Sprinklers are the most effective way to ensure that fires are suppressed or even extinguished before the fire service can arrive. They save lives and reduce injuries, protect firefighters who attend incidents and reduce the amount of damage to both property and the environment from fire.
County Durham & Darlington Fire & Rescue Service (CDDFRS) would like to see greater inclusion of automatic water suppression systems (AWSS) within the built environment in the UK and believe the Government should do significantly more to increase their use across the built environment in England.
CDDFRS Responds to The Government Consultation on Approved Document B
We fully support the government consultation which closed on March 17, 2023 to make it mandatory for:
- New care homes to have sprinklers fitted.
- New residential buildings above 30 meters to have a minimum of two staircases.
We have reaffirmed our support in the National Fire Chiefs Council response which was drafted in consultation with our colleagues across the Fire & Rescue sector.
Sprinklers
Sprinklers save lives and reduce injuries. They have been used for over one hundred years and are consistently reliable, protect property, reduce the cost of repairs, and minimise the impact of fire on the environment. Sprinklers can also buy crucial additional time in firefighting operations which may mean that evacuations are not necessary in the first place. Analysis has demonstrated that they are 99% effective in extinguishing or controlling a fire and 94% reliable in their ability to operate across all building types.[1]
England’s national building and fire safety regulations trail behind its neighbours; governments in other UK jurisdictions have set lower mandatory thresholds for the installation or retrofitting of sprinklers. In Scotland, sprinklers are required in all blocks of flats, care homes, social housing, and schools. Wales has required sprinklers in all new single dwellings since January 2016 and this has now been extended to include all new care homes, student halls of residence, boarding houses, and certain hostels. The Government should be looking to emulate the policies in the devolved governments to support unitary policy across nations by lowering or removing the acceptable height, floor area, or occupancy threshold dependent on building type.
Whilst we support the installation and retrofitting of sprinklers in all buildings, we are particularly concerned about the following buildings:
- Care homes
- Residential buildings
- Schools
- Car parks
- Storage and warehouses
- Hospitals
It is important for England to have effective fire safety measures in place to protect lives and property. While fire sprinklers are required in certain types of buildings, the floor area or height threshold for installation or retrofitting remains relatively high. This has led to concerns that many new and existing buildings may not have adequate fire protection. Given the significant cultural issues in the system[2] and the competency levels across the sector, our recommendations improve safety through greater use of fire sprinklers in appropriate buildings.
Watermist
While this position statement predominantly covers the use of sprinklers in buildings, CDDFRS also recognises the use of alternative AWSS.
Watermist can be used as a form of suppression in buildings where there is an appropriate test protocol in accordance with the relevant British Standard. However, watermist systems cannot be used interchangeably with sprinkler systems. Watermist systems are an engineered solution for specific applications and strengthened test protocols are required to support their use in the instances outlined in the below recommendations.
This statement does not cover the use of personal protection systems (such as fog units) which can be installed as part of a risk-based solution following a ‘person-centred fire risk assessment’. Such systems usually deal with specific risks and are outside of the British Standards for sprinklers and watermist systems.
Recommendations
- Government should make it a requirement to install sprinklers in all new care homes, irrespective of height, including all those undergoing major or significant refurbishment, extension, or alteration.
- Government should make it a requirement to retrofit sprinklers in all high-rise residential buildings over 18 metres or that have at least 7 storeys that are served by a single staircase.
- Government should make it a requirement to retrofit sprinklers in all existing residential buildings over 11 metres on a risk-assessed basis.
- Government should ensure the installation of sprinklers in a residential building covers the whole building, in accordance with the relevant British Standard, and not just a specific area or purpose group as referenced in prescriptive guidance.
- Government should require all new schools, all new student accommodation, and all existing schools and student accommodation undergoing major or significant refurbishment, to have sprinklers fitted regardless of height.
- Government should require AFSS in all enclosed car parks.
- Government should carry out further and in-depth research into fires in car parks and the design of car parks.
- Government should lower the threshold for the requirement to install sprinklers in all storage and warehouses to 4,000 square metres.
- Government should set different thresholds for mandatory fire sprinkler installation depending on the type of material stored in a storage building or warehouse below the maximum of 4,000 square metres.
- Government should require all new hospital buildings to have sprinklers fitted regardless of height.
Care homes
NFCC has serious concerns about fire safety in care homes, where residents are more vulnerable to fire due to age, mobility issues, or cognitive impairments. We believe that sprinklers are critical to protecting vulnerable residents and staff. For many years, NFCC and fire and rescue services (FRS) across England have been calling for the greater mandating of sprinklers in care homes.
There have been several recent high-profile fires in care homes across England.[3] In these cases, it was not possible for the FRS to fully mitigate the effects of serious fires that resulted in multiple lives lost, injury, and/or major property damage. In many of these instances, there were no sprinkler systems in place.
Current evacuation strategies are critically dependent on giving staff sufficient time to evacuate residents before escape routes become compromised by smoke. If these escape routes are compromised during a fire, it is very likely that staff or residents will be placed at significant risk. This is particularly concerning given the challenges posed by:
• Staff shortages and high turnover in staffing across the care sector resulting in challenges to maintain training and competence in emergency procedures.
• The complexity and challenge of emergency procedures and the urgent movement of residents in the event of a fire.
• The level of staff fitness required for the physical effort of moving many dependent people.
• The installation of sprinklers in care homes would reduce the likelihood of a fire spreading beyond the room of origin, which buys time for evacuation and firefighting and can reduce the need for unnecessary movement of vulnerable residents.
We welcome the Government’s December 2022 proposal to make it a requirement to install sprinklers in all new care homes regardless of height, but this requirement must go further to cover homes undergoing extension or major and significant refurbishment.
Recommendation
- Government should make it a requirement to install sprinklers in all new care homes, irrespective of height, and all those undergoing major or significant refurbishment, extension, or alteration.
Residential buildings
NFCC welcomed the 2019 reduction of the height threshold for the installation of sprinklers in new residential buildings to 11 metres, something we had consistently called for. Despite the lowering of the threshold, it remains a significant concern that there is still no requirement to retrofit existing residential buildings with sprinklers.
The Government’s decisions in relation to building regulations guidance over time dictate that, for many existing buildings, ‘Stay Put’ advice[4] will continue to be the most appropriate strategy. ‘Stay Put’ is a suitable strategy when buildings are properly designed, built, and maintained for this purpose. However, all residents should be able to safely leave their homes in the event of a fire if they wish to.
Sprinklers complement the ‘Stay Put’ advice and would be an ideal way to enhance public safety alongside the direction the Government has chosen to take when allowing developers to construct ‘Stay Put’ designs for many decades. ‘Stay Put’ should not be seen as incompatible with measures that also enable people to safely exit the building should they wish to. Sprinklers can buy crucial additional time in firefighting operations and can help ensure that evacuations are not necessary in the first place, but importantly they also assist those that need to or wish to evacuate during a fire incident.
NFCC has consistently urged the Government to make it a requirement to retrofit sprinklers in all high-rise residential buildings that are over 18 metres or have at least 7 storeys that are served by a single staircase regardless of future major or significant refurbishment.
We have also consistently urged the Government to make it a requirement to retrofit all existing residential buildings over 11 metres on a risk-assessed basis[5] and to amend section 4(3) of the Building Regulations.[6] If a risk assessment indicates that the installation of a sprinkler system may be necessary to adequately protect residents, then the responsible person under the Regulatory Reform (Fire Safety) Order 2005 should be required to install one even if the residential building did not previously have a sprinkler system.
Following the Lakanal House fire in London in 2009 the requirement for sprinklers in new residential buildings was introduced in Wales in 2013, followed in 2016 by a requirement for all new and converted houses to have sprinklers installed. NFCC would support greater alignment across the UK of the application of learning arising from serious incidents.
Where sprinklers are required in prescriptive guidance, NFCC believes that this should mean the whole building is protected (including the residential and any commercial parts). It is the experience of FRSs that sprinklers are often only installed in a specific area or purpose group referenced in the guidance, without covering other associated parts of a building (for example, sprinklers being omitted from a car park in a high-rise residential tower, because the guidance only specifically refers to the residential aspect). NFCC believes that where sprinkler protection is installed, the relevant British Standard should be followed, which requires the whole residential building to be covered.
Recommendations
- Government should make it a requirement to retrofit sprinklers in all high-rise residential buildings over 18 metres or that have at least 7 storeys that are served by a single staircase.
- Government should make it a requirement to retrofit sprinklers in all existing residential buildings over 11 metres on a risk-assessed basis.[7]
- Government should ensure that the installation of sprinklers in a residential building covers the whole building, in accordance with the relevant British Standard, and not just a specific area or purpose group as referenced in prescriptive guidance.
Schools
Deaths and injuries in school fires are rare. While sprinklers would provide additional life safety benefits, the greatest gains to be made are in protecting property, which will in turn secure the continued education of children and minimise community disruption. NFCC has persistently called for sprinklers to be mandated in all new and major or significantly refurbished school buildings. One FRS reported 75 school fires from 2013 to 2020, and of those 75 fires in schools, only the two schools with sprinklers resulted in minor damage and fire contained within the rooms of origin.
School fires can be devastating, and the use of sprinklers is proven to not only minimise the disruption to a pupil’s education but also the impact on their family, the community, and the wider education system. Schools are important community assets that need protecting. The loss of a community asset such as a school can unintentionally impact disproportionately upon lower socio-economic areas as was highlighted during the COVID pandemic and the related school closures.
School fires can be large and take up a large proportion of resources from FRSs and other first responders, increasing the risk to the services responding to the incident. The installation of sprinklers can help contain fires, not only reducing the burden on resources but also the risk to firefighters. This is another reason why we have consistently called for the installation of sprinklers in new schools and all new student accommodation, including the retrofitting of sprinklers in existing school buildings when major or significant refurbishment takes place.
In May 2021, the Government announced a proposal to make the installation of sprinklers mandatory in new schools over 11 metres in height. However, given that only a few schools currently meet this threshold, the benefits of this proposal are likely to be limited. When replying to the consultation on these proposals, NFCC was clear in our strongly held belief that they constitute a lessening of standards from previous guidance. The original guidance, when first released in 2007, acknowledged the important role of sprinklers and stated that “all new schools should have fire sprinklers installed except in a few low-risk schools.” The proposed changes in the guidance are a retrograde step and represent a real lessening of standards in this area.
Fires do not discriminate based on building height. Accordingly, the requirement for sprinklers should be extended to include all new and substantially refurbished schools regardless of height. In both Scotland and Wales, sprinklers are already mandatory in all schools regardless of height.
Recommendation
- Government should require all new schools, all new student accommodation, and all existing schools and student accommodation undergoing major or significant refurbishment, to have sprinklers fitted regardless of height.
Car parks
Car parks are a vital and often overlooked element of building safety. Government policy tends to focus on cars in terms of congestion, traffic, and road safety but where we park our cars is not always thought of holistically within thoughts of where we work, rest and play. There are concerns that some built environments, particularly enclosed car parks, may not be constructed with the measures needed to withstand and manage fires and allow safe access for firefighters.
Enclosed car parks include but are not limited to:
Open sided car parks
Basement car parks
Automated car parks
NFCC is concerned that the implementation of new requirements in the built environment may be taken in isolation, and not form part of the overall Building Safety Programme being led by DLUHC. The standard of safety expected in car parks, (particularly enclosed, covered, basement, and ventilation restricted car parks) should not be undermined by the introduction of technology and vehicles which did not exist when the original guidance was written. Current design guidance does not take into consideration the fire loading of modern vehicles, electric vehicles and liquified petroleum gas vehicles, as well as the risk of running fuel fires from plastic fuel tanks.
As part of our submission for the Technical Review of Approved Document B, (ADB), NFCC called for a review of the requirements for car parks, to take account of the products and materials used in modern vehicles (not just EVs), and to consider additional requirements for automatic water suppression systems and structural safety above those specified in the current guidance. This is supported by test evidence derived from research conducted by the Building Research Establishment (BRE) demonstrates the effectiveness of sprinklers in controlling fires in car parks. It shows that where sprinklers are present the property loss is around 95% lower than that of an uncontrolled fire.
Sprinklers within enclosed car parks, are common in Europe and also recommended by National Fire Protection Association Standard 88 (NFPA 88) in the USA.
While there have been few incidences of fatalities in car parks, there have been recorded fatalities to firefighters due to structural collapse abroad and there are cases of firefighter injuries within the UK while attending car park fires.
Recommendations
- Government should require AFSS in all enclosed car parks.
- Government should carry out further and in-depth research into fires in car parks and the design of car parks.
Storage and warehouses
Storage and warehouses, including large distribution centres, typically have a high storage density. This can result in fires of such size that it is difficult or impossible for the FRS to access and conduct manual firefighting operations. NFCC holds stark concerns about how fires in storage and warehouses can quickly spread and cause extensive damage, as well as closing nearby transport links. The disruption and destruction caused by these fires can result in a significant impact on the UK economy. Sprinklers protect property and allow business owners to be better prepared and able to recover from fires that threaten their own and others’ businesses.
NFCC has supported research to assess the ability of firefighters to safely perform rescues from large storage and warehouses. Our research suggests a threshold of 4,000 square metres is the limit to undertake effective rescue. This clearly demonstrates that the current sprinkler thresholds of 20,000 square metres for storage and warehouses must be lowered.
We are also concerned that too much focus has been given to the height and floor area of a storage building or warehouse rather than the types of material that are being stored. Storage buildings and warehouses can contain hazardous or dangerous materials with the potential for fire or explosion. This presents a risk to those in, or in the immediate vicinity of, the storage building or warehouse. More consideration must be given to the use of warehouses and storage facilities.
In Scotland, the thresholds of the floor area vary between 1,000 and 14,000 square metres depending on what is being stored. The justification for this variation is that the size and consequences of fire can vary significantly depending on the products beings stored. In the event of a fire, sprinkler systems can help control and extinguish the fire, reducing the spread of flames and smoke, and providing more time for people to evacuate the building.
Recommendations
- Government should lower the threshold for the requirement to install sprinklers in all storage and warehouses to 4,000 square metres.
- Government should set different thresholds for mandatory fire sprinkler installation depending on the type of material stored in a storage building or warehouse below the maximum of 4,000 square metres.
Hospitals
Hospitals are a vital community asset, yet provision to help protect them through sprinklers is not mandatory in England. The Department of Health and Social Care in England’s ‘Health Technical Memorandum (HTM) 05-02: Fire risk management in healthcare premises’ recommends the installation of sprinkler systems in hospitals. This document encourages sprinklers but does not mandate them, a recommendation that hospitals are choosing to ignore.
The fact that sprinklers are only encouraged, rather than mandated, is particularly concerning given that hospital buildings are at increased risk of fire due to a high concentration of people, patients with limited mobility, reliance on staff to assist with evacuation (which have reduced provisions in some wards during night-time hours when people are more at risk due to sleeping), complex building layouts, and the presence of combustible material including oxygen tanks and alcohol-based antiseptics.
Fires in these buildings would result in a significant loss to society and its ability to look after patients in our communities. A key protection measure that is demonstrated to mitigate these risks and impacts, and prevent multiple fatalities or injuries, is a sprinkler system.
Recommendation
- Government should require all new hospital buildings to have sprinklers fitted regardless of height.
May 2024
[1] Optimal_Sprinkler_Report.pdf (nfcc.org.uk)
[2]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/707785/Building_a_Safer_Future_-_web.pdf
[3] Examples include Beechmere Extra Care Village which was destroyed by fire in August 2019 and Newgrange Care Home which was destroyed by fire in April 2017.
[4] https://nfcc.org.uk/our-services/building-safety/protection-building-safety/stay-put/
[5] NFCC would support a requirement to retrofit existing residential buildings over 11 metres where there are risks that include compartmentation defects, design or build quality defects, the presence of vulnerable residents, extensive travel distances to a staircase, and the presence of hazardous materials. Please note that this is not an exhaustive list.
[6] https://nfcc.org.uk/our-services/building-safety/key-positions-work/
[7] As per footnote 5.