15 May 2018
If there is one lesson from Grenfell, it is the danger of complacency to the risks from our built environment. Dame Judith Hackitt will publish her review in the coming days and reveal how her thinking has developed since her Interim Report in December 2017. One aspect, which is not controversial and seems certain, is that she will call for structural safety and fire resilience to be elevated above all other matters (such as energy and acoustics) that are covered by building regulations.
What is more controversial is where she will call for future responsibility to be placed in determining what constitutes fire resilient design and construction. In the Interim Report, the construction industry was accused of “waiting to be told what to do” with the prescription in approved documents deemed to be “largely owned by Government”. There are several arguments for increased responsibility being taken by industry in contrast to Government prescription. These include: that it permits innovation; it ensures that those who are expert - the construction industry itself - are the ones making the rules; and, it moves the balance away from Government making rules which risk “some [in the construction industry] looking for ways to work around it”, as stated in the Interim Report.
However, these arguments seem to ignore the fact that the construction industry is already involved in the evolution of building regulations and approved documents through processes such as industry representatives on committees, experts used as consultants and periods of wider industry consultation. Furthermore, the current regulations do permit innovation that is outside or beyond the approved documents. And finally, a system that shifts more responsibility on the construction sector leaves just as many loopholes for those “looking for ways around it”. So what will the final report say on this issue?
Perhaps, no matter where the balance is struck between Government ownership and construction industry ownership of regulations, approved documents and guidance, the real answer lies in greater prominence and application of CDM regulations to the design, construction and operation of facilities with respect to fire resilience.
CDM provides a mechanism that highlights responsibility, and a mechanism for imposing sanctions. It has focussed the minds of designers on their obligations throughout the operation of an asset and at demolition stage: “How will that be cleaned safely?” “How will we safely demolish?” A higher profile to application of CDM thinking to fire resilience may shake up designers from complacency to the risks from our built environment in the area of fire.
One specific area is increased risk due to the use of timber frame. For perceived sustainability reasons it seems that a blind eye or, at least, only half an eye is applied to the issue of timber fire risk. Remember, it was said earlier that it is likely Hackitt will call for structural safety and fire resilience to be elevated above other matters.
The HSE is clear in their HSG168 Construction Guidance: timber frame constructions, when all fire resilient measures are not in place, pose increased risks. Anyone in construction knows that even if workmanship is perfect, through the lifetime of an asset there is degradation. In the realm of fire resilience compromising fire protection boarding or fire compartmentation happens. Is it any wonder then that Government statistics show that timber framed buildings subject to fire suffer more extensive fires? It is exactly what the HSE state in their Guidance would happen if all protection is not in place. And indications from Grenfell and inspections of many buildings demonstrate that fire resilience measures are often not as intended and frequently deficient.
Cognisant of these facts, designers can, and perhaps should, respond by choosing non-combustible structural materials in order to discharge their CDM responsibilities. If there is one lesson from Grenfell, it is the danger of complacency to the risks from our built environment.
1. Analysis of fires in buildings of timber framed construction, England, 2009-10 to 2011-12; Department for Communities and Local Government; December 2012.