THE BUILDING SAFETY ACT CONSULTATIONS 30

fire strategy should be considered by the BSR. A typical example might be where a ‘tradeoff’ is proposed between active and passive systems, such as a reduction in fire resistance periods being compensated by the installation of a suitable suppression system, It should be noted that the ASFP does not support the principle of trade off in any situation. However, if it is to be considered, it should be notified to and formally considered by the BSR.

Another concern we have is in relation to product substitution. We are very concerned about this statement from the consultation allowing: ‘Substituting a �like for like” product where the new product has the same specification/performance classification as the original specified in the original building control approval application’.

This sounds harmless enough, but in the past has led to extreme value engineering and a race to the bottom, as highlighted by Dame Judith Hackitt in her report. For example, the term ‘or similar’ is often used to justify totally inappropriate product substitution. We believe this should be notifiable as a ‘major change’ rather than a ‘notifiable change’ and should be considered by the BSA. If nothing else, it might concentrate the minds of designers and specifiers to get it right first time.

Maintaining Accuracy of Information in the Golden Thread

The consultation states: ‘through the design and construction process there should be a duty on all dutyholders to review the information within the golden thread to ensure it remains relevant and proportionate and supports compliance with building regulations’.

We are concerned that when you ask a lot of people to do something, they all assume one of the others is doing it. If one considered the arguments over design liability at Grenfell Tower, all the parties found a reason to blame the others. If you don’t single out ONE person/ dutyholder this will fail.

Consultation on the In-Occupation Regime for Occupied Higher-Risk Buildings

The consultation asks if only information relevant to building safety risks should be stored in the Golden Thread. The ASFP considers that the Golden Thread should include all active and passive fire safety systems and measures. We further believe that there is a need to separate out Golden Thread information on fire/structural as these are the main drivers behind the Building Safety Act. Our worry is that Golden Thread information will become bloated and/or irrelevant and/or inaccessible.

There is also a proposal that the Golden Thread requirements will be sufficient so that the current Regulation 38 ‘cannot apply to buildings in scope of the more stringent regime.’ Regulation 38 information is specific fire safety information on installed fire protection systems (active and passive). The purpose of this was so that the Fire Risk Assessor could access this before doing the fire risk assessment under the Regulatory Reform (Fire Safety) Order. The idea being that the Regulation 38 information will provide a list of what to check which will make their assessment easier, but also more thorough. The concern is that if this is ‘buried’ in the Golden Thread that it won’t be accessible, and this will lead to poorer fire risk assessments

Key Building Information

The consultation considers the creation of Key Building Information to be provided to the BSR to enable oversight and analysis of the building industry. We have two main comments: 1. There is a LOT of overlap between

Key Building Information and Golden

Thread. Do we really need two types of information? We would argue that a less bloated Golden Thread might make a very good Key Building Information. Or Key

Building Information could be developed into Golden Thread. 2. There appears to be no information on active, passive or firefighting systems!

Whether or not a building has a sprinkler system is crucial to any analysis of how buildings behave in a fire. The same applies to passive systems. We would propose that information on active, passive, or firefighting systems, even if just in a very simplified form is an essential factor in analysing data from buildings and fires.

Work undertaken by residents

We are concerned about the statement: ‘Building work commissioned by residents within a dwelling should not change the key building information because of the nature of such work and the confinement to an individual dwelling.’

We would argue that work by a resident such as changing room layouts to increase room sizes and/or the installation of services into the property without adequate firestopping would affect Key Building Information. A more pertinent example would be a ground floor resident removing concrete protection to cast iron columns to obtain a more aesthetic look could compromise the structural integrity of the building. One ASFP correspondent has recently seen an example of this.

Conclusion

The ASFP welcomes the Building Safety Act as a major step forward in the creation of safer buildings, but we have significant concerns regarding some of the details that are emerging in these latest consultations. We shall continue to lobby to ensure that the legislation enhances the quality of designed and installed passive fire protection thus delivering safer buildings. All the comments above and others have been submitted to DLUCH for consideration.