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Understanding Fire Safety Requirements For PDF
Understanding Fire Safety Requirements For PDF
Adrian Pargeter
Received (in revised form): 31st July, 2018
Kingspan Insulation Ltd, Pembridge, Leominster, Herefordshire, HR6 9LA, UK
Tel: +44(0)1544 388601; E-mail: adrian.pargeter@kingspan.com
Adrian Pargeter joined Kingspan Insulation Keywords: The Hackitt Review, Part
in 2009 after 20 years’ experience working in B Building Regulations, combustible
the automotive component supply chain sector. cladding materials, cladding fire safety,
Adrian started in the Research & Development external cladding systems, cladding
department, where he was responsible for insulation, fire engineering
fundamental research into Vacuum Insulation
Panels (VIP) as part of the development of the
Kingspan OPTIM-R VIP system. Subsequently IT STARTS WITH REGULATION
he worked as a Product Development Manager, The Building Act 1984 permits the Secretary
focusing on developing thinner insulation solu- of State to make regulations for the purpose
tions for energy efficient buildings, before of ‘securing the health, safety, welfare and
moving onto Head of Marketing. In 2015, Adrian convenience of persons in or about buildings
became Head of Technical and Marketing for and of others who may be affected by build-
KIL GB, responsible for Technical Services, ings or matters connected to buildings’,2
Technical Projects, Marketing and Product among other purposes such as facilitating
Development. sustainable development. The resulting
building regulations have evolved over time
Abstract to the current statutory instruments, which
The final report from the Independent Review were last updated in 2010.3
of Building Regulations and Fire Safety1 (led Schedule 1 of the Building Regulations
by Dame Judith Hackitt) was published in May 2010: England and Wales outlines the spe-
2018, proposing radical changes to how the con- cific requirements, and is split into sections
struction industry tackles the issue of fire safety in A–P. Each section sets out the statutory
Higher Risk Residential Buildings (HRRBs). If requirements for a particular area of the
the recommendations in the report are adopted by design and construction of buildings, such as
government, it will take a considerable amount of electrical safety (Part P) or conservation of
time, and a huge cultural shift to implement the fuel and power (Part L). The Government
full scope of what is proposed. In the meantime, has then provided guidance as to how these
there has been a specific focus from the media and requirements may be met, in the form
other interested parties on which materials should of Approved Documents. So, guidance on
be permitted in rainscreen cladding applications. how to comply with Part B of Schedule 1
Journal of Building Survey,
Appraisal & Valuation
This paper sets out the current requirements, what (Fire Safety) of the Building Regulations
Vol. 7, No. 2, 2018, pp. 162–172 the issues are and how the Hackitt Review could 2010: England and Wales can be found in
© Henry Stewart Publications,
2046–9594 revolutionise the way in which we build. Approved Document B (ADB) Parts 1 and
Page 162
2, covering residential and non-residential ADB essentially offers two different routes
buildings respectively to compliance with this specific require-
ment — one based on the fire performance
classification of individual products (the
REQUIREMENT OR GUIDANCE? linear route), the other based on a large-
One issue that is frequently not under- scale test of the whole external wall
stood is that the regulatory requirements cladding system (the performance-based
and the guidance provided by the Approved route).
Documents is not the same thing. For
example, Part B of the Building Regulations
is mandatory, ADB is not. ADB is just the THE LINEAR ROUTE
government view of what would fulfil the Section 12.5 of ADB is the entry point:
statutory requirement laid out in Part B.
Other routes can be taken, provided it can
be demonstrated that the requirements of External walls should either meet the guid-
ance given in paragraphs 12.6 to 12.9 or
Part B have been met.
meet the performance criteria given in
There is also a whole raft of other the BRE Report Fire performance of external
guidance supplementing the Approved thermal insulation for walls of multi storey build-
Documents, some of which has evolved ings (BR 135) for cladding systems using full
over the intervening years since ADB scale test data from BS 8414-1:2002 or BS
was last reviewed in any detail in 2006 8414-2:2005
(with minor updates in 2010 and 2013).
Perhaps the most significant of these in Paragraph 12.6 deals with the external sur-
relation to high-rise buildings is BCA4 faces of walls, stating that they should meet
Technical Guidance Note 18: Use of the provisions of Diagram 40 (see Figure 1),
Combustible Cladding Materials on which depicts the requirements for various
Buildings Exceeding 18m in Height5 scenarios, including height and distance
(TGN 18). First published in 2015, the from other buildings. An important area
document was updated in June 2017, and to note is the requirement for the external
introduces additional, alternative routes to façade surface of buildings over 18m, or less
compliance with Part B of Schedule 1 to than 1000mm from an adjacent building, to
the Building Regulations to those indi- have Class 0 (national class) or class B-s3, d2
cated in ADB. These alternative routes or better (European class).
will be explained later in the paper. Paragraph 12.7 gives the requirement
for insulation. This is much stricter, stipu-
lating that it should be classed of ‘limited
THE CURRENT STATE OF PLAY
combustibility’ or better. ‘In a building
Under Part B of the Building Regulations,6 with a storey 18m or more above ground
the statutory requirement for external fire level any insulation product, filler material
spread is clear: (not including gaskets, sealants and similar)
etc. used in the external wall construction
B4. (1) The external walls of the building should be of limited combustibility (see
shall adequately resist the spread of fire over Appendix A)’.
the walls and from one building to another, The guidance given in paragraphs 12.8
having regard to the height, use and posi-
tion of the building.
and 12.9 refers to cavity barriers and is not
covered in detail by the scope of this paper.
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Figure 4: ISO 13785 tests with A2 solid core ACM: non-combustible mineral fibre insulation (left), combustible phenolic
insulation (right)
Source: Kingspan
Page 167
as these full-scale BS8414 tests, but based test and the overall heat energy (ie intensity
on the existing standard ISO13785-1: 2002 and duration of simulated fire exposure) to
(Reaction-to-fire tests for façades — Part 1: which a cladding system is subjected in BS
Intermediate-scale test), which is approxi- 8414, significantly exceeds that achieved in
mately a third of the scale of BS 8414. The NFPA 285.
test comprises a 2.4m high wall with a Tenos compared the fire load from BS
corner, and a fire barrier two thirds of the 8414 against measurements taken from
way up the wall (see Figure 4). experimental fully furnished apartment
The correlation between the Efectis fires. They concluded that the heat load
ISO13785-1 tests and the Governments from BS 8414 is more severe and lasts con-
BS8414 tests was good, indicating that siderably longer than that measured from
testing to ISO13785-1 may have promise these experimental, but wholly realistic,
in supporting the extension of scope of BR fires.
135 classifications. The Tenos study also analysed readily
Requiring desktop studies to include test available information about fire spread in
data at an intermediate-scale on the actual recent fires in residential buildings of over
system being analysed could therefore make five storeys in height. The study identi-
this route to compliance far more robust, fied 17 fires and found that none of them
by basing it on empirical data rather than contained a combination of materials which
relying on opinion. Crucially, capacity for had, or would have, passed a BS 8414
ISO13785-1 testing can be ramped up easily test. They included systems with non-com-
and quickly, and it would be realistic to bustible insulation as well as systems with
achieve on the kind of scale that we would combustible insulation.
need to ensure that a comprehensive range The Tenos report concluded that the
of systems can be tested. absence of evidence of fires with significant
fire spread in cladding systems compliant
with BS 8414 is indicative that BS8414
ROBUST TESTING is a good measure of robust façade fire
Of course, no amount of tighter regulation performance.
will make desktop studies fit for purpose Notwithstanding the above, consideration
if the original test data on which they are is being given to whether BS 8414 can be
based is not robust. BS 8414 has recently further improved in other ways.
come under heavy scrutiny, with some
parties claiming that it does not sufficiently
reflect the realities of constructed buildings, WHY BANNING COMBUSTIBLES WILL
because it does not incorporate aspects such NOT WORK
as penetrations and windows. Although the Government consultation on
A recent report by Tenos International banning the use of combustible materials in
Fire Engineering Consultants16 has com- the external walls of high rise buildings will
pared the BS 8414 test to the NFPA 285 have closed, it is important to understand
whole system tests used in other regulatory why the apparently straightforward step of
regimes, notably including the USA, UAE banning materials that are considered ‘com-
and New Zealand. The Tenos study found bustible’ will not guarantee a desirable level
that the fire load used in BS 8414 was more of fire safety. If the proposed ban goes ahead,
onerous than that in NFPA 285 because the only cladding and insulation that is classed as
minimum heat flux to which the cladding ‘non-combustible’ or of ‘limited combusti-
system is exposed is greater in a BS 8414 bility’ (probably based on Euroclass ratings
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A1 and A2) will be permitted on high- ‘combustible’ does not necessarily mean
rise buildings. This will severely limit the ‘flammable’. There is a huge range in the
materials that can be used and will involve actual flammability of ‘combustible’ prod-
a much greater burden of weight and thick- ucts — from those that can perform as well
ness on building structures. as ‘non-combustible’ and ‘limited combusti-
More importantly, regardless of whether bility’ products as part of a system, to those
the insulation and cladding materials used that are highly flammable.
in a cladding system are classed as A1 During the presentation of his expert
(‘non-combustible’) or A2 (of ‘limited com- witness report to the Grenfell Public Inquiry,
bustibility’), there will still be a surprising Professor Luke Bisby expressed the signifi-
amount of combustible material within cance of this point, saying:
the overall construction, including thermal
breaks, sealants, vapour barriers and tapes. ‘The word “combustible” has received
It is the interaction between all these dif- a great deal of attention and use in the
ferent components, how they are spatially media since the Grenfell Tower fire. In
arranged and how they are installed, that will reality, for materials that have the potential
ultimately determine how a façade system to burn, by which I mean those materials
behaves when exposed to fire. It is also that are combustible, flammability is a
worth remembering that many materials relative rather than absolute property.
classified as ‘non-combustible’ and all that Depending on the circumstances, there-
are classified as ‘limited combustibility’ still fore, combustible materials can either be
burn. more or less flammable, and this distinc-
This has been exemplified by recent tion is actually very important’.
research into how certain non-combus-
tible and limited combustibility products For example, ‘combustible’ thermoset insu-
perform in the large-scale system test BS lation materials char when exposed to
8414 in accordance with the performance fire or heat preventing further fire spread,
criteria set out in BR 135, as cited in ADB. and they self-extinguish when that fire or
There have been several failures, including heat is removed. Systems insulated with
two systems, one containing a solid core these products can meet the performance
A2 ACM along with A1 rated foil faced criteria of BR 135 mentioned as an
stone wool insulation (also referred to as alternative route to compliance in ADB
mineral fibre), and the other containing because, despite not meeting the require-
an A2 rated honeycomb aluminium clad- ments to be classified as ‘non-combustible’
ding panel with an A1 rated stone wool or ‘limited-combustibility’, they are also
insulation. ‘non-flammable’. By contrast, thermoplastic
Under the Government’s proposed ban materials, such as polyethylene, are highly
of combustible materials on buildings over flammable. Grouping products with such a
18m these systems would be permitted, and wide range of performance together under
under the current regulatory system they one broad heading of ‘combustible’ is there-
would automatically be deemed to comply. fore misleading. This leads the public to
Yet they failed BS 8414, when many systems believe that all combustible materials burn
containing high-performing ‘combustible’ in the same way and at the same rate, yet
insulation have passed. they do not.
Just because a material has been classed Whilst individual product testing is
as ‘combustible’ does not mean that it important to provide a baseline for per-
will burn in any given circumstances. So, formance, it has severe limitations when
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trying to assess the performance of a com- robust, outcomes-based approach for gov-
plete building element, such as a rainscreen ernment to adopt and the industry to put
façade, both in terms of scale and because it into action.18
looks at material samples in isolation, not as Crucially, Hackitt does not recommend
the product has been designed for use in an an outright ban on the use of combus-
application. Product classifications give no tible materials, recognising that ‘prescriptive
indication of how a material will perform regulation and guidance are not helpful in
when combined with others in a system. designing and building complex buildings,
Furthermore, there are no product classifi- especially in an environment where building
cations for an airspace, ventilation gap, or technology and practices continue to evolve,
any of the other myriad parameters that can and will prevent those undertaking building
affect system performance. work from taking responsibility for their
This is why it is so important to look at actions’.
the whole wall assembly to ensure that it Instead, what she proposes is an ‘inte-
will achieve the desired performance. Full grated systemic change’. In other words, it
system testing is therefore the best way to requires reform at every level of the chain of
assess how any given combination of prod- delivery for HRRBs.
ucts will perform, regardless of whether The proposed reform includes clearer
the insulation and cladding is classed as lines of responsibility, much more effec-
‘non-combustible’, ‘limited combustibility’ tive oversight, and serious consequences for
or not. Just banning all ‘combustible’ mate- non-compliance. The first recommenda-
rials will not achieve the objectives of fire tion is for a new regulatory framework
safety in all cases and, as the Hackitt Review for HRRBs, which would be overseen by
reveals, the issues run much deeper than a new Joint Competent Authority (JCA).
that. The JCA would involve Local Authority
Building Standards, fire and rescue authori-
ties and the Health and Safety Executive.
THE HACKITT REVIEW The framework is designed to simplify the
Since ADB was last revised to any mean- requirements. It provides better oversight,
ingful degree, much has changed within the clearly defined dutyholder roles, a series of
industry, with new materials being devel- ‘gateway points’ to enable better regulation,
oped and modern methods of construction incentives for good practice and real sanc-
becoming increasingly popular in the tions for poor practice.
attempt to meet multiple pressures in terms Improved levels of competence is a major
of thermal performance, speed of construc- area where we can expect to see change
tion, skills shortages, healthy buildings, and enacted, with a working group already
the often over-riding issue of the bottom set up to create a framework for those
line. This has led to question marks over installing safety critical systems. There are
the fitness of the current system to properly also working groups looking at defining
regulate and guide the industry, competences for those involved in pro-
The Hackitt Review takes an in depth, curement for HRRBs, site supervisors and
holistic look at the many failings in the project managers.
system that allowed the tragedy at Grenfell From a surveying point of view, it will
Tower to happen, and the final report, be vital to improve understanding of which
alongside the Interim Report published in aspects of the design and specification are
December 2017,17 sets out a series of clear crucial to building safety, and how to improve
recommendations to create a much more procurement so that ‘value engineering’
Page 170
Key recommendations:
1. The framework;
2. Improve the focus on building safety during design, construction and refurbishment;
3. Improve the focus on building safety during occupation;
4. Giving residents a voice;
5. Improved levels of competence;
6. More robust and transparent construction products regime;
7. Creating a golden thread of information;
8. Tackling poor procurement practices;
9. Ensuring continuous improvement and best practice learning through membership of an international
body.
becomes a true reflection of value over been shown to be a far more robust way of
the lifetime of the building, not just a cost assessing and achieving a safe design than
cutting exercise. Meanwhile, construction relying on simple product classifications.
product manufacturers have work to do The issues that led to the Grenfell
to ensure that the testing, marketing and Tower fire run far deeper than the cladding
traceability of products is clear, consistent construction. The Hackitt Review has com-
and robust. Above all, the ‘golden thread’ of prehensively covered which problems are
information must form an integral part of endemic within the industry and provided
the building lifecycle — regulating construc- a roadmap for how these may be addressed.
tion, highlighting responsibility, informing We stand at a critical point, where we
maintenance and providing reassurance for can work together to create an industry that
residents that their homes are safe. leads the world in competence, quality and
It will take time for the sweeping change building performance, or we can focus piece-
that is so badly needed to be put in place meal on quick fixes and patches that might
and become enshrined in the regulations, satisfy public perception and boost political
‘… in the meantime’, Dame Judith writes favour, but which will not ultimately address
‘industry must start living the cultural shift the fundamental issues. The choice is ours.
that is required’.
References
(1) Gov.UK (May 2018), ‘Independent
CONCLUSION Review of Building Regulations and
The intention behind the Building Fire Safety: Final report’, available at
Regulations is clear, but the guidance on www.gov.uk/government/publications/
how to achieve it is complex. Work is independent-review-of-building-
already underway to clarify the existing regulations-and-fire-safety-final-report
(accessed 8th August, 2018).
Approved Documents and a further consul-
(2) Legislation.Gov.UK (1984), ‘Building
tation on this has recently been published.19
Regulations 1984’, last updated 2010,
The full review will take two to four years. available at www.legislation.gov.uk/
The consultation on whether or not to ukpga/1984/55 (accessed 8th August,
ban combustible materials could lead to 2018).
severe restrictions in how we can construct (3) Legislation.Gov.UK (2010), ‘The Building
high-rise buildings, without necessarily Regulations 2010’, available at http://
achieving the objective of ensuring that they www.legislation.gov.uk/uksi/2010/2214/
are safe from the risk of fire spread in and contents/made (accessed 8th August, 2018).
on a façade. Large-scale system testing has (4) For further information see Local
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