to nail down, it will depend on the complexity of each project and the number of projects to be reviewed.

12.5.39 A Fire Engineer, a local authority verifier, and a SFRS fire engineer would be an ideal mix.  But again consistency is key if we are to see an improvement over the current system.

12.5.40 If people are rotated through the hub, conflict of interest needs to be carefully addressed. Likewise, statutory conflicts, such as with BSD (Views) and SFRS need to be taken into consideration. Legislation would have to be looked at if changes in responsibilities considered.

What qualifications and experience is appropriate for members?

12.5.41 Anyone working in the hub should have highest qualification, e.g., Chartership, Expertise and experience crucial. The ‘gatekeeper’ needs to have the right knowledge, expertise and experience to know when to send something to the hub. Someone with broad knowledge of how a building works is needed too. A process like the RIBA process might be helpful in looking at designs more holistically.  

12.5.42 The verifier does not necessarily have to be a CEng or IEng in fire, as they have broader responsibilities for verifying across several disciplines. However, verification of fire engineered designs must be undertaken by those with appropriate qualifications and competency in fire engineering, especially for designs that deviate from the Technical Handbooks.

12.5.43 If people are rotated through the hub, conflict of interest needs to be carefully addressed. Likewise, statutory conflicts, such as with BSD (Views) and SFRS need to be taken into consideration. Legislation would have to be looked at if changes in responsibilities considered.

12.5.44 All participants need to have at least a first class honours degree in a relevant discipline AND be qualified professionally to Chartered status. To have had at least 5 years’ experience in a responsible role(s) in an aspect(s) of fire safety engineering.

12.5.45 All attendees should be members of an appropriate professional organisation. Fire engineers should be Chartered Fire Engineers, while local authority and SFRS attendees should have at least a degree in fire engineering. All should have appropriate training, knowledge and expertise to be aware of the hazards and risks involved and be part of an engineering registration program. If the role of the representative from BSD is to facilitate the process, publish the outcome and ensure the regulatory procedures are complied with, then there is no need for them to have a specific fire engineered qualification. All professionals present must be able to demonstrate that they have met their CPD requirements in a relevant area.

12.5.46 If the purpose of the hub is to review fire engineering, the hub must be staffed by competent and qualified fire engineers. It is irrelevant whether the engineer is a consultant or from the approval authorities as long as they meet the qualification/competency criteria, work in a transparent and professional manner and take responsibility for their actions.  The hub will fail if technical decisions are not made by competent persons using appropriate engineering knowledge and methodology, further there must be a mechanism to enforce professional practices on the hub, i.e., a regular audit process undertaking by peers, similar to that provided to structures, gas, electric. This would fit into registration for all fire engineers (designers or approval authorities).

12.5.47 It will entirely depend on the fire engineered solution. Qualifications of IEng and CEng for standard reviewers is recommended.

12.5.48 A chartered fire engineer or a fire engineer with at least 10 years’ relevant experience in Scotland could be considered suitably qualified.  The local authority verifier and SFRS representative should either be chartered or have at least a BEng in fire engineering, or suitable experience dealing with complex fire engineering solutions.

What limits on member service might be applicable?

12.5.49 The employment of ‘building professionals’ who will populate the hub(s) could be very flexible as permanent staff would result in fixed views and limited knowledge for application to a complex challenge. Although a totally flexible workforce would not be a good idea as the task for the coordinator to gather a suitable group could be difficult and very time consuming – a situation that should be avoided. Maybe a ‘skeleton’ group should be employed for one or two groups (hubs) but the majority of the staff would be part-time people. The part-time staff need to regard service on a hub as more important than other work. There should be no ‘conflict’ of interest as the ‘target’ for all is a fire safe building. Assuming that it is not practicable to avoid any commercial or industrial people in a hub then each of the professional people in the hub need to declare any potential conflicts.

12.5.50 For the fire engineering community to have confidence in the hub, the process has to be transparent and the appointment of members to the review clear to all. As regulators are independent from design pressures there would not be the same concern as to who attends.  The reality however, is that there are very few local authority and SFRS personnel with fire engineering qualifications and experience.  This will result in certain individuals being called upon to attend the hub more regularly than the other members. LABSS and others should use this process as a learning exercise and send along representatives from other authorities to watch learn and understand.

12.5.51 A registration process for all involved would be an effective tool for mitigating/avoiding a conflict of interest between different parties and upholding professional standards.

12.5.52 As stated above, the hub needs to be for fire engineering and employ fire engineers. If the role of the hub is expanded to include a centralized approving authority role (i.e., similar to the current role of local authority verifiers), the required level of knowledge to review a fire engineering solution will be missing. We accept the concerns raised that a private firm would be looking out for business opportunities, however, in our experience in England, the higher level of fire engineering knowledge is found in approved inspectors as they spend more money training staff than a governmental approving body, who frequently face cut backs.

12.5.53 A fire engineer serving the hub should not be able to review a fire engineering report prepared by their firm. Therefore, the hub’s fire engineer should not be a practicing fire engineer employed by a private firm.

What attributes of a design would trigger review via the hub?

12.5.54 The trigger(s) that cause a submission to a LAV to be ‘called in’ by the hub might be: very tall; complex space uses and complex geometry; those that house dangerous activities; significant variation(s) to the guidance in Section 2; ‘extreme’ designs (floating buildings); extensive application of fire engineering; and use and application of computer aided fire safety design.

12.5.55 Buildings of national significance, hospitals and tall buildings should all go through the hub. In addition any fire engineered solution that is outwith the expertise of the Local Authority Verifier. For example CFD modelling, calculations, FED, or where the regulators or fire engineers knowledge and competence is in question or it is believed that there is inappropriate use of the design codes etc.

12.5.56 It is difficult to understand why a hub would only be used for complex and high risk buildings: does this mean that incompetent fire design will not result in death or injury in less complex buildings? The uncertainty associated with fire design is not just bounded by the size and complexity of the building, therefore there is little confidence in the ability of a non-competent/qualified designer or verifier being able to undertake fire engineering in any building irrespective of complexity. My understanding of structural, gas, electrical is that professional competence is required to all buildings irrespective of size, given fire is a critical safety system why should it be treated any differently.   Therefore all projects which deviate from the Technical Handbook (guidance) should be sent for review, the complicity and size is irrelevant in the context of incompetent design and verification. I think a verifier or indeed the Scottish minister responsible would be hard pushed to defend their action of not using competent review on the basis of it being a small and non-complex building, if it materialized the design was sub-standard, bad design and verification is independent of size and complexity and is a function of incompetency, which is related to a underregulated industry that does not support competence.

12.5.57 As a minimum information should be passed to the hub as soon as a local authority recognises that they do not have the specific knowledge in house. This should also be recognised by the project fire engineer to help smooth out the approval process. Documentation required, the fire strategy from the local authority as soon as possible (i.e., once they recognise they do not have the knowledge in house).

12.5.58 I think all deviations from standard code guidance, i.e., all fire engineering solutions, should be subject to hub verification.  That way, there will be no confusion or time needed to agree on a category of the fire engineering solution as complex or simple, high risk or low risk, and the process will be simplified.

What order of magnitude of response time is appropriate?

12.5.59 This is a difficult aspect of the Hub activity. Least time: 2 weeks. The construction programme for the building(s) will influence time needed. The construction process could be very long, more than 10 years, with discrete multiple phases. The time constraint can only be assessed from the initial analysis of the submission. Time for any particular project cannot be predicted with any certainty as there will be some dependence to cooperation of people and bodies outside the immediate Hub.

12.5.60 The timescales should be similar to currently provided under the BSD’s ‘Views’ process. On receipt of a request for a project to be assessed by the hub BSD, should issue a response within 48 hours, stating whether the BSD consider it an appropriate referral. The timing will depend on the nature and complexity of the fire engineering proposal and whether sufficient information has been submitted to allow it to be reviewed. BSD would then notify the applicant of the proposed timescale, who would need to accept it before the process could begin.

12.5.61 Extremely difficult question as all projects and circumstances differ, but 2-4 weeks would be within norms.

12.5.62 Two weeks to review a fire engineering solution and provide response. However, this may need to be tweaked depending on the number of fire engineering solutions received per day and the level of complexity.

12.5.63 This should ideally be based on the industries requirements for design and construction programmes. Larger projects typically have longer programmes that allow more time for building warrant and fire strategies to be approved. This would need to be informed by our collective experience of typical projects, but could be in the order of: 2 to 4 weeks for small projects with limited fire engineering; 4 to 6 weeks for projects with more fire engineering; and longer times could be expected for major projects.

12.5.64 There was agreement that pre-warrant discussions are helpful, and most LAVs happy to have such – when time permits. Getting discussion on issues early, and agreeing path forward, is a major issue. Waiting until the end almost always causes problems. How will the hub help this?

12.5.65 Response time is difficult to specify. A key issue is having a qualified person making the initial determination, and having whatever review resources needed to be readily available.

12.5.66 Documentation and time constraints include: (i) the same documentation as submitted to LAV; (ii) assuming that the following is not available in the submission to the LAV: test results (where a request can be justified) for materials, components and systems; (iii) design calculations; (iv) maintenance regimes for fire safety critical elements (advisory OR under the Fire (Scotland) Act); (v) advice on replacement of systems that are safety critical (advisory OR under the Fire (Scotland) Act); (vi) type of construction contract;(vii) construction programme) and (viii) arrangements to observe and assess changes during construction.

How do you think the hub should be funded?

12.5.67 There are several layers: (a) Scottish Government – for permanent staff; (b) LAV to self-fund contribution of own staff seconded part-time on a project specific basis; (c) project budget – for contributions from client design team; (d) all project budgets + LAVs + SFRS + Local Authorities – for general funding for the part-time members of Hubs; and (e) maybe from ‘the industry’ through a national levy!

12.5.68 The Scottish Government recently reviewed the fees for Local Authority Verifiers.  Included in the implementation of the review was that some of the additional income would go towards funding the role of BSD.  This was to allow BSD to undertake research, talks and other works to support Local Authorities and improve the Verification process in Scotland.  As it is not envisaged that there will be a large number of projects going through the hub, it would be reasonable to expect BSD to fund the running of the hub out of the additional monies they now receive from Local Authority Verifier.

12.5.69 Government or local authority or combination. One way of reducing costs to the country would be the adoption of a registration scheme that would improve the application standards reducing the energy required for the individual reviews,  as well as speeding up the warrant process, this would give clients and the public confidence that they were getting safe and effective buildings. Given the commercial competition between Scotland and the other countries in the UK, any tools that give Scotland a commercial advantage need to be implemented.

12.5.70 Local authority approval fees increase (if governmental), fire engineering fees increased (agreed rate throughout the industry) if a pool of engineers, private body approved inspector role specific to fire engineering.

12.5.71 Government, local authorities, possibly building warrant fees.

What other issues are important to consider?

12.5.72 Fire engineer should be involved from ‘cradle to grave’ for any assurance that systems / features installed and function as intended. Not the procurement system in Scotland. It was noted that the SFPE performance-based design approach calls for an Operations and Maintenance Manual (OMM) to be developed, and that NFPA 3 and 4 provide helpful resources for testing and commissioning of integrated performance of fire protection systems.

12.5.73 CPD programmes: Such programmes for any or all of the construction professions. Could be on general topics within fire safety or on parts of fire engineering by request. At present (2018) there seems to be no provision. Attendance could be required as part of the review process!

12.5.74 As the majority of projects are designed before a building warrant is submitted the review panel would need to be able to consider fire engineered solutions prior to building warrant submission. I think the trigger of complex and high risk may be misleading, while the outbreak of fire in such buildings may have catastrophic outcomes all live should have the same value, and even some of the simplest buildings with the smallest segments of fire engineering could contain the highest risk for improper engineering. The responsibility of design should clearly rest with the fire engineer, and BSD should encourage the continued development of the profession along the lines of other engineering professions such as structural engineers.  A clear matrix should be developed identifying the different risk types and the level of checking that should be undertaken. 

12.5.75 The BSD with their many years of knowledge in the area of Certification and the setting up of such schemes, should assist the Fire engineering community. They will be able to help the fire community see the benefits of such a scheme, such as: The confidence given to local authorities by the undertaking of independent third party monitoring; Robust procedures for membership; Recognises that experienced and qualified professionals can accept responsibility for their design; Recognition that members carry professional indemnity insurance; Recognition that members are covered by a robust complaints procedure.

12.5.76 The persons responsible for setting up the hub (assumed to be BSD), need to develop a plan of what they want to see and have a round table discussion with all interested parties (e.g., local authorities, the fire service and fire engineers).

12.5.77 I can understand the benefits of a hub in the short term but have concerns to its effect over the medium to long term, to such an extend it will not alter the situation where there is a lack of competence and expertise throughout the industry. Fundamentally the “hub” is a small iteration of the present system, being centralized to ideally generate a greater degree of professionalism and application of technical review, however this does not change the fundamental issue, that there’s no industry controls on who can practice fire engineering, which effectively means technical and professional competence is not a requirement to design and verify buildings for fire.   

12.5.78 Fire is a safety critical system, however unlike Structures, Gas, Electric there’s no controls on who can practice, which in light of recent events I would imagine the Scottish Ministers and the public would be shocked and amazed that Scotland does not have ANY qualification/competence controls that the other safety critical systems named have adopted. 

12.5.79 Furthermore unless the industry puts a focus on providing an industry staffed by highly competent and skilled professionals, away from the current focus on formulating the regulatory system for approvals by simple applied guidance, we will not optimise buildings for the advantage of Scotland, but will continue to produce buildings that are thrown together with little thought for holistic and principle safety, I have provided a Quote from the Cullen Report (Piper Alpha) which highlights the problem of relying on  guidance which adheres well to a low skill/qualification baseline found in industry: “many regulations are unduly restrictive in that they are of a type that impose solutions rather than objectives and are out of date in relation to technological advances. There is a danger that compliance takes precedence over wider safety considerations”.

12.5.80 Fundamentally the hub will allow the present situation to fester which will not increase competence within the industry with a continuation of all associated endemic negative effects, without the individual engineers accepting responsibility for their competence and not hiding behind approval authorities (competent or not), the industry will not improve to a standard where safe, efficient and effective designs are the norm.

12.6 Insurance Industry   

Is there value in the concept of a centralized review hub?

12.6.1 There is a lot of inconsistency, in design and approval, in Scotland and across the UK. A hub could help in that regard in Scotland.

12.6.2 As technology changes, associated knowledge and expertise is required. This is not just for building-related technology, but the fire engineering analysis tools. The hub could help concentrate the needed expertise.

12.6.3 The hub could perhaps provide clarity in interpretation of the Standards, such as whether sustainability is applicable to fire safety design of buildings (i.e., a building that burns down is arguably not sustainable).

How would you view the Role of the Hub in Relation to the Existing System?

12.6.4 A hub might help foster better communication between parties involved, and help stakeholders better understand the decision-making process. 

Do you have views on a form which may be suitable?

12.6.5 It seems like the hub should be independent, with dotted line reporting to the BSD. The hub would be in support of verifiers, but it seems like it can also help the market.

What make-up of membership is appropriate?

12.6.6 Need a mix of expertise. No one person knows everything. Need to have expertise in fire engineering, the tools used, how the building comes together.

What qualifications and experience is appropriate for members?

12.6.7 Not specifically discussed beyond needed appropriate expertise. 

What limits on member service might be applicable?

12.6.8 Not discussed. 

What attributes of a design would trigger review via the hub?

12.6.9 Complexity is a trigger, but difficult to define. High risk might be people sleeping, new technologies (e.g., CLT), high-rise, area of building, multi-tenancy, shopping centres. 

12.6.10 Reviews need to happen at all levels, including occupancy. The draft Nordic standard on building control was noted as a potential document to consider.

What order of magnitude of response time is appropriate?

12.6.11 Not discussed. 

How do you think the hub should be funded?

12.6.12 Not sure about funding. This is a government issue to answer. Insurers have their own research and review and approval process, so not sure they would support a hub.

What other issues are important to consider?

12.6.13 The hub should help the process and not add time or problems.

12.7 Local Authority Verifiers (LAVs)

Is there value in the concept of a centralized review hub?

12.7.1 From experience, many of the fire engineered projects are too small to warrant review from something like a hub, and given the experience and support within the authorities (via LABSS), there are many cases where a hub would not be needed.

12.7.2 Some type of centralized hub could provide some benefits. It could be a resource for LAVs when needed. It could also be used for unique, one-off designs, which are completely engineered or deviate significantly from the TH. However, it is expected that the total number of such designs would be rather small. 

12.7.3 It was noted that the idea of a hub has merit, particularly for complex projects, as long as it fits within the verification process, does not undermine verifiers, is not abused by being used for even minor deviations, and can take advantage of review assistance as already exists within LABSS.

12.7.4 There is value in the idea of a central hub for complex fire engineering solutions e.g., Level 3 in the recent letter issued by BSD. However, this should be a short-term solution until local authorities have the appropriate number of qualified staff to deal with the demand. 

How would you view the Role of the Hub in Relation to the Existing System?

12.7.5 If it goes forward, the central hub should serve a supportive role to local authority verifiers with, the approval of building warrants still lying with the local authority. Unless the legislation changes the hub would technically have no authority unless the BSD used the system such as granting of relaxations / views process. The use of SFRS for 3rd party reviews for fire should not be permitted. The hub structure should be set up and SFRS should be a consultee or sit within the hub. The BSD would facilitate any process within the hub and ensure that a proper and rigorous review would take place. They would also have to check qualifications of each party that sit on the hub. 

12.7.6 If a hub were to be formed, it would have to fit within the verification process, and rationalised with the view process. The hub would have to have a clear remit and purpose.

12.7.7 Guidance around different levels of engineering and associated verification could be helpful. It was stated that some designs use comparative analysis, but that the baseline for comparison is not always appropriate. It was noted that similar input has been obtained in other countries, such as Sweden. It was noted that the Nordic standards committee has a draft document for review of fire engineered designs, which at the time of the meeting was out for public consultation. 

12.7.8 The idea of a ‘verification method’ such as C/VM2 in New Zealand was raised as being something that could be of significant value for designs which are more than simply minor issues (e.g., extending travel distance by 1m) but not a fully performance-based design. It was noted that the Australian Building Codes Board (ABCB) has developed a fire verification method now for Australia as well, which at the time of the meeting was out for public consultation.

Do you have views on a form which may be suitable?

12.7.9 A question was asked about the 3-route verification process in Japan, which was explained (Note: see discussion in Annex A).

12.7.10 It was noted that LABSS have qualified people to help out a local authority when needed as internal resource. The 3rd party review option is also available. A hub could perhaps replace the need for the 3rd party review. 

12.7.11 It would be helpful to have a filter process to screen what can be done ‘internally’ and what warrants going to the hub.

12.7.12 There are two forms which the hub could take: (1) There is a permanent review panel which invites people with the relevant expertise to comment on a design and the panel makes the decision based on the outcomes of the review. (2) A panel is formed each time from a pool of people with the required expertise. The people would have to be rotated in order to prevent any bias within the various stake holders. There is also a sensitivity of commercial information regarding designs which maybe an issue particular for fire engineering companies.

What make-up of membership is appropriate?

12.7.13 The number of people that sit on the hub would have to be relatively small so that a decision could be reached.

12.7.14 It was noted that verifiers have a broader remit and understanding of a project beyond just fire, and that such an holistic approach is needed for proper verification. 

12.7.15 It was discussed that the assistance offered within LABSS could essentially serve as the ‘gatekeeper’ role, helping local authorities make decisions on what can be addressed internally, providing LABSS resource where needed, and facilitating additional review by experts where deemed appropriate.

12.7.16 It is proposed that the number of verifiers would have to be at least two: one from the local authority and one with the appropriate fire engineering qualification. If SFRS is involved, the same would be required from SFRS. There might need to be two also from fire engineering community. To maintain an even balance, perhaps a member of the fire section from BSD.

12.7.17 The SFRS needs to remain involved as they play a significant role. The role should stay as a statutory consultee, and not verge into any approval function, as verification is the role of the LAV.

12.7.18 BSD should not be involved, or at least should not do anything to impact the views system and responsibilities. 

12.7.19 A range of subject material experts may need to be available to the hub, at the highest level, if certain expertise is needed as part of review. However, it is not anticipated that this would be needed often.

12.7.20 The BSD would have to administer the hub and if a design required to be referred they would inform all parties and select relevant qualified people for the review. The hub would have to consider having the people for the relevant backgrounds such as fire engineers, local authorities, SFRS and possibly academics that are specialist in a particular field.

What qualifications and experience is appropriate for members?

12.7.21 Verifiers have a range of expertise across the breadth of building design, which includes fire engineering in some authorities. Fire engineering is in demand the most, so most authorities have some experience in the area. Those authorities with experience have graciously shared their knowledge and experience with others, and have served as resources for review when an authority lacks the necessary knowledge and experience.

12.7.22 All people should be a member of a professional body. Fire engineers should be chartered, while local authority and SFRS should be at least degree level with relevant experience in dealing with fire engineering solutions in the short term. Local authorities and SFRS should also be trying to attain CEng or IEng qualifications. Similarly, the BSD should have suitability qualified members to sit on the panel.

12.7.23 The Section 34 letter caused significant concern, as it was open to interpretation. It is not clear that IEng or CEng in Fire Engineering is needed, or exactly how it will help, since verifiers need knowledge across the broad spectrum of areas regulated by the building standards. Some staff have experience and competency, but not the post-nominal letters. This is just a process issue. 

12.7.24 The Section 34 letter has resulted in some LAVs sending all fire engineered design for additional review, even for deviations they handled in the past. In part driven by interpretation of the Section 34 letter to require this, in other cases caused consideration as to whether decision should be made based on competency in fire engineering. The Section 34 letter has negatively impacted confidence in some cases.

12.7.25 Discussion around background of Section 34 letter noted that the underpinning research was tabled as a starting point, not an end point, and that it was understood that work was required on delineating the levels of complexity / analysis that might trigger different levels of competencies / qualification as part of the verification process. 

12.7.26 It has been observed that since the Section 34 letter some designs have been submitted, purporting to have followed BS7974 or other fire engineering guidance, of which that level was not used in the past or necessarily warranted. This adds unneeded complexity and cost to the verification process. Qualifications should be appropriate to the work undertaken.

What limits on member service might be applicable?

12.7.27 The BSD should be impartial, providing the decision taken are not political and are based on the technical aspects of the report. Similarly the local authorities are impartial when making decisions on designs within their geographical area. There is potential conflict when companies are reviewing other companies’ reports and there may also be a commercial sensitivity regarding some design information particular if it is unique.

12.7.28 Ultimately under the legislation, the local authority makes the decision to accept a design (unless the BSD grant some form of relaxation). Depending how the hub is set up and administered (if set up and administered by BSD and reviews are issued as part of the relaxation process) then the local authorities is bound by that decision.

12.7.29 The input from the hub is there expertise and to evaluate the fire engineering design. It would be up to the BSD to issue the acceptance of the design based on the report by the hub and any other consideration which they feel may be required (e.g., continuing requirement). 

What attributes of a design would trigger review via the hub?

12.7.30 From experience, many of the fire engineered projects are too small to warrant review from something like a hub, and given the experience and support within the authorities (via LABSS), there are many cases where a hub would not be needed.

12.7.31 There is difficulty in defining what is complex. The view process has been used for single stairs, external wall systems, and similar, but these are not necessarily complex. There is already a two-stage process: the verifier needs help or does not. If help is needed, they can go out and get it within LABSS or third-party review.

12.7.32 The difficult in addressing complexity was further explored, with issues such as predicting movement through some amount of smoke without consideration of toxicity, reliance on safety management practices of owner (which may change over time), and mix-and-match of different engineering approaches without necessarily demonstrating their compatibility.

12.7.33 They are a number of considerations, because a building is large or of national significance does not mean it has to go through the hub (after all they are numerous design guides such as those for hospitals) because it may still comply with the guidance. The guidance clearly states that an alternative solution can be provided but must still meet the functional standard. 

12.7.34 The main trigger would have to be variation or alternative from Section 2 in the Technical Handbook (although with recent events the Technical Handbooks will be reviewed) as the legislation sets this out.

12.7.35 The only issue is when this trigger is activated to send this to the hub. If the BSD Section 34 letter is still current, that would mean any deviation from Section 2 would be sent to them which is not practical to manage. The IEng level on the letter would cover 95% if not all the fire engineering solutions submitted currently. Some local authorities can deal with this level of application because they have qualified staff and a level of experience in dealing with fire engineering solutions. Therefore Level 3 (on Section 34 letter) should be sent to the hub.

What order of magnitude of response time is appropriate?

12.7.36 Any hub which is set up would delay the processes if this is referred after the warrant is submitted. If submitted at an early stage this may reduce the period to grant the warrant as most of the issues should or could be addressed during the review by the hub. This would encourage architects and fire engineers to discuss at an early stage projects which deviate from the guidance.

12.7.37 The hub which would or could be made up from people that have a normal day job, therefore timelines could be an issue for people on the hub and responding to key performance objectives set by Scottish Government.

12.7.38 If a design is referred then the BSD could give an initial response to whether the design should be reviewed by the hub, then the timeline would depend on length of time to set up the review board, complexity of the application etc.

How do you think the hub should be funded?

12.7.39 Funding could come from government, but could also be from fees paid by LAVs which use the hub (as collected from fees from those submitting complex designs for review). 

12.7.40 The funding should be by Scottish government. This would maintain the impartiality of the review and more importantly the decision. If any 3rd party contributes to the hub it could be considered a bribe.

What other issues are important to consider?

12.7.41 While the idea of certification (self-certification) for fire engineering, such as with structural engineering, is interesting, there have not been any fire engineered designs through the verification process without changes, and it would seem unwise to push too fast at this point – the market is just not ready.

12.7.42 There are numerous problems within the regulatory and fire engineering community in relation to number and competency of qualified staff. It should however be noted that the number of fire engineering solution that are submitted is not large within Scotland and many projects which provide an engineering report do not require one. The hub appears to be trying to address the issues with the lack of qualified staff within the local authorities and none of the issues within the fire engineering community as a whole. The hub if set up correctly should be used more as a short term aid for local authorities rather than a long term solution.

12.7.43 The focus of a review of a fire engineering report by different parties will vary depending on their role e.g., the fire brigade looks at it mainly from a fire fighting and rescue point of view, the local authority from the deviation within the guidance and fire engineers mainly in how far they will be allowed to deviate from the guidance and what they are required to provide for that deviation. 

12.7.44 If the hub is organized by the BSD they will review any report to see if it is required to be reviewed by the hub group. The BSD should establish clear guidelines on what the criteria will be for this and if they decide not to have it reviewed what will be the process, do they review it their self, or do they refer the local authority that submitted the report to another local authority that has expertise in a particular area.

12.7.45 There is also a role for LABSS here to pull its resources and expertise gained over the years to aid authorities, which do not have any qualified staff.

12.7.46 The problem changes if the BSD are saying that local authorities have no competent staff to carry out a review of a fire engineering solutions in which case any deviation should be reviewed by them. (but if you go by the requirements of the section 34 letter they do not have the qualified staff either).

12.7.47 The definition of high risk or complex building would have to be clarified as people’s perception would vary greatly.

12.8 Scottish Fire and Rescue Services (SFRS)

Is there value in the concept of a centralized review hub?

12.8.1 The verification system in Scotland is not broken. However, LAVs have a lack of resources, and use the SFRS, 3rd party verifiers and peer reviewers to help.  Ultimately, verifier has decision-making role. If better resourced, they could do better.

12.8.2 The concept of a central review hub has merit, given LAV resource limitations: in many ways, the SFRS FEG serves in that capacity now, as an unpaid consultee. However, it would seem to be better to have fire engineering resource within LAV as compared to have a hub.

12.8.3 If any formalized hub is brought forward, it would need to be efficient. Processes and procedures need to be in place, decision-making clear, and outcomes understood. At this point, it is difficult to know what might go to the hub. Overall, process would work better if verifiers were properly resourced.

How would you view the Role of the Hub in Relation to the Existing System?

12.8.4 The SFRS FEG has beneficial knowledge, expertise and experience, and should see all fire engineered designs, regardless of whether other form of hub is developed or not.

Do you have views on a form which may be suitable?

12.8.5 The SFRS FEG can provide the services as understood to be needed, but need statutory authority and should be paid for the service. Capabilities, skills, etc. can be expanded if deemed necessary. All fire engineering designs should be submitted, and should have all necessary documentation. Feedback is given to the LAV, who ultimately makes a decision.

What make-up of membership is appropriate?

12.8.6 A key concern is the independence of any proposed hub. Having a broad range of people to draw from does not guarantee independence, if they are still working in the market (including academics, architects, fire engineers). The SFRS FEG is independent.

What qualifications and experience is appropriate for members?

12.8.7 Reviewers need to be adequately qualified and competent. It is not clear that requiring IEng or CEng (in fire engineering) necessarily accomplishes this. It might be too early to require such without having a better understanding of what such qualifications actually means.

12.8.8 The SFRS Fire Engineer Group (FEG) has fire engineering expertise and computational modelling expertise to review fire engineered designs, and has the added benefit of operational experience.

What limits on member service might be applicable?

12.8.9 There is concern that there are resource limitations if one prohibits practising professionals from participating, so as to avoid conflict of interest. 

What attributes of a design would trigger review via the hub?

12.8.10 One part of the challenge with the existing process is that some verifiers only accept fire strategies at the end, when work is nearly complete, instead of in the beginning, when most beneficial.

12.8.11 There is concern that the SFRS FEG only sees part of a design in some cases, and not the full documentation. It can be difficult to assess the suitability of a design component out of context with the entire design approach. In addition, some documentation, even for components, is incomplete. There is no statement of assumptions, limitations, bounding conditions, or similar rationale.

What order of magnitude of response time is appropriate?

12.8.12 Not specifically discussed, but it was noted that a better understanding of perceived problems with the current process is needed. Quantification of delays in the verification process would be helpful.

How do you think the hub should be funded?

12.8.13 Not specifically discussed. 

What other issues are important to consider?

12.8.14 While the SFRS FEG provides feedback to LAVs, they often do not get any information in return, so the SFRS does not know what final solutions were implemented. There are concerns that the procurement process isn’t working as it should, since fire engineers not involved in beginning of projects, which can sometimes lead to issues at the end.


Email: sarah.waugh@gov.scot

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