Chapter 6: Risk management – ongoing control
229. Chapter 6 covers the responsibility for fire safety in the building and the fire safety messages for residents. There are important reminders of controlling building work and alterations (including resident's DIY) and ongoing inspection, testing and maintenance of fire safety systems and equipment.
230. Arrangements for managing fire safety should include:
- Developing a fire policy and appointing someone in the organisation to take overall responsibility for fire safety.
- Using residents' handbooks and other media to engage with residents and communicate fire safety information, and to have a channel for receiving concerns from residents.
- Providing generic training to ensure housing officers and others visiting blocks of flats have fire safety awareness.
- Preparing fire procedures and making everyone aware of them.
- Managing the risk from building works, including adopting a 'hot work' permit system.
- Putting in place programmes for routine inspection, testing, servicing and maintenance of fire safety measures and systems.
- Monitoring the internal common areas and external areas through formal inspections, and as part of day-to-day activities by staff.
- Carrying out fire safety risk assessment reviews.
- Liaising with SFRS and encouraging residents to take up the offer of Home Safety Visits.
Responsibility for fire safety in the building
231. Those responsible for fire safety in high rise domestic buildings are owners; local authorities, housing associations and factors operating on behalf of residents as the housing providers and managing agents.
232. There should be a fire safety policy for the high rise domestic building which includes the roles and responsibilities of all organisations who contribute to the management of fire safety.
233. It is important that an individual in the organisation has overall responsibility for fire safety, even though they may not be on site to manage fire safety on a day to day basis. There should be routine fire safety inspections carried out where possible.
234. It is common in larger housing management organisations to split responsibilities. Estates maintenance teams may deal with repairs, routine testing and inspection of fire safety measures, and the letting department may be responsible for ensuring residents understand the conditions applying to alterations to their flats, and have fire safety information. Where responsibility is shared, one department should have overall control and authority to ensure that activities are coordinated.
235. Where there are commercial occupiers in the building, there should be coordination and cooperation on fire safety issues, between all parties.
Engaging with residents
236. Residents are integral to effective fire safety to keep themselves and others safe. It is important they know and understand the fundamentals of fire safety in the building and how they can contribute to it. Those responsible for fire safety have a significant role in engaging with residents and to share fire safety messages. This should support them to prevent fires in their own home and in the common areas, including:
- Basic advice for residents (A leaflet containing fire safety information for residents of high rise buildings ("Keeping yourself and others safe from fire in your high rise buildings") can be found on the SFRS website: https://www.firescotland.gov.uk/.).
- Maintaining the building security by making sure doors close behind them when they enter or leave.
- Never storing or using petrol, bottled gas, paraffin heaters or other flammable materials in their flats, on their balcony or in shared areas.
- General policy on what common areas can and cannot be used for.
- The importance of the self-closing and fire resistance features of their flat entry door to slow spread of fire.
- Safeguarding communal escape routes, making sure fire doors self-close and are never wedged, tied or otherwise held open.
- How to raise building fire safety concerns and need for repairs.
237. The information should also inform people about action to take if they discover a fire.
238. The "Stay Put" advice applies when there is a fire elsewhere in the building (Annex 1 contains a fire action notice for where 'Stay Put' applies). Basic fire action notices are a simple, effective way to tell residents the actions they should take in the event of a fire.
239. A Residents' Handbook is a useful place to put basic fire safety advice for new residents and for their future reference. Providing regular information and campaigns to promote fire safety maintains awareness.
Instruction and information for non-residents
240. Caretakers, housing officers and others working in, or visiting, blocks of flats need to have awareness of the fire safety measures in the building and the procedures in the event of fire.
241. In-house staff should have appropriate training to monitor fire safety as part of routine visits and inspections.
Preparing for emergencies
242. There should be a suitable emergency plan (usually a fire action notice) for the premises. Only on rare instances in high rise blocks of flats, will a more elaborate emergency plan be necessary.
243. When displaying a fire action notice it is good practice to place it where it is seen routinely by people entering the building. This can be by the main entrance or by the controls inside a lift.
244. Fire action notices must be relevant to the building, so most fire action notices designed for commercial buildings are likely to be inappropriate.
245. It is neither practical nor necessary to carry out fire drills and practice evacuations in domestic high rise properties.
246. It is likely that there will be residents with mobility difficulties, physical disability and mental health issues that impact on their ability to evacuate. It is not usually expected that those responsible for fire safety in the building need to plan or put special arrangements in place.
Controlling building work and alterations
247. There should be processes in place to scrutinise alterations and building work in common areas that could affect fire safety. Building Regulation approval should be obtained where relevant.
248. There is the potential for fires to start or fire safety measures to be impaired during building and engineering works for alterations or repairs. Examples of impairments to fire safety measures include:
- Holes made in separating walls and floors.
- Stairway doors removed for easier access.
- Parts of the structure opened without providing suitable fire-resisting hoarding to separate work areas from occupied areas.
- Site huts placed too close to the building.
- Gas cylinders left in the building overnight.
- Combustible building materials left in common areas.
- Access to a rising fire main inlet blocked.
- Parking over fire hydrants.
249. There should be clear, strict obligations from those responsible for the high rise domestic building for those undertaking works. These are to implement precautions when carrying out works to prevent issues arising. Incorporating conditions in contracts is commonly used to set out and agree the obligations. These should be reinforced by scrutinising method statements and with checks during the course of the works. Advice on fire safety during construction work is available from the Health and Safety Executive (HSE) and the Fire Protection Association (FPA).
250. Control should be applied to small works and maintenance and major projects since both can potentially create difficulties.
251. There should be control exercised over 'hot work'. Usually, this is by a 'permit to work' system that requires those carrying out the work to inspect the areas in which work is taking place, before and after the work, and to take all necessary precautions, including the temporary provision of fire extinguishers.
252. Residents should understand that work they might undertake should not be detrimental to fire safety, as in these examples:
- Changing the flat entrance door to one that is not fire-resisting and self-closing.
- Installing a new bathroom suite, without ensuring that fire separation to the common riser for fire stopping is maintained at the end of the job where there were breaches of riser walls created for new drains.
- New gas supplies to flats requiring ventilation to gas meters from unprotected openings into common corridors and stairways (Figure 10).
- Smoke vent windows with are replaced with sealed units.
- A new false ceiling installed without transfer grilles to allow smoke to reach existing permanent vents.
Fire safety systems and equipment - Inspection, Testing and Maintenance
253. Fire safety systems and equipment needs to be maintained in effective working order. This is achieved by having arrangements for routine inspection, testing, servicing and maintenance in place. British Standards apply to some systems and equipment maintenance and testing. The advice given on frequency of testing and maintenance should be followed. Minor deviations for practical reasons may be appropriate but this should be based on an assessment of risk. Appropriately competent in-house staff can inspect and test some measures; other work should be carried out by competent contractors. There are third party certification and approval schemes for assurance of quality, reliability and safety against a recognised standard.
254. If systems are tested by in-house staff, contractors need to be available through a call-out arrangement for required repairs.
255. It is good practice to keep records on the inspection, testing and maintenance of fire safety systems and equipment. Results should be made available to residents on request. Residents should also be notified of any defects and plans for remediation. SFRS should be notified of defects which could have a significant impact on life safety or their ability to undertake firefighting operations e.g. firefighting lifts, dry risers etc. Contact details can be found on the SFRS website.
256. The following are the basic requirements for routine testing and maintenance of fire safety systems.
Emergency escape lighting
257. Test each fitting periodically, except where the emergency lighting is a self-testing type. In most cases, the testing comprises monthly functional test to check that the luminaire has not failed. This is a simple test that can easily be undertaken in-house. An annual full duration discharge test is important to confirm that the batteries can supply the fitting for its duration. (Care should be taken not to leave a building entirely without escape lighting while batteries recharge after a test). Further guidance on testing and servicing emergency escape lighting systems can be found in BS 5266-8.
258. AOVs and electrically operated OVs should be tested once a month for correct operation using the manual controls provided. This is a simple test that can be undertaken by non-specialists.
259. Testing and maintenance of the interface between smoke detection and the controls associated with AOVs should take place at least twice a year, and in accordance with the manufacturer's instructions. Further guidance can be found in BS 7273-6.
260. Other systems of smoke control – including smoke extract systems and pressurisation systems – should be tested and serviced periodically in accordance with the manufacturer's instructions. This will normally be at least annually, but may involve monthly or more frequent functional tests where the systems are intended to protect the means of escape. It is important that those servicing such systems are familiar with the performance parameters used in the design of the system.
261. Further guidance on testing and servicing of smoke control systems can be found in BS 9999.
Smoke and heat alarms in flats
262. Smoke and heat alarms should be tested at least every month (preferably each week). It is usually the responsibility of residents to test smoke alarms in their own flat.
263. Landlords should use opportunities to check on the general condition of smoke alarms they have provided. For example, signs that a tenant has interfered with or disabled a smoke alarm is easily checked when visiting the property. A contractor can also test a smoke alarm while undertaking a routine visit to carry out a repair or at an annual gas safety check.
264. Further guidance on testing smoke alarms can be found in BS 5839-6. Alarms should be replaced at the end of their lifespan in line with manufacturer's recommendations.
265. Fire dampers in communal ductwork or rubbish chutes, should be inspected and tested periodically to ensure that they are functioning. This should be undertaken at least once every two years for those operated by fusible links and every year for those that are spring operated. Guidance on testing of fire dampers can be found in BS 9999.
Automatic fire suppression systems
266. Sprinkler systems and water mist systems should be inspected annually. It is unlikely that a landlord will have staff with appropriate specialist knowledge in-house. Contractors may need to be employed. Guidance on maintenance of domestic sprinkler systems can be found in BS 9251.
Rising Fire mains
267. Rising fire mains should be inspected every six months and tested every 12 months. Inspections are primarily checks to confirm that the outlets are not damaged and padlocks and straps on the landing valves are still in place. This could readily be carried out in-house. Testing involves pressurising the main, and will require a specialist contractor.
268. Guidance on testing and maintenance of rising fire mains can be found in BS 9990.
269. The firefighters lift switch should be tested weekly to ensure the lift returns to the fire service access level, parks with its doors open, and does not respond to landing calls. Monthly inspections should include a check to ensure secondary supplies take over in the event of a power failure. Annual servicing by a lift maintenance contractor should cover the correct operation of all aspects of the firefighters lift(s), including communication systems. Further guidance on testing and servicing can be found in BS EN 81-72.
Evacuation Alert Systems
270. Evacuation alert systems for use by SFRS should be tested and maintained in accordance with BS 8629.
271. Fire-resisting doorsets should be inspected every six months to check for defects such as:
- Missing or ineffective self-closing devices.
- Damaged or missing intumescent strips and smoke seals.
- Damaged doors or frames.
- Poorly fitting doors caused by distortion, shrinkage, or wear and tear.
- Newly fitted, inappropriate, door furniture.
- Doors that have been replaced using non-fire-resisting types.
272. Checks of flat entrance doors could be combined with routine repairs or annual gas safety checks. Further advice on routine inspection and maintenance of fire-resisting doors can be found in BS 8214.
273. Damage to walls or signs of unauthorised work in common corridors, lobbies and stairways – including DIY by residents – are likely to be obvious. Fire safety checks offer opportunities to inspect other areas such as riser cupboards, plant rooms and so forth.
274. Other opportunities, such as when flats become vacant or change tenancy, should be used to inspect the condition of fire separation.
275. Windows and other non-electrical means provided for venting smoke should be opened on a regular basis, at least once a year, to ensure they open freely.
Checking fire safety standards
276. It is good practice to undertake regular fire safety inspections as part of housing stock management. A fire safety inspection of high rise domestic buildings is a way to identify fire prevention and maintenance issues. The frequency of fire safety inspections may vary, depending on how successfully standards are being maintained. Frequent inspections are likely to be necessary in high rise domestic buildings where there are concerns about anti-social behaviour and a consequent threat of fire raising, or where a 'managed use' policy applies to the common areas.
Fire Safety Inspection - Checklist
The following should be checked:
- Monitor common areas and check they meet the policy.
- Doors to residents' store rooms, electrical cupboards, plant rooms, bin stores and other ancillary rooms are not left or held open.
- Entrance and exit doors are closing properly.
- Signs of damage to fire-resisting walls, doors and glazing.
- Smoke control vents have not been tampered with or obstructed.
- Fire exit signs or fire action notices are not missing or defaced.
- Fire detectors are in place and have not been damaged, covered over or interfered with.
- Rising fire main outlets are not damaged or obstructed.
- Entrance doors are closing effectively and security lights are working.
- Plant rooms and electrical cupboards are locked shut and bin rooms are secure.
- There are no materials sited or vehicles parked, close to the external façade.
277. Day-to-day activities that take place in a block of flats also provide opportunity to monitor fire safety in the common areas. Housing officers, repair teams, cleaners and any other staff or regular contractors can significantly impact on the standard in a particular building by being aware of what to look out for.
Being alert to the possibility of improving fire safety standards
278. Planned alterations and improvements to high rise domestic buildings can provide an opportunity to upgrade the fire safety measures. For example, a lift replacement can be upgraded to firefighters lift standard, particularly in relation to power supplies and will improve the protection afforded to firefighters. Where a block of flats is due for extensive refurbishment, careful consideration should be made when deciding what safety features should be upgraded.
Liaising with the Scottish Fire and Rescue Service
279. The SFRS undertakes visits to high-rise domestic buildings to obtain information so that operational crews can become familiar with the features of the building, including access, availability of water for fire-fighting, and fire-fighting facilities such as firefighters lifts and rising fire mains.
280. The high rise domestic buildings that should be visited is at the discretion of the SFRS. These visits are invaluable as pre-planning for an emergency and should be welcomed by those responsible for the premises.
281. The SFRS may also carry out an enforcement visit to check on whether the obligations to maintain the property and maintain the facilities for firefighters are met.
282. Home Safety Visits are a key component of the SFRS's community safety engagement and are available to residents. These can be highlighted to residents, particularly those who are known to need fire safety assistance.