We are not commenting on any feature other than the use of the FSO in relation to multi-occupancy high-rise buildings. Our responses contained below.
General comments
Q7. To what extent do you agree or disagree with the scope of the Fire Safety Order?
- We disagree with the scope of the Order
- The application of the FSO to the common parts of high-rise multi-occupancy buildings has not been a success.
- The coroner investigating the Lakanal House fire (2009) raised the uncertainty which she had identified over ‘the scope of inspection for fire risk assessment purposes which should be undertaken in high-rise residential buildings’ and ‘evidence that indicated that inspection of the interior of flats or maisonettes in high rise buildings was necessary to enable an assessor to identify possible breaches of the compartment’ in her letter to the relevant Secretary of State under rule 43.
- The post-Grenfell uncertainty over whether cladding constitutes a common part (we assume that the Home Office is aware of the details of this issue) suggests this issue has not been resolved and has been a factor in the length of time it is taking to remediate ACM cladding.
- We are also aware that a number of buildings have subsequently been discovered to have internal compartmentation issues unrelated to cladding. While the FSO has been effective in allowing fire services to take enforcement action in these cases, the existence of widespread problems with compartmentation suggests that the FSO has not been effective in terms of prevention.