Hackitt Review must put maximum public safety first & foremost
The Mineral Wool Insulation Manufacturers Association (MIMA) writes in advance of the interim report of the Review of Building Regulations and Fire Safety.
With the Hackitt interim report expected before Christmas, we all have high hopes for Dame Judith’s independent review. What is clear is that we simply cannot and must not compromise on public safety.
As the organisation representing the non-combustible insulation manufacturers, MIMA is firmly supportive of the scope of the Building Regulations review but believes we need to be more stringent, albeit prescriptive with particular attention being given to all mid- and high-rise, sensitive and high occupancy buildings such as schools, hospitals and care homes.
Fit for purpose
We need to go wider with a review that fully considers the implications for fire safety in technology advances. Current developments in technology mean it is perfectly practical to track a product from factory to installation while keeping a digital record of what the product characteristics are. A record for current and future building occupants.
We should consider whether wider testing methodologies are fit for purpose. Specifically focusing on whether the testing regimes applying in all buildings are only testing a perfect installation rather than a ‘real world’ one.
Current regulations are ambiguous
Currently ‘guidance’ for facades in buildings over 18m high sits in multiple documents with Approved Document B referencing a variety of supporting documents which don’t lead to clear guidance on what is or isn’t permitted.
To offer maximum public safety, the approved document should offer the only point of reference and the only permissible routes to compliance should be the use of Euroclass A1 or A2 rated products on facades which should be clearly set out in a redrafted Approved Document B. That redrafting should also clearly set out that Approved Document B is the only acceptable route to compliance.
Routes to compliance
Currently Approved Document B is not the only means to compliance with the Building Regulations – other bodies are permitted to publish their own guidance on how the regulations can be met. This has led to industry bodies publishing their own guidance on BR135 – these guides both contained four routes to compliance including desktop studies, which allow for combustible materials to be used without even being tested.
There is substantial confusion within the industry and even amongst fire experts about what the official regulations do and do not state – only specifying either A1 or A2 Euroclass products / systems can ever offer certainty to occupants that the façade will offer the maximum protection against fire. All other routes permit human error or judgement in to the system.
Classification
References in Approved Document B to national fire classifications such as “Class O” alongside Euroclasses A1, A2, B, C, D, E and F cause confusion - Class O certification is commonly misinterpreted to mean that a product is non-combustible. The continued use of “Class O” classification has allowed manufacturers to imply a greater degree of fire-resistant performance than is actually the case. All reference to the British Standard (BS) ‘Class O’ should be removed to avoid ambiguity and uncertainty of interpretation.
Similarly, marketing terms such as “fire retarded”, “fire safe” and “non-flammable” are frequently used to describe the reaction to fire properties of materials which are classified as combustible.
The difference between combustible and non-combustible materials is an extremely significant distinction which must not be blurred. Combustible materials contain considerable fuel loads which contribute to the spread of fire. Non-combustible products cannot contain significant quantities of combustible materials, including any glues and binders, as this would prevent them from achieving a non-combustible classification. Fact.
Smoke toxicity must be tested
Building regulations must offer greater assurance of fire safe performance for occupants of both residential and non-residential buildings over 18m. Given the fatal danger of toxic smoke, the smoke toxicity of construction products must be tested, classified and labelled to provide important information to consumers and made a key component within Approved Document B.
Testing Methods
No modelling available can ever genuinely replicate the behaviour of a fire in a complex building in the real world while no fire test on a perfect installation can ever replicate fire behaviour in buildings that have received real world installation practices.
Desktop studies do not produce a reliable indication of fire performance. These generalised assessments can do little more than guess at how combustible materials might behave in a fire on an unspecified building. The acceptance of these studies has promoted a light-touch approach.
Testing regimes must be continually reviewed to keep pace with construction practices as well as to ensure the process is sufficiently robust. The BS8414 test should be updated to reflect real life construction features such as windows and vents and the communication of test results based on perfect laboratory conditions must highlight the limitations of these tests in terms of predicting real life performance as highlighted by the Fire Protection Association.
Enforcement
Finally, compliance clearly needs to be policed while sanctions for non-compliance robust. Approaches on how any new guidance will tackle policing and sanction should also be clearly set out. No one can disagree that sanctions must be meaningful, tough and properly enforced.
MIMA believes that public safety is paramount and we can be instrumental in developing a comprehensive fire risk analysis for both existing and new buildings. However Dame Judith must recommend the right framework to ensure we can deliver maximum safety for the general public across the UK.
MIMA’s submission to the Hackitt Review can be found here: http://mima.info/info-centre/news/mima-responds-to-the-hackitt-review-on-building-regulations-and-fire-safety
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