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CONSULTATION ON REGULATIONS IN SUPPORT OF THE BUILDING (SCOTLAND) ACT

Building (Scotland) Regulations -
Requirement 2.15 Automatic life safety fire suppression systems

Introductory Paper

The third part of the consultation concerns the addition of a requirement for automatic life safety fire suppression systems in certain building types and comprises:

• this introductory paper and
• a draft of the additional technical pages showing the proposed guidance for inclusion within the Technical Handbooks.

The text of the proposed requirement is included in this paper.

Introduction

The purpose of this consultation is to seek out views on the definitions of exactly which building types should be required to fit automatic life safety fire suppression systems and to establish precisely what technical guidance should be given in connection with such systems.

The Building (Scotland) Act 2003 has established a new framework for the building standards system within Scotland. Regulations are currently being prepared to introduce the system and it is intended that it should start on the 1 May 2005. This consultation includes as its first and second parts the proposals for the Procedures and Fees Regulations respectively.

The Building Regulations which set out the actual requirements to be imposed on new buildings and conversions were issued for consultation in July 2003 and consideration has already been given to the comments submitted in response. These Regulations and the associated Technical Handbooks are currently being considered by other member states of the European Union to ensure they do not contravene the Construction Products Directive by forming a barrier to trade. The building regulations as consulted upon were a level transposition of the existing Technical Standards and do not introduce any significant new requirements. This consultation is a departure from that principle in that it introduces an additional requirement on a limited number of buildings. For this reason the requirements have been made the subject of a special and more detailed consultation.

BRE Research

In February 2004 the Building Research Establishment (BRE) published the results of a two and half year project "The effectiveness of sprinklers in residential premises" commissioned by the Buildings Division of the Office of the Deputy Prime Minister (ODPM) carried out by the Fire Research Station. This project had been supported by the Scottish Executive and funded by the Office of the Deputy Prime Minister.

The Executive Summary of this research is included as an appendix to this paper. It found that residential sprinklers are probably cost-effective for residential care homes (old persons, childrens and disabled persons care homes) and for tall blocks of flats (eleven storeys and above), but not cost-effective for other dwellings. It also found that for sprinklers to become cost-effective, high risk buildings may be targeted, and justified on a case-by-case basis using the cost-benefit approach developed in this project.

Proposal

This consultation presents proposals from the Scottish Executive to include requirements for automatic life safety fire suppression systems in some new buildings. It has been derived from the BRE research and from discussions with the Building Standards Advisory Committee and a variety of stakeholders. The buildings to be covered are:

• residential care buildings
• high rise flats
• sheltered housing
• enclosed shopping centres (enclosed shopping centres over 5,600 square metres in size are already required to install such systems, this is now being extended to all enclosed shopping centres).

There are also already many industrial and storage buildings where automatic fire suppressions systems are already installed in order to be able to have larger undivided spaces. This is not a mandatory requirement of the building standards, but a well established trade-off which will be unaffected by the proposed new regulation. In these contexts the concern is less with the immediate needs of escape and more with the need to limit the fuel available in a fire, therefore the automatic fire suppression is not required to be a life safety system and the response times of the sprinkler heads need not be so short.

The term being used in these proposals is automatic life safety fire suppression systems rather than the more colloquial "sprinklers". This is because it more accurately describes the type of system which is required. It should be automatic. It should be targeted on the saving of lives (and therefore have quick response components). The use of suppression system includes sprinklers, but also does not preclude other systems being used once there is adequate test data and design standards available to ensure that they are equally effective.

Conversions, alterations and extensions

Although the requirements will not apply retrospectively to existing buildings within these categories, should a building which is not within these categories be converted to serve such a function then it will also be required to be fitted with such a system. For example an existing residential care home will not be required to fit a system, but if an existing hotel was to be converted to a residential care home then it would be required to fit such a system.

Alterations and modifications carried out to buildings in these categories will not mean that sprinklers become necessary. However where significant extensions are made to such buildings then the extensions should be so fitted out. For example the refurbishment of a residential care home would not require the installation of a system, but if an additional wing was to be added to a residential care building then the new wing would have to be fitted with a system.

Definitions

One of the principal purposes of this consultation is to seek views on how the different groups of buildings should be defined.

Residential Care Buildings

It is proposed that the definition of residential care buildings includes homes for old persons, children and disabled people (including residential care homes, boarding schools and childrens homes). It is proposed to define these by reference to the services they provide and their category of registration under the Regulation of Care (Scotland) Act 2001.

Hospitals are specifically excluded from the definition of residential care homes because there is less argument for the installation for sprinklers. Hospitals have much higher staffing levels and the almost constant supervision of patients which is provided. There is also the potential to evacuate patients horizontally away from a threatened area into adjoining wards or departments and normally sufficient staff can be mobilised from other parts of the hospital in time to accomplish such an evacuation.

High Rise Flats

It is proposed that high rise flats should be defined as domestic building in which there is a floor at a height of more than 18 metres from the ground. This would mean that in most cases blocks of flats with seven or more storeys would be covered by the regulation. This height is a long standing definition within the building regulations system which is related to fire-fighting facilities, fire service equipment and rescue practices. It is lower than the height in the BRE summary findings, but in the detail of that report it is clear that there is probable cost effectiveness at the lower heights, the issue is simply one of available statistics. The research data was insufficient to give a completely reliable finding for the lower flats. If the higher level was adopted in Scotland, it would have virtually no effect as there are no new developments at that height.

The requirement would be for the installation of sprinklers within the dwellings and not the common areas. Should a fire start within a common area then the requirements for separating walls around flats should provide protection to the residents until the fire brigade has extinguished the fire.

Sheltered Housing

It is proposed that sheltered housing should be defined so as to include groups of houses which have been specifically designed and constructed to provide sheltered and supported homes for people who will need a high degree of assistance to be able to live independently. It is included because of the finding in the BRE research that high risk buildings should be targeted on a case by case basis.

It is not intended that the definition should include existing dwellings where modifications are made to enable people to remain in them for longer or to aid mobility (ramps, grab rails, special ironmongery etc.). Neither is it intended that the definition should include new build developments aimed specifically at people who have retired.

Regulation

The additional requirement will be in Schedule 5 of the Building (Scotland) Regulations. This schedule lists the building standards applicable to construction and is applied to all new buildings and to all designated conversions. The schedule is in six sections and section two covers issues related to fire. The new standard will therefore be numbered 2.15. It will read as follows:

Technical Guidance

The other principal purpose of this consultation is to seek views on the guidance which should be provided within the Technical Handbooks to support the requirement.

There will be two Technical Handbooks published to support the building regulations, one covering domestic building and the other covering non-domestic buildings. The guidance on enclosed shopping centres and residential care buildings will be in the non-domestic handbook. That on domestic buildings in which there is a floor at a height of more than 18 metres from the ground and those which form the whole or part of a sheltered housing complex will be in the domestic handbook. In both cases the requirements will form section 2.15, as the handbooks are structured to accord exactly with the requirements.

As the guidance on residential care homes and high rise flats is provided in dedicated Annexes within the relevant handbooks it will also be necessary to refer to these. As the requirements for enclosed shopping centres are not new these have already been consulted on and are included in the relevant Annex, however they will now be called up under section 2.15 of the non-domestic document.

Draft pages for the handbooks from these sections and Annexes are provided as a separate document within this consultation. They have been formatted in the style proposed for the Technical Handbooks and in accordance with the earlier consultation on technical guidance.

The technical guidance makes reference to two British Standards Drafts for Development :

DD251 - Sprinkler systems for residential and domestic occupancies - code of practice, April 2000, and

DD252 - Components for residential sprinkler systems - specification and test methods, July 2002.

These represent the most authoritative guidance available on residential sprinklers and provided the basis for much of the BRE research. Should these Drafts for Development be adopted as full British Standards it is probable that the references will be accordingly updated. The Handbooks makes some additional suggestions to amplify this guidance and ensure it is adequate for the intended use.

In the case of enclosed shopping centres DD251 and DD252 are not used, but rather the existing more onerous requirements are retained

There may be alternative or innovative fire suppression systems available including fresh water sprinkler systems, mist or fog systems. However these are not described in the guidance as there is as yet insufficient evidence, test data or established standards available. This would not prevent such a system being used, but it would put the responsibility upon the designer who wishes to use such a system to show to the satisfaction of the verifier that such a system was as effective and as reliable as that described within the guidance.

Conclusion

The Scottish Executive would welcome views from all interested parties on these proposals. In particular we would like to hear views on the definitions of the building types to be covered, particularly "residential care homes" and "sheltered housing". We would also like to hear views on appropriateness of the technical guidance, particularly on the use of DD251 and DD252 and the additional requirements. All views will be carefully considered and before final decisions are made.

Appendix - Executive summary of the BRE Research "The effectiveness of sprinklers in residential premises"

This Executive Summary describes the project "The effectiveness of sprinklers in residential premises" commissioned by the Buildings Division of the Office of the Deputy Prime Minister (ODPM) carried out by FRS. Any views expressed in this report are not necessarily those of the ODPM.

Full details of this study and its findings are given in BRE report No 204505. The overall aim was to determine the benefits and effectiveness of sprinklers in residential accommodation. To achieve this, the project was divided into stages: a Pilot Study, Cost Benefit Analysis, Benchmark Tests and an Experimental Programme. This project was guided and reviewed by a Steering Group. The members of the Steering Group included representatives from government regulators, the sprinkler industry, the water industry, the housing industry and the fire service. They provided general advice and review on all aspects of the project methodology, and specific advice on sprinkler installation and water supply costs for the cost benefit analysis phase of the project. Also, there was a smaller experimental

working group.

The Pilot study included an analysis of statistical information. A strong correlation was observed between the risks of death and injury per fire, and the area damaged by the fire. This formed the basis for an indirect estimate of sprinkler effectiveness as it was not possible to provide a direct estimate of sprinkler effectiveness from the UK fire statistics. Experiences with residential sprinklers in other countries were also reviewed. Cost benefit analyses including uncertainty analyses have been performed for a range of domestic and residential building types, including houses, flats, various types of houses of multiple occupation, and residential care homes. Further analyses were performed for different building heights, within certain of the broad categories in this list, in order to focus on properties that would be expected to have higher than average risks from fire. The potential benefits of sprinklers include the prevention of deaths and injuries, the reduction of property damage and costs include installation; provision of water supplies and annual maintenance.

Tests were carried out to establish a benchmark fire test for UK conditions to support the further development of British Standard Drafts for Development DD251 (Sprinkler systems for residential and domestic occupancies - code of practice, April 2000) and DD252 (Components for residential sprinkler systems - specification and test methods, July 2002) and to assess the performance of residential sprinklers in fire test conditions. A series of 18 fire tests was conducted, based on the procedures given in DD 252 to examine the effect of varying parameters on the performance of residential sprinklers. The stylised fuel package was intended to simulate furniture and wall linings, and was characterised using calorimetry. The parameters investigated were: sprinkler model (four pendent types), location of the fuel package within the sprinkler spray, the effect of the presence of lintels, and the sprinkler water flow rate (3 or 4 mm/min).

An Experimental programme, burning realistic residential fuel arrays was conducted to examine and quantify the effectiveness of residential sprinklers, in particular to life safety in the room of fire origin. The effectiveness of the sprinklers was primarily assessed by measuring their ability to control toxicity, temperature and visibility. 8 house lounge fires were conducted inside a two-storey house with a loft conversion, with and without sprinklers. Smoke alarms were present. Fire tests were performed in a standard lounge and an open plan lounge arrangement. 29 compartment fires were conducted inside a room connected to an adjoining single storey volume via a doorway, with and without sprinklers. Smoke alarms were present. The fire scenarios were: a) Lounge, nightlight and television fire- shielded, b) Lounge, fire under table directly beneath sprinkler- shielded, c) Bedroom, fire on duvet-unshielded and d) Lounge, fire on sofa (compliant with 1988 Furniture Regulations)-unshielded. An unshielded oil pan fire kitchen scenario was also examined, with and without sprinklers. Each of these fuel packages were characterised using calorimetry. The effects of fire room door open/closed, compartment size, sprinkler model, sprinkler orientation and water flow rate were also studied. The flow rates were 60 or 42 l/min for a single sprinkler for standard compartment, and 60 l/min for a single sprinkler or 84 l/min for two sprinklers operating, for the large compartment and open plan lounge arrangement.

The main findings of the project are:

• For the majority of scenarios experimentally studied, the addition of residential sprinkler protection proved effective in potentially reducing casualties in the room of fire origin and connected spaces
• Sprinkler protection was not found to be a complete panacea, slow growing and shielded fires can be a problem
• Smoke alarms, fitted in the room of fire origin, responded typically in half the time required by sprinklers and well before the conditions had become life threatening
• Closing the door to the room of fire origin, was found to be effective in keeping tenable conditions in connecting spaces
• Residential sprinklers are probably cost-effective for residential care homes (old persons, childrens and disabled persons care homes)
• Residential sprinklers are probably cost effective for tall blocks of flats (eleven storeys and above)
• Residential sprinklers are not cost-effective for other dwellings
• In order for sprinklers to become cost-effective, high risk buildings may be targeted, and justified on a case-by-case basis using the cost-benefit approach developed in this project
• In order to be cost effective in a broader range of dwellings, installation and maintenance costs must be minimal, and/or trade-offs may be provided to reduce costs by indirect means.
• In general, the cost benefit conclusions from other countries' experiences were the same as this project, i.e. that sprinklers were not cost-effective, unless systems were low-cost or trade-offs could reduce costs.
• A number of issues relating to the procedures for the fire test in DD 252 have been identified, for submission to BSI.

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