Joint Inspection Team training videos

Jonathan Herrick: Hello and welcome to this presentation about the Housing Act 2004 for the benefits of Fire

and Rescue services. My name is Jonathan Herrick, I'm the principal fire engineer for the Joint Inspection Team and I have 26 years of experience in the fire and rescue service and 30 years in the fire industry in total. I shall now introduce my colleague,

Richard Chubb.

Richard Chubb: Hello, my name is Richard Chubb, I'm a Principal Environmental Health Officer in the Joint Inspection Team. I've worked in the team for approximately two and a half years, and prior to that I was a Principal Environmental Health

Officer at Nottingham City Council. The National Fire Safety Joint Inspection Team was set up in 2019 as the Government's post Grenfell response it's paid for by the Department for Levelling up in Housing Communities. And we are based and employed by the Local Government Association. We are effectively employed to parachute into local authorities and assist them with inspecting and enforcement of tall buildings.

Jonathan Herrick: The aim of this presentation is to enhance the knowledge and understanding of fire safety inspecting officers of the powers available under the Housing Act 2004, and how those powers can be used in conjunction with fire safety law to make buildings safer for residents.

Richard Chubb: The objectives of this presentation today are to help fire and rescue service inspecting officers to better understand the legislative landscape in relation to housing. Housing Act 2004 and the Housing Health and Safety Rating System, which is made under regulations under the Housing Act to help understand relevant matters that inform the assessment and to understand what we mean by likelihood and harm outcomes which feed into the assessment. Areas of enforcement underneath the Housing Act and the powers of entry that are  available to officers who are authorised under the Housing Act 2004.



The compliance with Approved Document B does not always mean that the building is totally safe and how the fire rescue services can work in partnership with environmental health officers for the benefits of the communities.

Jonathan Herrick: We'll start with a brief overview of the various laws that relate to housing. A natural start point

feels like the Regulatory Reform (Fire Safety) Order 2005. The Fire and Rescue Service should be very familiar with the fire safety order.

While it's principally a workplace law, a point which has really not changed in recent years, it has some relevance to non-workplaces, in particular parts of domestic premises, used common by the occupants of more than one such dwelling. The order centres about the provision of general fire precautions that should be identified from undertaking an assessment of risk from fire in premises to which the order applies.

The duty to take general fire precautions is imposed on the responsible person as defined at article three. And further duties are imposed on other people. At article five. well, there's a duty to comply where necessary with articles and any regulations made under Article 24. The minimum standard to be established through the law is that required for life safety. The Fire Safety Act 2021 has been recently introduced. It clarifies the scope of the fire safety order and applies to premises that contain two or more sets of domestic premises. The scope is clarified in so far as it applies to the structure, external walls,

including cladding and balconies.

It also applies to individual flat entrance doors between the domestic premises and common parts of multi occupied residential buildings. For both areas that have been clarified, the Act makes no provision for additional powers of entry

to fire safety. Inspecting offices, for example, to inspect balconies up close to get close to external walls, to see what they’re made from or indeed to inspect and look at  front doors of individual flats. The Act also clarifies that compliance

with government guidance tends to imply that there was no contravention and that failure to comply with government

guidance might tend to indicate the presence of a contravention.

Finally, the Act conferred power to make further changes to the fire safety order and to the premises to which it applies.

Richard Chubb: Okay, so the Housing Act 2004 applies to all housing stock, and it's mostly used by local authorities

to regulate private landlords, but it can be used to assess and enforce against social landlords as well. The Housing Health and Safety Rating system, the HHSRS, is used to assess 29 different hazards. The joint inspection team effectively

only really assesses the hazard of fire in tall buildings. And so as part of the assessment, we assess the likelihood and the harm outcomes and we use a numerical calculation to calculate a hazard score that is then turned into a banding,

which is a letter from A to J, with A being the most serious and J being the least serious.

The addendum to the Housing Act 2004 was produced post Grenfell and assisted to clarify how local authorities

should use the HHSRS to assess tall buildings.

Jonathan Herrick: The Fire Safety (England) Regulations 2022 are yet to come into force, coming into force in January 2023. These regulations further outline the overlap with fire safety law, with housing.

Within the regulations, three height thresholds are established applicable at 18 meters, 11 meters and to all buildings with rules applicable to each height threshold. The new requirements relate to wayfinding signage, the provision of information to residents, which builds on the provision of information that should be provided to employees under the fire safety order already and various requirements in relation to fire doors and fire door surveys and provision of information.

There are also requirements made in relation to two new terms: key firefighting equipment and essential firefighting equipment. These two terms use the words firefighting equipment in a different way from that in which the order has historically applied them. So that is something for fire and rescue services to look out for when enforcing the new regulations.

The Building Safety Act is a huge piece of legislation which has been in production since the Grenfell Tower tragedy. In all likelihood, you will be well aware of the upcoming Building Safety Act, which will deal with high risk buildings, with respect to fire and structural risks. It will apply a safety case model to buildings and will regulate those risks using a Building Safety Regulator.

The Health and Safety Executive will be the home of the new BSR and they will establish multidisciplinary teams consisting of the Health and Safety Executive, Building Control, Fire Services and maybe housing authorities. Using the multidisciplinary teams, The BSR will regulate the buildings in scope of the Act. We do not have time to go into detail of the Building Safety Act, but the last few slides should have made it very clear that the landscape of regulation in housing is changing and that there will be several layers and several different routes to fire safety enforcement in certain subsets of housing.

The next few slides will give more information about the Housing Act in particular before we touch on joint working and more technical details of the Housing Act to better aid your understanding of it.

Richard Chubb: The Housing Act 2004 confers powers on inspectors to enter residential premises at any reasonable time,

but must get at least 24 hours notice when the inspection will take place. The inspection can consider parts of the residential premises used in common by the residents and access to individual flats. If access is refused, the local authority can obtain a warrant to inspect from Magistrates Court.

EHOs can take with them any person who they feel is necessary to assist them in the carrying out of their duties. Those with specific skills that might contribute to their understanding and interpretation of risk. This power to take others with them could be a useful function to fire safety inspectors if they want to take a closer look at the fire safety hazard posed by external walls, balcony construction or front doors. In common with the fire safety order, EHOs have the power in the Housing Act 2004 to take samples of materials to require the production of documents.

Documents required for production must exist already. EHOs cannot require the writing of new documents that do not exist under Section 235. So the HHSRS system and the hazards of fire. So the things that we consider are initially - the likelihood. So the likelihood is of a resident suffering harm from a fire. So as you'll see on the table here, these are representative scale points for likelihood, national average for a typical 1979 block, which is most of the housing stock that we are assessing is in this band here. So 1800. So we assess relevant matters within the building. This may include things like absence of or non-functioning fire detection. It might include non-functioning communal automatic fire detection.

It could include non-functioning or poorly maintained smoke control system. It also includes about 30 relevant matters in total. I'm not going to go through them all today. They're all included within the addendum to the HHSRS. All right. So if you could just go back to that last slide and as we get more and more problems with relevant matters so we normally score these from 0 to 3, zero being no problem with it, three being seriously defective.

So as we look at this representative scale point, which is our likelihood from the average building, we then move this down and choose what we think is most representative. Considering how many issues we've got with our relevant matters.

So how bad a building is. Some relevant matters are going to affect the fire safety more than others. For example, the external wall system. If there's a lot of combustibles on the outside of the building and it's close to places where fires can start and it can pass between windows on the building, for example. That's going to have a lot a larger effect on the building effectively. So a problem with that would increase our likelihood considerably. Something like if you saw a couple of penetrations that were poorly fire stopped, for example, it's not going to have a massive effect on the entire building. So we consider that it would probably have less effect. So if you just saw that, you might just move it to one in one thousand.

For example, if you saw a combustible wall system completely encapsulating the building with a broken fire detection system, then say, for example, with falling bits of fire doors, then we're going to be moving it down here to the to the higher likelihoods.

Okay. Next slide. This is the HHSRS formula. You'll see here the class of harms. This effectively means there’s four classes class one is the most serious, which is death or permanent disablement or in a coma, for example, going down to serious burns, less serious burns with fires, or maybe just some mild smoke inhalation for class four. You don't need to memorise this, it’s calculated effectively by a spreadsheet.

This is a fraction of, say, one over the likelihood. So if you've chosen one in 100, for example, it's one over 100 that’s then multiplied by the spread of harms. So when we choose our rating for that. Okay. Next slide. So from that, when we calculate the hazard score, it's a numerical score and we then compare it to our hazard band so if, for example, we've scored it and it's come to 980, it's within this band here. So that would then correspond to a D say band D. So bands A to C are category one hazards and bands D and below are category two hazards.

So what do we mean by a Category two hazard and category one hazards? So Category one hazards are the more serious hazards category two are less serious. Councils are under a duty to take action under Category one and under Category two the authority may and has a power to enforce, but it needs to be reasonable. So if we have, for example, the J and you're requiring them to spend £10 million on the repair, is that, for example, that might not be proportionate. Think is the word the more serious hazards, for example. Councils will be considering whether or not there's an imminent risk and if there's an imminent risk, it affects what enforcement action we take after that.

So the Housing Act 2004 provides a power of entry for local authority officers. EHOs have to be authorised by the council via delegated powers just as the fire safety order confers powers of entry on inspectors. Both pieces of legislation give a power of entry to parts of premises used in common by the occupants of more than one dwelling, whereas the order facilitates access to areas used in common at any reasonable time. The powers of entry from the Housing Act requires a notice served under Section 239 and 24 hours’ notice. If the Section 239 notice is served on owners and occupiers of dwellings, access under the Housing Act can be gained to those dwellings.

If fire inspectors were to accompany EHOs this access would enable inspectors around the building. This access would also allow fire inspectors to see if the temporary alarm is in place in the dwelling and to inspect the front doors of individual flats. We note the powers of fire and safety inspectors have not been extended under the current fire safety laws. Joint working to overcome access issues could be mutually beneficial. In practice less than 24 hours’ notice can be given for access, can be refused. And even if access is granted, the information obtained could not lead to the serving of an enforcement notice.

Common parts could be inspected, and emergency action could be taken. The greater notice required by the Housing Act when compared to the fire safety order is because it principally concerns access to people's homes. Our experience

today is the occupiers of private blocks welcomed the fire safety team into their homes. If we are flexible with them, for example, they may need to tidy up or ventilate or climb out the shower and get changed. This is aided by being personable

and we wear protective face masks during periods of COVID.

It is also important to understand the limits and scope of the Housing Act 2004.Only deficiencies with premises, i.e. the fabric of the building, give rise to a risk of harm to residents can be enforced. The scope is such that there is nothing precluding the local housing authority, the council, from requiring any measure to be taken if it will reduce the risk, including the installation of facilities and equipment for the fire and rescue service, which of course is something that fire safety inspectors cannot require

under the fire safety order.

Jonathan Herrick: Having said that, the Housing Act cannot require ongoing maintenance or other management related issues. The Act can request repairing maintenance to defective building systems, just not ongoing maintenance or management controls, including occupier behaviour issues for example. By contrast the Fire safety order is useful to regulate

maintenance under Articles 17 and 38 and management behaviours under Article 11, which the Housing Act cannot require.

This includes, but is not limited to the inappropriate storage of residents’ belongings in cupboards, risers or corridors.  Introduction of new ongoing maintenance processes, etc.

Richard Chubb: This presentation aims to give an introduction to the Housing Act 2004.We feel it might be helpful to touch

briefly on joint working. As with any inspection, information and data might be available before the inspection takes place. Any information held by either party should be shared so that a common understanding is reached and everyone proceeds from the same starting point. Naturally, any sharing of data needs to comply with data sharing protocols and the law. Section 235

allows the local housing authority to require the production of documentation the authority might need to carry out its housing enforcement functions and also to investigate whether an offence has been committed in relation to residential premises. Note documentation is produced not created, so the authority can only require documentation that already exists. Examples of existing information that might already be under the control of the duty holder include, but are not limited to fire strategy, fire risk assessment, commissioning certificates, maintenance records and test certificates for any of the following for example, the dry rising main, wet rising main, emergency lighting, fire detection systems other active and passive fire safety systems, lightning protection. Cause and effect schedules might be requested. Plans of the building are often available and information relating to solar PV, which might be present on the roof. All documents required by the authority must be requested from the right person, meaning someone who might be reasonably expected to hold the document. Authority should consider people who may hold information such as a duty holder, freeholder head leaseholder, leaseholder or the responsible person.

Jonathan Herrick: In all cases where a prescribed fire hazard exists and the local authority intends to take enforcement action, the local authority has a duty under Section ten to consult with the local Fire rescue service, to confirm that the requirements relating to fire safety are appropriate. 

Richard Chubb: The sharing of skills, knowledge and experience across the team is very useful at all stages, and any joint inspection ultimately results in a well rounded conclusion and the best safety outcomes for residents. During the inspection and for the debrief, it's helpful to establish shared descriptors for such things as the different elevations of the building, both externally and internally, especially with more complex layouts. The cupboards and risers that will be referenced in any communications with responsible persons, different staircase enclosures if there's more than one and demised areas as well as any of the building specific matters. By sharing experience and technical understanding, hazards can be identified

and better communicated, and ultimately an agreed understanding of the risks posed by the building can be determined.

On conclusion of the inspection, the findings of each agency should be discussed at an appropriate location. The discussion and sharing of understanding, and priority concerns should be drawing from the specialisms, skills and experience across the team. 

Jonathan Herrick: After the inspection, and if enforcement action is necessary, it is helpful to agree as early as possible, which authority will take the lead and for which actions. Remember, the limitations of the Housing Act 2004 that it may only make requirements in relation to deficiencies in the building, but not in relation to ongoing management and maintenance. Decisions might relate to which legislation takes primacy and if both apply equally, it might be preferable

to use the legislation that offers the path of least resistance. In some cases, using the order might be quicker because notices are served on the responsible person or on the duty holder, whereas copies of some notices served under the Housing Act 2004 must be served on all people with a relevant interest in the building, which could be a huge administrative burden.

There might be some required action that cannot be taken under one law that can be done under the other. Together, there should be routes to address all requirements by using a combination of the Housing Act 2004 and fire safety laws. Clearly, each inspection inspector from the respective authorities should make their own notes and complete their own administrative functions after the inspection. Having agreed terminology will help with note writing, and especially when serving notices. If common terminology is used by both authorities. The reader will be better positioned to understand what is being required. Environmental health officers might be unfamiliar with tall buildings and the fire safety features used in them, so they might need help to understand the terms applicable and any notes that are shared with them.

In addition, we find benefit to sharing notes made during the inspection between the people present. We find that note sharing between those present can act as an aid to memory or can spark further reflection and thoughts that contribute to the shared understanding of risk. Under the Housing Act, the improvement  notice is served with two schedules. The first describes faults or risk, and the second, the works required to address the hazards. When notices have been drafted. It can be helpful for both authorities to read them through and be able to comment to ensure that all the necessary or agreed points have been covered and that if the required action is taken, the assessment, sorry the assessed risks will be reduced to a reasonably safe level, typical for the age of the building. Despite this being best practice, the local authority has a duty imposed by Section 10 of the Housing Act to consult with the local fire and rescue service before taking enforcement action in relation to the prescribed fire hazard. The requirement is to consult. They don't necessarily have to agree, but they are normally advised to.  Fire safety inspectors might be well aware that just because a building once passed through building control process, it does not mean

that the building is necessarily safe. It might even be said if some new buildings, especially where the statutory consultation with the fire and rescue service has been less than smooth. Inspectors may also be aware that it's not the role or duty of the building control body, to comply with the functional requirements of the building regulations.

That is the duty of the principal contractor, principal developer etc. So during our inspections of high rise buildings, we have found many examples of buildings that pass through the building control process, but in which there were building safety hazards. Both created through mismanagement of the building and hard baked into the design of the building. In other cases, compliance with building regulations has been treated like a tick box exercise, and the feature needed to satisfy the  regulations does not in fact deliver safety in reality.

We have noted this most often in relation to smoke control and other ventilation systems. We have seen ventilation provided to satisfy approved documents B to the building regulations, but which in practice allows the wind to blow any smoke produced by a fire back into the building and into the means of escape routes. We have seen deviation from the agreed

building plans such that offices and dwellings are open to the staircase enclosure and smoke ventilation that is locked behind a door. We've seen natural ventilation used inappropriately and smoke shafts that don't extend above the roof level, where the fire might spread to the roof itself, as well as smoke shafts, that are combustible. The list goes on.

Richard Chubb : We frequently see smoke detection in common areas and wonder often what its function is. We often require the production of a cause and effect matrix for that system so that we can actually fully understand the sequencing

and operation of those systems.

Jonathan Herrick: We see many facilities for use by the fire and rescue service, but sometimes the systems are poorly

installed. So that for example, the use of a dry rising main outlet would hold open an adjacent corridor door

or would prevent the door from being opened so it was necessary to evacuate people they couldn't get out. We've seen firefighting lifts that have not been serviced that lack some or many of the features of the fire fighting list, etc. We've seen dry rising mains in premises for which guidance would recommend wet rising mains. We see many issues with access

to the perimeter of buildings, especially in connection with tackling fire in the external walls and access for high reach appliances.

Richard Chubb: We've seen riser cupboards containing various fire hazards. There have poorly fitted fire doors, walls

made of aluminium metal section framework holding plasterboard in place where a fire would melt the aluminium frame

and allow the plasterboard to fall out. It is also impossible to inspect a building fire safety without finding issues with fire doors or doors intended to be fire doors, whether it be excessive gaps, missing screws, incorrect vision panels, broken self-closing devices, etc., etc. We have seen penetrations going through compartment walls and into false ceilings, including gas pipes in the firefighting shaft.

Jonathan Herrick: Compartment floors can be let down by penetrations that are improperly fire stopped. An issue with converted buildings or buildings to which floors have been added is with the fire resistance of the compartment floors, for example. Where the previous building had a requirement for 60 minutes of fire resistance, with subsequent floors added to it, the new height threshold might require 90 minutes of fire resistance to the structure, to the floors. Frequently, in such cases, the fire resistance to the structure of the lower section of the building is not enhanced to match the new building height. We also see penetrations in the floors above basement carparks, for example, such that a car fire could penetrate through the floor into the dwellings above. We've even seen a service shaft clad internally on between three and four of the walls of the shaft with chipboard open at the basement car park, such that a car fire would spread up the shaft like a chimney spreading to the fire in the chipboard in the cupboard of each residential floor.

Richard Chubb: More often than not, all openings for doors are constructed much larger than the door frames fitted into them. The resulting gap between the wall opening and the door frame is often not filled at all or filled with inappropriate material. It has no fire resisting properties so that the only protection to the residential corridor from a fire in the cupboard is the architraves that's facing to the corridor. The evacuation method can be cause for concern.

Jonathan Herrick: Not only staying put when simultaneous would be better, but also changes from stay put to simultaneous

without thinking it through or with instruction to report to an assembly point which doesn't exist or report to a non-existent fire marshall. This subject links to the NFCC guidance on changing evacuation strategies in buildings, which is not always taken

into consideration.



Richard Chubb: In another example, during the building control process, an atrium space was suggested by the developer as being the same as outside space for the purpose of balcony access to flats. The atrium had a permanently open vent in the vertical plane. See here through which the prevailing wind blew. So the south westerly was blowing straight into that and wouldn't allow it to function properly. The top of the atrium was closed with glazing. To our way of thinking, the atrium was not equivalent to a building with an external balcony approach.

Jonathan Herrick: Naturally, our work is targeted first and foremost on buildings with hazardous external walls, and for which there is no plan for remediation. As we've already shown, the external walls are only the start of the issues that can be found in these buildings. But it would be amiss of us to discuss the safety of tall residential buildings without at least mentioning the cladding, which should never have been combustible in the first place, but which nonetheless obtained building control approval in many cases. We have seen many wall coverings and layers, including ACM in various categories, expanded polystyrene, high pressure laminate, combustible insulation and missing or substandard cavity barriers to name but a few.

The fire safety order can deal with some of these findings, but others may be more difficult to address under the order. Remember the Housing Act 2004 can go beyond the requirements of building regulations and associated guidance and beyond fire safety guidance as we have previously said, there is nothing precluding the local authority from requiring anything they think necessary.

Richard Chubb: So I mentioned earlier the relevant matters. So they are stated in the addendum to the HHSRS operating guidance. These include issues with absence of evidence that an external cladding system is non-combustible and extent of coverage. Disrepair to the outer surfaces of the building. Lack of current, suitable and sufficient fire risk assessment.  Outstanding action points from the fire risk assessment. Lack of or non-functioning AFD and alarms in dwellings in cases where individual dwellings are being inspected. Non functioning or poorly managed and maintained smoke control systems in the common parts. This may include no record of weekly testing to BS9999 2017. Disrepair to the fabric of the building and any compromising compartmentation and the absence or inadequate record of dry wet riser six monthly checks. So relevant matters to the hazard of fire in tall buildings includes services and service ducts that compromise compartmentation services

not in fire resistant enclosures.

Non fire resistant doors or badly maintained doors opening onto common parts disrepair to refuse chute hoppers, sources of fuel, rubbish or other flammable material external or internal inadequate waste storage opportunity for external intentional

firefighting starting external unintentional fire starting for example car fires, skip fires or barbecues on balconies. Lack of  controlled secured access to the building permitted permitting unauthorised access and risk of arson. Matters that can be required to be improved include the following removal of the existing cladding and or insulation and or cavity barriers. This is likely to then include installation of new external wall systems involving the need to comply with building regulations. There are obviously also Regulation seven issues. We can't put old combustible insulation back on and there's a complete ban on anything that's now not A1 or A2 B1 D0. It may require the replacement of balcony and terrace floors, including combustible elements of construction, such as the beams and joists. Compartmentation and fire stopping survey, and to address all of the issues found on those surveys. May also include additions to or existing or completely new fire detection systems in common parts or covering common and leasehold flats also. May include a fire door survey and the requirement to repair or replace

any defects found on that survey. It includes additional firefighting facilities such as a dry rising main, wet rising main, smoke control changes and repairs, including requiring changes to mechanical extraction and issues with pressure differentials

in mechanical smoke control systems.

As with the Housing Act is quite complex in terms of who we are required to serve the notice on. And if there is a right to manage company, it adds additional complexity. We're not going to go into detail of that today but please be aware of that. If flats are demised to a leaseholder, including the front door, there may need to be a separate notice served on the leaseholder. This may include repairs, to fire doors opening onto common parts, fire detection and alarms, including additional units and flats to comply with NFCC guidance, that would normally form part of the overall improvement notice on the freeholder.

Fire resistant back plates two electrics on the inside face of external walls. If such work would offset hazard posed to the external wall system. So the Act requires the authority to serve notices on a person who is an owner of the specified premises, concerned and, in the authority's opinion, ought to take the action specified in the notice. Normally it’s served on the freeholder, but not always. As I mentioned before if there’s a right to manage company it adds a level of complexity because they aren't true owners of the building, yet, they may have the right to do all of the repairs to the building.

So be aware there’s case law surrounding this issue. Also the same applies with resident management companies

where they're responsible for repairs. So the council will need to take advice from their solicitors in such cases. So the powers available to the local authority under the Housing Act are relatively similar to those available to fire services under the fire safety order. If there's an imminent risk in a building, there is something known as emergency remedial action. So this may include if the freeholder isn't immediately contactable, the council may employ the services of a fire alarm company to go in and get it back working or install temporary alarms.

So please note that that requires an imminent risk. And quite often the fire service will need to provide that opinion as to

whether or not there is imminent risk. Emergency prohibition is also requires imminent risk.  So again, the fire service is likely to be consulted upon the risk posed by that defect. There's also a prohibition order which takes 28 days to take effect if it's not appealed. If it's appealed, it may suspend that. An improvement notice is the most commonly used tool by the local housing authority. It imposes requirements to be addressed within certain time limits. So, for example, the council may serve

a notice requiring the external wall system and insulation to be replaced within 18 months to two years. It's probably sensible at the moment due to shortage of contractors. So it needs to be reasonable. Another action is to serve an improvement notice

and then suspend it. This may be used where councils are dealing with a trustworthy landlord such as  a university landlord, for example, where they can demonstrate to them that they have specified the works, have obtained planning permission and are in the process of starting the works already. That would then be suspended until, for example, 18 months from the date of the notice.

If they aren't starting works after those 18 months and it doesn't appear that they're going to start you would then re-serve a full improvement notice. Another option is to serve a hazard awareness notice. Now, this doesn't actually specify that the council has to address anything with it. It's literally just discharging responsibility from the council and formally notifying the responsible person be it the freeholder that a hazard is present in the building. There is also a demolition order. These are rarely used due to the cost of property, but may be used where the cost of works exceeds the actual value of the property.

So thank you for your time today. Hopefully it's been useful to you. We've included our team email on here ([email protected]) and our individual emails as well. If you have any specific questions about a building or you would like further advice on anything that we've covered today, please feel free to drop  us an email. Thank you very much. Goodbye. Thank you.

 

Richard Chubb : Okay, so welcome to the HHSRS meeting that we've got here in the offices today. So we're gonna go through our scoring of the building in question: Castle Towers. So I'd just like to introduce each other. So do you wanna introduce yourself?

Paul Stevens: My name's Paul Stevens. I'm the principal building control surveyor for the joint inspection team.

Richard: Thanks, Paul.

Jonathan Harrick: Jonathan Harrick, principal fire engineer for the joint inspection team.

Richard Chubb: My name's Richard Chubb. I'm the principal environmental health officer today.

Steffan Micah: My name's Steffan Micah. I'm the principal EHO with the joint inspection team.

Richard Chubb: Okay, so today we're gonna be going through a discussion basically of how bad this building is. So we're gonna be going through each of the relevant matters that are contained in the addendum and effectively scoring it, and including our evidence for why we are concerned about that item or not concerned about that item. So we're gonna kick off with number one. So you'll see in column A, which is the presence of an external cladding system and the extent, location to which the building is covered and the absence of any evidence that it is non-combustible.

So I'm going to first of all go over to you, Steffan. You've read the cladding report. What can you tell me about what we saw from the documentation that came from the building owner?

Stefan: It's possibly best if I combine that with what we actually saw the other day as well.

Richard: Okay, that's a good idea.

Stefan: So the majority of the walls, the external walls, they consisted of brick. It was a brick cavity wall but not a traditional

type brick cavity wall with two leaves of brick. It was an outer leaf of brick supported by a steel framing system. There was a cavity. The cladding report said inside that was combustible polyisocyanurate insulation.

Richard: Let's just call it PIR for the training today.

Stefan: Behind that there was two layers of plasterboard separating it from the inside flat. We also had silver coloured panels, cladding panels. The cladding report says these are insulated sandwich panels. So two layers of aluminium sandwiching, a

PIR core. So again that's combustible. We've also got some spandrel panels. These are panels that are above and below

windows covering the floor area. They consisted of an outer layer of aluminium behind which was two layers of plywood sandwiching an extruded polystyrene core. So again, that's combustible.

Richard: Yeah, what do we know about extruded polystyrene cores, Paul, is it particularly combustible?

Paul: Well, the testing on previous spandrel panels does show it is highly combustible.

Richard: Okay, sure.

I'm kind of thinking that Lakanal House that had some sort of spandrel panel problem, wasn't it?

Paul: Yes.

Richard: Yeah, okay. So I guess moving on from those sort of systems, any other systems that we saw on the building?

Stefan: We also had some glazed spandrel panels. These aren't mentioned in the cladding report, so all we can say about these is they've got outer surface is glass, there's some kind of grey coloured material behind them, possibly could be insulation there, possibly not. So I think that's something that needs further investigation.

Richard: Okay, great. So moving around the building, we saw balconies. John, do you want to talk about balconies? What they were made of? How concerned were you?

Johnathan: Yeah, they were a steel frame balcony, timber struts and a surface of deck board.

Richard: Yeah.

Johnathan: But on the underside of those, the soffit had a steel plate. So if there's a fire underneath, the steel plate really is going to deflect most of the flame and heat from it. So we don't really see fire leaping from balcony to balcony. They were pretty good, no bigger than maybe two meters by one meter.

Richard: Okay.

Johnathan: But we did see plenty of combustible materials on them and a couple of balconies with barbecues.



Richard: That's right, I remember seeing a couple of bags of rubbish on one of them and some artificial grass, which had been put down probably to make it less slippery on there.

Johnathan: Yeah.



Richard: Paul, how were they sort of connected to the building?

Paul: So these are cantilever balconies.Yeah. So the steel frame supporting the balconies from internally. The, they're deemed to be cantilever. They're in series, the ones above each other. Combustible wires as a building, very low. Part glazing, glazing can contribute to fire spread. But apart from that, I deem it to be lower. Lower.

Stefan: How would the glazing contribute to, I suppose?

Paul: It's laminate, it contains laminate.

Richard: Is the laminate in the middle or on the outside or?

Paul: It depends on the glazing panel and the design.

Richard: It's like, right, yeah. I think I remember seeing in the flat that I went into on the fourth floor, I think it looked like there was glazing and then a very thin film, which presumably was glass. And then a thin film, which presumably is the sort of glue that's holding it together, if it fractures. Would that be an issue?

Paul: It depends which type of actual type of the glass, what type of glass it is, how it was manufactured.

Richard: Oh, okay, great. Right, so you're thinking around the building from the front aspect, so we're going to call the front aspect the east in this case. So that was facing onto the road, we had an access sort of straight through the middle, through some flower beds to the front door. I'm kind of thinking what sort of penetrations did we see coming through the water, Jon?

Johnathan: There were multiple, there were some that were air vents, plastic vents on the outside, typically through the brick. Also through the brick there were what looked like the original boiler air ventilation. So there were two of them, one presumably for in and one for out there, but a number of the flats had had their boilers replaced with a balanced flue system. So another pipe, but the old flue system was still there. So some of the flats had maybe three penetrations associated with boilers.

What else did we see? Oh, there were some trickle vents, especially near those spandrel panels.

Richard: Any electric lights?  I'm trying to think of the ones to the balcony. Each balcony had an electric light. What can happen with that?

Johnathan: It's very unusual for something to go wrong with the wiring itself as it comes through the wall, or it can do. But more typically there could be some kind of electrical issue with the lamp itself, which could generate heat and could lead to a fire. But it's less likely, less of a risk I suppose on the brick finish, more of a risk if the wall surface itself is combustible.

Richard: Okay. Steffan, did you pick up anything else around the external wall system?

Steffan: Yeah, we also need to consider fire stopping to the penetrations.



Richard: Yeah, so that's sort of stopping a fire from say the boiler flue or something getting into the walls.

Steffan: That's right. So where the boiler flue penetrates the external wall, it would need to be fire stopped to stop fire

getting into the wall system. In one of the flats we went into, the kitchen, there was a boiler flue penetrating the external wall.

It was a brick wall on the outside. And we could see that the penetration hadn’t been fire stopped on the kitchen side. So there was a way for fire to get, if there was a fire in the kitchen, there was a way for it to get into the cavity to the brick wall. And inside there we've got a combustible insulation.

Right.

Paul: I believe there was also an issue with cavity barriers around windows.

Steffan: That's right. The cladding report, it did have a look at one window and it identified that there were no cavity barriers around the window. Thank you. You would need cavity barriers there again to stop the fire inside the flats getting into the cavity.

Paul: And I think there is metallic obviously cladding, rain screen cladding to the top floors and there's also earthing to that.

That's right.

Richard: It's quite an unusual sort of shape wasn't it? With a lot of mono pitched roofs running at different angles.

So I'm kind of thinking most of those cladding panels were on the upper floors. Certainly when I looked on Google Earth and had a little spin around the building they all seemed to be

on that sort of central core area. So John, in terms of how concerned

are we with the location of them? Was there a route for fire from a flat to get into them?

Johnathan: It was difficult I think. I think I agree. Not beyond the realms of

possibility but really unlikely. You'd have to have a fire in that building. Those duplex flats on the shorter side of the building, there were Velux windows, there and those Velux windows were pretty close to the silver cladding. So if we had a severe fire in there and

it breaks out through the Velux and we've got some flaming combustion coming out of

there, possibly it could ignite the panels and then it could go up through the panels

but there's nothing really that communicates with residences within flats. It becomes quite isolated.

Richard: So inside those panels, from memory I think I can remember that it wasn't On the edge of the staircase at the very top so there was nothing.

Johnathan: It was a glazed front to the staircase enclosure. It was kind of side walls wasn't it?

Richard: Yeah.

Stefan: Usually we would, it covered a relatively large area, these sandwich panels, and usually we would be very concerned about that. In this case we didn't have

any windows or penetrations or vents opening onto these panels.

Richard: So the smoke from any combustion is more than likely to go into the outside rather than going in because there wasn't really any way for it to come into that building was there?

Johnathan: I would anticipate that if a fire got into the panels, in most cases that would be a spectacular looking fire from the outside. It would look incredible. But the risk of it would be reasonably low.

Richard: What about if any of the outer parts of the metal bits fell off? I suppose it's not combustible anyway, that outer skin is it? So it's just going to expose the insulation?

Johnathan: If there's sufficient heat from those panels with the glazed front to the staircase enclosure, it might cause some of the glazing to fall out, there's some projectile hazard potentially but that's a long way into a fire. I imagine that the fire service is either well on top of it by then or has evacuated the building.

Richard: That makes sense. Anything else from the outside of the building then? So involving the external planning system, kind of thinking, it's probably covered in all of that.

Paul: I must note the cladding is surrounding the fire fighting stairs.

Richard: Okay, yeah, yes. Why is that an issue?

Paul: We're looking at protection of means of escape, so there's windows on the escape route, which there is in this case. If there is a cladding fire, that could hinder evacuation. true.

Stefan: Another thing we need to consider is cavity barriers within the cavities to these wall systems. The cladding report didn't really say whether there were or whether there weren't any cavity barriers. There should be to stop, you know, if a fire does get into the cavity, to stop the fire spreading out. So we haven't got any evidence whether there are or aren't cavity barriers. But I think it's probably reasonable for us to assume that cavity barriers are inadequate.

Richard: Yeah, I think I remember in the cladding report, they had taken out a brick effectively at the sort of junction between the outer wall and one of the floor plates. There didn't seem to be any evidence of any non-combustible fire break in that area. So I think it's fair to assume here that there are none. Now, Jon, what can happen in terms of firefighting if a fire did get into that cavity? Nightmare.

Johnathan It's a nightmare because you can't really access the fire. There's no flame to be seen, so you have to open up the wall. These are the brick walls. Yeah. Typically, the fire service is going to fight the fire from inside. It might fight it from outside if you

can get a high reach appliance to it, work from a cage or top of a ladder. But more typically, they'll fight the fire from the inside, chop away at the plasterboard to try and expose the fire

in the cavity, right back to the brick if necessary, and pour water onto it. Our problem with that is that nine times out of ten, by the time our thermal image camera said, this is a hot piece of wall and we've chopped it open, put the fire out, the fire now is spread up to the

next piece of wall or spread laterally. We've got a new hot piece of wall which we

have to cut open, put the fire out, a new piece of wall, cut open, put the fire out. Before you know it, we've cut away most of the inside of the building. It's useless.

Richard: I remember seeing in the news recently, there was a building in Boston in Lincolnshire, which was pretty similar to that, and they ended up actually knocking down the entire block of flats, losing tons of flats, which is obviously a bad thing. And did we see a similar type fire in Deptford in London? I think there was something similar, yeah,

certainly worth an investigation afterwards.

Johnathan: So it's not really a risk for the means of escape phase, because the building is destroyed bit by bit while the fire service are in attendance, most of the people would have gone, in fact all of the people would have gone and evacuated the site. From a resident safety point of view, not a great thing. From a resident welfare point of view, they're going to lose their flat, their place to live, probably a lot of possessions. Just a nightmare, because you've

got multiple households and they haven't got anywhere to live. So it does cause us a problem.

Richard: So I think, unless anyone's got any other things that they want to talk about, is there anything else that you, I think, that's pretty much summed it up?

Stefan: Yes, there's plenty left.

Richard: Okay, so back to the spreadsheet. We're now going to be moving down our

relevant matters to a lack of current suitable and sufficient fire risk assessment,

lack of FRA type 1, lack of FRA type 2 or 4. So hopefully the people watching

this already know what a type 1, type 2, type 3 or 4 risk assessment is. So we'll go straight into Jonathan. Have you formed any opinion on whether or not it's suitable and sufficient and what is suitable and sufficient?

Jonathan: A pretty open and shut opinion. The assessment has a review date on it, January 2021. Since we saw the place late in 2022, it's nearly two years out of date. And so its findings really aren't relevant to the way the building is now. Although there are some things in there that still relate to the building, as it is. A lot should have changed between

now and then - a lot of findings.

Richard: By that, do you mean maybe they haven't even addressed some of the problems that they had then?

Jonathan: For sure they haven't issued some of the issues that they had. Curiously, the assessment claims to be a type 4. There's no information in there that says they did any kind of destructive work.  I think what they mean is that there was some kind of survey done by another party at the time and that assessment was taken into account.

Richard: Right, okay, so taken account. A bit like a PAS 9980 type.

Jonathan: Not that good.

Richard: Not that good, obviously. But something like that. Okay, Steffan, do you want

to say anything about that? Obviously you've read it.

Steffan: Not a problem.

Richard: Okay, so we'll score that as a 2. So out of 3 is obviously our worst score for this. So it's not good. They have got one, but it's not good. It didn't have one all together, we'd

probably score that as three, wouldn't we? So they've got some form of fire risk assessment. It's probably the sort of thing that we might pass across to the local fire brigade.

Jonathan: For sure. There's a duty to review it regularly so as to keep it up to date and they haven't done that. So it's something that we've just got it to.

Richard: Okay, if we move on to the next one, number three, which is the outstanding action points from the fire risk assessment. So the first one that we were talking about before was a lack of current suitable and sufficient fire risk assessment. This is actually the action

points at the bottom of it. It tends to be at a table, doesn't it?

Jonathan: Yes, more often than not.

Richard: Okay, what do we know about that then?

Jonathan: Well, from the pictures in the risk assessment at the time, there were lots of combustibles being stored in most of the corridors throughout the building. That's something we did not see. So some things happened. Either that or they were expecting us and

someone's been around and cleared it up. I'm not sure which. But certainly we did not see

all those combustible materials. We saw some, but not as much as we're shown in the fire risk assessment. The assessment identified things like missing nosings off the stairs. So you could have potential trip hazards on the means of escape. They were still there, weren't they? They were still missing. Or maybe other ones were missing. We're not entirely sure which ones

were missing in the first place. We still had the issues with the external walls that the risk assessment reported. I don't think it knew independently about. And there were still some

outstanding action points. So given the fact that it should have been in January 2021, there were still a lot of serious points.

Richard: OK, I'm going to throw it to the open table. So how do you think we should score this?

Jonathan: I think with them standing out, being outstanding for so long, I'll probably go in three.

Stefan: OK, yeah, I think I'm the same opinion.

Richard:  Yeah, I'll get some nods there. All nodding-ish. OK, great. Let's move on to the next one. OK, moving on to number four, then, which is a lack of stroke, non-functioning AFD and alarm system within flats. So this is within the flats themselves. Steffan, what did you see within the flats that you went to?You were on the other team, weren't you?

Steffan: Yeah, I saw smoke detectors to the entrance lobby, heat detector to the kitchen. So yeah, grade D LD2 too. Grade D LD2.

Jonathan: We just did the one flat.

Paul: Sure. The ones we visited is the same, yes. And in the duplex, it was a smoke detector on each landing.

Richard: That's right. So did we see a broken detector on the ground floor?

Paul: Yes, on the duplex, there was a

detector that was misfunctioning.

Richard: Absolutely, yeah. I remember we said to the EHO site, we said, she was going to take it up with the, because it was a private rented land model wasn't it, who owned that one, and she was going to address that immediately. Okay great, so we've got it scored as a zero,

we've got the capability within the flats,  we think that there was just one that was

broken, it was probably 20 years old by then. We weren't too concerned by that, there

was a general picture of pretty good detection pattern within there wasn't the. So we've scored that as a zero. So moving down onto number five, lack of or non-functioning communal AFD. So, who would like to talk about the communal AFD? What is AFD?

Johnathan: AFD is automatic fire detection.

Paul: There was no detector in the fire fighting stairs to operate the AOV, however obviously there was detectors in the common corridors.

Richard: So there was no building wide alarm system?

Jonathan: There was no alarm system, there was no sound system, we think it was just like an L5 system, so stuff there to operate the… smoke control, AOVs, yeah, from the common corridors.

Richard: We didn't see a panel though did we? There was a panel, there was no panel.

Steffan: No, I didn't see anything in the cupboards downstairs. You wouldn't usually expect to see that kind of system in this building. For example, if the block was completely

Clad in ACM, we thought there was a high risk of fire spreading into the cladding

and then fire cladding around the building. It would probably benefit from having at

least an interim communal alarm system. I think in this building we weren't

so concerned about fire spreading around the building via the external doors, which aren't there.

Richard: Agree.

Steffan: So, yeah, we don't think it would benefit from a communal alarm system.

Richard: Okay, so I'm sort of going to propose that what we saw was adequate for I think the provision was appropriate. Yeah, okay, so I've scored that as a zero then, satisfactory for the type of building that we're dealing with. So, shall we move on to the next?Yeah. The next thing I want to say is that lack of or poorly maintained sprinkler system. Did we see any sprinklers?

Jonathan: I didn't see any in the rooms.

Richard: No. I didn't really expect it to be in the building.

Jonathan: At the time it was built it wouldn't have required them.

Right.

Richard: Right. So there would have been - correct.

Paul :Yes. Over 30 metres. Yes.

Richard: Isn't it over 11 metres?

Paul: Oh sorry, 11 metres. We'll cut that out. Okay, so let's go back

onto the sprinkler system. So the sprinkler system. Paul, do you want to tell us about

the building regs that are applicable  at the moment for sprinkler systems? So number six is a lack of or poorly maintained sprinkler system. Now I didn't see any sprinklers in

this building unless you saw some of the flats that you went to.

Jonathan: No, there weren't any.

Paul: Nothing.

Richard: So at the time of construction, which was maybe in the 2000s? Around about 2005.

Steffan: 2005.

Richard: What building regs were applicable and what was the sort of requirements in those days?

Paul: So the requirement for a sprinkler system was brought in  in 2006 for over 30 metres. If the block was constructed today, anything over 11 metres would require a sprinkler or suppression system. Also, more complex buildings approved document part B may not apply. I wouldn't classify this building as that. That may be other guidance. But as the requirement at the time, it wasn't an issue.

Steffan: What about any, because this block is in London, would there be any London specific regulations?

Paul: So Central London, there is a requirement for section 20 of the London Building Act. Outer parts of London wasn't privy to that, so it's more related to Central.

Richard: So this would be far enough out that it wouldn't really apply?

Paul: So that's correct.

Richard: Okay, so I'm going to propose that we score it as a 2.

Steffan:  Although it wasn't necessarily required  by regulations at the time, the presence of a sprinkler system still wouldbenefit the building in a positive way. It would reduce the likelihood of a fire spreading to the common parts, even though it's not a big problem.

Richard: Okay, so I'm going to propose 2. Any objections? Okay, number 7. Non-functioning or poorly designed, managed and maintained smoke control system in the common parts, or no weekly testing in accordance with 9991. So, what did we see in the building? Jon?

Jonathan: We saw the, Paul's already referred to the AOV in the staircase. So an opening window at high level in the staircase enclosure. And then on the rear residential corridors,

we had another AOV in that corridor, in the window, again in that window. And then, almost a bit curiously really, in the lowest part of the building. It was only the three-floor side,

remember, on that sloping roof, how it came down, but just a three-floor section.

Richard: Very short travel distance there, wasn't it?

Jonathan: Really short, yeah, only four metres, and then a smoke shaft in there.

Richard: Triggered by the overhead smoke detection, wasn't it?

Jonathan: On the whole, triggered by smoke detection in the corridor, although the ground floor had a...The whole door assembly was broken, and the door was held shut against the frame by fitting the handle upside down, so the handle...That was strange, wasn't it? Any...Door frames. Suspended. In all other cases, there was a powered arm that opened the door into the shaft.

Richard: I remember seeing on some floors the... I don't know if it was a call point or...

Was it flashing lights above some of the...

Jonathan: Yeah, there were overrides, smoke control overrides. And many of them, and without fail, they all had a green light, presumably for healthy power, but also a red light, which was... Depending on which one we looked at, it was either a constant red light or a flashing red light. And it just indicates that, well, something's wrong with the system.  It's not working as it should, there may be a failure on it or something.

Richard:Okay, so...I'm kind of thinking that it's almost. Would you say it's over-provided for

on the front of the building, then? Or is there another reason under Building regs why it might have been installed like that?

Paul: Without looking at the fire strategy. I think we're protecting the firefighting stairs, aren't we? We're protecting the firefighting stairs, but...going to get straight into the Staircase. Staircase, right. That makes more sense than that.

Paul :So the firefighting shaft itself, under Approved Document Part B, you're looking at protecting smoke entry in the staircase. So the firefighting shaft would

have been part of the fire strategy at the time, which does seem to be

a requirement under the guidance.

Richard: So, certification for that. What's been provided by the council?

Steffan: I don't think that I've seen. There was a test certificate from...

Richard: I think it was like 2020, where they said there was some faults with it. There was a certificate identifying faults.

Steffan: Yeah, it wasn't a test pass certificate. It was a service report.

Jonathan: It had nothing to suggest that it works properly.

Richard: Yeah, okay. And I also found in the common parts, there was a logbook, which should have been used for recording their weekly or monthly fire test.

Jonathan: Yeah, it was on the notice board.

Richard: Yeah, it just fell off, didn't it? And that actually said it had been

tested last year, 2020, I think as well. So I think we've got a problem with management in this block. Yeah, unless it's recorded elsewhere. Okay so we've got faults on it, it's

probably not been tested properly since 2020. I'm going to propose two.

Steffan: I was just going to say, if we're kind of, possibly for the purpose of the HHSRS assessment, are we going to presume that these red lights mean the system isn't working? If we do presume that, then I think we should give it a 3.

Richard: I remember looking to the top of the shaft that was in the... The smoke shaft, the short thing. Top of that, it was already open wasn't it?

Jonathan: There were open vents at the top, now that could have been causing the red lights, because something was opening where it shouldn't have been, but likewise if you looked up that shaft, it was not non-combustible, as we've said. It was combustible. There were elements of plastic floor timbers, you could see the whole lot going up through the building. The fire stopping in that shaft is dreadful.

Paul: And there would also be a requirement on how the top of that shaft would be finished off.

Jonathan: It was incidentally the level of the roof.

Paul: It was basically connected with the pitch of the roof, rather than extending.

Richard: So what sort of impact on the building could that have?

Jonathan: The combustible shaft means that we could spread fire from the flat into the shaft, and the shaft is on fire. And I think, well, I'll let you make your own points.

Paul: So basically if you haven't terminated it correctly, you could get hot embers escaping over smoke that's cooled down, but you could spread the fire to the roof plane.

Richard: Right. And then it might end up anywhere I guess.

Quite difficult to fight that fire I guess as well if it's on the roof. Got a solid steel top. Okay, well I proposed to begin with two, but I'm kind of thinking maybe this is a three.

Steffan: I agree with that.

Richard: Yeah, number eight, disrepair to outer surfaces. So what do we see? I kind of saw quite a lot of water ingress there. Any other?

Steffan: Yeah, I think that's it. It looked okay from the outside, but on the inside we saw a lot of water penetration to the common areas.

Paul: It's a profile roof with a lot of angles to it, a lot of flashing details, which has led to a lot of leaks to the upper floors. And there's also a vertical crack.

Jonathan: So a flaw in the brickwork.

Paul:  There was a vertical crack. It does need to sort of maybe further monitoring, but at the moment I'd classify it as some sort of movement.

Richard; Okay, so we'll probably rate that underneath the fire hazard, for example, it'd be something zero.

Jonathan: By movement you mean expansion or a movement of the building?

Paul: Movement of the brickworks. So contraction and expansion.

Steffan: So do we think the water ingress is probably something to do with the roof rather than the external walls?

Paul: The majority of the leaks to that building would be down to the roof.

Richard; Not all is it?  Because I saw some coming straight into the shaft at a low level associated with the water supply pipes.

Paul: In the shaft you can see there have been past issues and there was water coming into the shaft from the roof as well. There have been past leaks.

Steffan: So we're discussing water penetration here. What effect can that have on fire

because it's a fire risk process?

Paul: You could be looking at any fire protection compartment walls that have been damaged by water. If the integrity of that wall becomes not obsolete.

Richard: We're going to come onto that in a bit. Water and plastic are all our friends.

Jonathan: The vertical shaft that was being dampened by the water coming in also contained all the electric meters to the flats. The CCTV monitors were at the ground floor. The smoke controls were in the first floor or second floor. Somewhere in the same shaft. It's either the ground or first, the smoke control. So there's a lot of electrical apparatus and safety apparatus in the shaft that's fire safety apparatus. I think it was actually the ground. It was on the first floor. The ground floor was CCTV above that smoke control stuff.

Paul: And you can most certainly see water staining on the switches and switch here.

Richard: That's right.  On the smoke control system. I initially thought the fault might have

been associated with the electrical failure.

Jonathan: It promotes the chance of an electrical failure. So there are fire safety

implications to water penetration. Question for you. With the same disrepair throughout surfaces, and then drawing a distinction between, oh, is it a leak in the roof or in the outside walls? Does it make a difference?

Steffan: Depends what the safety of the addendum is.

Richard: We may need to go back to the addendum.

Jonathan: The roof in this case is definitely an outer, in all cases, I suppose, is an outer surface. I mean, nonetheless, either way, I guess that there's still a risk to the fire safety measures in the building.

Steffan: Yeah. Even if it's not mentioned in the addendum, we can still include it if we think there's an effect on the fire escape.

Richard: I also saw quite a few of those ventilation, you know, where they cut out a brick and inserted a..Airbricks. Airbrick. Yeah, I guess it would be an airbrick, wouldn't it?  I saw quite a few of those at low level where, and we actually had quite a bad rat infestation outside, didn't we? It's not beyond the realms of possibility. that they might spot a little

entry hole get into the cavity and all the electric wire in there?

Paul: Airbricks are required, they're required for suspended floors and in this case we had a suspended floor. They are required for cross-flow ventilation. In this case they were plastic

airbricks, they were damaged. If there was any secondary or primary power supplies coming underneath that floor they could potentially be damaged by rodents

Richard: okay, so I'm going to propose a two. We saw quite a lot of actual

penetrating damper didn't we? Which will have an effect on the fire safety after building.

Propose a two.

Jonathan: A strong two.Two stroke three. Okay. You guys are the experts in this.I just foresee a risk from the water ingress, that's all I'm seeing.

Steffan: So a three is seriously defective I think. 

Richard: It's a three isn't it? Which I think might change my mind on that.

Jonathan: It might be if it's causing the constant red light and the red flashing lights on the smoke control lights. Could be.  I don't know.

Richard: Let's go for a three.

Jonathan: I'll leave it to you.

Richard: Okay, moving on to the next one. We have, move that down a little. So we've got disrepair to the fabric in compromising compartmentation. So Steffan do you want to just talk

about the different compartmentation relevant matters on here? Because they can be quite

confusing can't they?

Steffan: Yeah, under the addendum, under the likelihood relevant matters, there's three different relevant matters that are to do with compartmentation.So there's this one, disrepair to the fabric, compromising compartmentation. There's presence of services and service

ducts that is compromising compartmentation. And there's services not in fire resistant enclosure. So sometimes it can be difficult to decide exactly which one is.

Richard: So if we put, say for example, under presence of services and service ducts that's compromising compartmentation. Should we include like fire stopping in that?

Steffan: Yeah, I'd include things like where you have got pipes, cables passing through walls.

Richard: Okay, that's great.  So what issues do we see with compromising of  compartmentation for walls?

Paul: We did see a couple of penetration holes as well. That's the next one. Penetration, yeah. Which is added. So we did see that. the riser cupboards damaged the plasterboard. In fact you could easily push a pen through one leaf.

Richard:You could, yeah. We shoved our hands into that one.

Paul:  So there was no integrity and it needs to, yeah, a lot of them.

Richard: It's got to be at least 60 minutes those shots haven't it?

Paul: Depends on the risk, minimum 30.

Richard: Oh right.

Paul: So depends on the risk, if you could have a room that's...

Richard: It's like a water.

Paul: If it's water, there's nothing there. But yeah, so in the high risk areas, it was a

through floor to the riser cupboard as well. Yes.  So you've got to be careful of

Compartmentation getting around the enclosure of that.

Richard:  Yeah, sure. So the important thing is when you've got a shaft which isn't stopped at each floor level that you've got really good doors, really good shaft compartmentation.

Paul: Compartmentation, but I mean it's pointless.

Richard: Talking about the metsec that we saw in there, was there any issues with that?

Paul: There was metsec. Basically, obviously there's two ways of forming a stud wall. You've got timber and you've got Metsec.

Stefan: So Metsec, is that some kind of steel framing?

Paul: That's a steel frame, it's used in timber, it's quick and easy to erect. You can get it in different materials, in this case it was aluminium. And you need to look at the manufacturer's

details of how it is erected and how the plasterboard has to be attached to that.

Richard: Would that be on, say for example, Saint Gobain's website or...Obviously it turns out you can't publish the manufacturer here.

Paul: It could be Gyprock, what's called the white book.  It gives you different scenarios of part of the walls, stock walls with different layers of plasterboard and different frame materials.

Richard: I think I saw on the top floor also, when we opened up the doors, didn't we? Do you want to look at it? That was Metsec.

Jonathan: So open to the... Paul already said that there were suspended floors and there was a void underneath the floor, especially on the top floor that was open to the service shaft. So if there's a fire in the service shaft, it's reasonably foreseeable that that fire might get under the

floor of the top floor of the building. There's just one flat on the top floor, but we don't know if the void was open to the flat. In which case, it's worse in case, because we might get fire underneath the person in the flat, especially while they sleep. Yuck. Otherwise, it's just their exit route that's on fire, which is equally not great.

The other floors were not brilliant either. Where there was the void, they'd filled it with a length of timber. Which, you know, it's better than nothing. It's going to give something. It's going to char and give some protection. That's the ideal, but there was nothing at all on the top floor.

Richard: It seemed to be quite haphazardly just cut and tapped in. There wasn't necessarily one piece either, whilst sometimes there was an extra bit of shelf. Yeah. Okay, so we've got quite a few issues there, haven't we? Yeah, generally, from looking

through ceiling panels and stuff, it seemed pretty good above them. Did anyone else see any issues with that?

Paul: There was some tagging to some firestopping. So someone has, in the

past, gone round to record.

Richard: I think we saw mention in the risk assessment of a compartmentation survey, didn't we?

Steffan: That's right. The fire risk assessment refers to a compartmentation survey around about the same time, so January 2020. We didn't see that survey ourselves,

but the fire risk assessment does say there were several problems noted to the compartmentation. We saw a lot of...some work had been carried out on that. Fire bats, intumescent sealants that kind of thing. Hopefully, that's been carried out to sort out.

Richard: So the fire stopping is the second one, isn't it? Yeah, we always... The next one, the wandering in, I think.

Steffan: Yeah. It would be useful if it just had one compartmentation. They all have the same two parameters, which is inadequate compartmentation survey.

Richard: Let's discuss the disrepair to the fabric and compromising the compartmentation, removing fire stopping. I'm thinking it's about a two. It wasn't systematic problems. It was relatively localised. It tended to be between the fire shaft and the common part. Sorry, is that not the fire shaft, is it? It was mainly around the vertical shaft, the service shaft.

Steffan: Also around the smoke shaft. Yeah, that's true. And the smoke shaft too,

where we can see the floors. Yeah, you have the same problem with the floor. The smoke shaft. The floor might be open to the smoke shaft.

Richard: Okay, I'm going to put to the floor, it's either a two or a three.

Paul: With the smoke shaft and the smoke shaft being open to the void of the floor, it's not fire rated, I'd possibly say a three.

Richard: Okay. Okay, everyone happy with that? Yes. Three. So now we're going on to the

presence of services and service ducts, compromising compartmentation. So, as we mentioned just then, it looks like they've had a survey done and some works following the survey. That also gets debated correctly. good standard of fire stopping I thought.

Paul: Yes, we still got considered maybe penetrations through the cladding system as well.

Richard: That's true, yeah.

Paul: You've got boiler flues since the regulation 7, building amendment regulations, now boiler flues in high-rise buildings above 18 meters, got to be non combustible at the time. Flues to boilers did have a rating to them, wasn't A2, and then we do have plastic ducting.

Richard: Anything else to add to this? So, penetrations, we've got the fire stopping was generally okay.

Jonathan: Yeah. We might see fire batt in places, wasn't there?

Steffan: Yeah, the internal, some bits have been done, fire stopping was good.

Richard What didn't we see? Plant room No access, there was no access to those, yeah, so the half floor beneath the ground floor, wasn't it? So maybe we'll add a bit of a caveat to our

judgment on this, that we haven't seen it, there may be stuff that's, and we might just

ask local authorities to go back, whether they can get a key, have a look round, be

sensible, wouldn't it, and include something on the improvement notice or something.

Okay, moving on to the next one. Sorry, was that a one? Oh, we'll just call it a one.

Yeah, everyone happy with that?  Okay, so services not in fire-resistant

enclosures, so, no, they're not.

Jonathan: Most of the services were up that vertical shaft, the vertical service, riser, but there was the gas that didn't. Yes. That seemed to go up the inside face of the brick walls.

Richard: Okay.

Jonathan: The meters, if you remember, were all at the ground floor perimeter of the building on the outside.

Richard: How do we know what it goes up in? I'm just thinking. Did we see some sort of

gap in a board?

Jonathan:  Well, in the flat we went into, where they'd had a new boiler flue put in, new boiler and flue, there was a cutout section, square piece, maybe a little bigger than my laptop, and we could see into that, you could see the gas pipe in the back of that. I think there was a brick leaf, there was the insulation. On the outside, then? Then a cement board, and I think it

was inside the cement board face.

Steffan: It was. Yeah, you had the outer brick leaf, the cavity.

Richard: A picture tells a thousand words with this, doesn't it? So maybe we can refer to our film to overlay some pictures here, couldn't we?

Paul:  Yeah, for my point of view, obviously, we'd have found it. the gas safe installation use regulations. I didn't see any gas installation should be obviously in steel piping. I never saw any pipes.

Richard: Is that in between the road and the meter or where would you expect that?

Paul:  It technically should be going from the meter to the flats but I never saw any piping on the immediate.  It all seems to be copper.

Richard: What's the problem with copper?

Paul: Copper is prone to movement, damage, vandalism, solder joints.

Richard: Slightly complicated thing for us is that gas explosions is rated under a different hazard here isn't it? So it may pose a bit of a risk. It's essentially an explosion risk. What did we see at Grenfell?

Jonathan: Gas contributed massively to the ferocity of fire.

Steffan: So gas is relevant to explosions but it also has an effect on fire risk. You could rate it under both and Since doing a fire assessment.

Richard:  Anything else that we need to mention? Water damage to the enclosure.

Steffan: Did we have any concerns about the gas pipes? Because we've talked about them. We haven't said what our concerns are.

Richard: They're passing unseen in cavities aren't they? We normally see them in ventilated shafts.

Jonathan: On the plus side it means that the gas pipes aren't running through the residential area, through the common areas.

Richard: So are you allowed to have gas pipes in escape routes?

Paul: You can't have them in the firefighting stairs. Obviously in some cases they can be in a corridor. Also be protected in shaft and riser cupboards.

Richard: So that's the gas safe installation and use regs.

Paul: That's correct.

Richard: Okay well I'm going to propose that we go for a two.

Steffan: I agree.

Richard: Okay let's move on to the next one. Absence or inadequate record of dry

riser or wet riser if the building is over 50 meters which ours isn't and checking which should be every six months. So certification wise what did we see Steffan? Let me just check on the computer.

Jonathan: The basic test certificate gaps with information dated March. Does it say what year? That's right, we have the certificate dated March.

Richard: How can you have something dated March? Do that in March. Right, so. Okay. Yeah, so we can't say whether it's this year or not.

Richard: Okay, maybe we can ask them to provide a decent certificate. Maybe go back to the person who serviced it and confirm. Could you bring up the name, number on the certificate?

Jonathan: They might know when they did it. This is when we invoiced for it, but

it sounds like it was a year ago. Okay. Also, with the dry rising main. Disrepair? Not disrepair as such, but its location meant that if you had opened the door to the dry rising main and attached your delivery hose as a fire service and charged it, which makes the hose rock solid, you would not be able to open a residential corridor door.

It would conflict with it entirely. It might open about a little

Richard:  yes, so this is on each of the landings when they're poking out a wall, weren't they? Yeah. That's really close to the residential corridor door. North corridor.

Jonathan: It shouldn't be a problem. Typically, the fire service is going to start a floor, maybe two floors underneath the fire and go up to the fire. But then if they subsequently decide

they want to evacuate, they can't. At least they can't evacuate that floor that they're working from.

Richard: Yeah, so on the top floor, I think you saw some damage to the – there's quite a bit of ASB in the block, wasn't Yeah. Antisocial behaviour.

Jonathan: Yeah, the glass fronts were broken on a couple of them. In fact, it was missing on one of them. They smashed it.

Richard: That's right, yeah. There was a missing key, wasn't there, from the fire ledge. We'll come on to that in a bit.

Steffan: What kind of risk is related to having the doors to the dry riser that's smashed?

Jonathan: Our problem with the dry risers often, especially where there's antisocial

behaviour, is that people will tend to interfere with the valve assembly. Sometimes they'll take bits from them. Sometimes they'll just open it when it should be closed.

So when we try and charge the dry rising, water just spills out on every landing rather than come out where we want it. So it just delays getting to work and getting a decent firefighting jet operating. And it's not unusual for the fire service to send a firefighter to the top and come down and make sure that all the landing valves are shut. The other thing that can happen is that if they pull off the blank front, there's a rubber washer that sits in there that makes

sure we get a decent jet of water out of it. Little fingers tend to take those out

and swallow them and throw them away.

Richard: Okay, so I'm going to propose we score this as either a 3 or a 2. Thoughts?

Jonathan: We'd normally go one. it was just the certification

is worse than that. It is definitely worse than that.

All:  Probably about two. Two. I'll give it two.

Richard: Paul?

Paul: I'll give it two.

Richard: Let's move on. Non-fire resistant doors, damaged or badly maintained doors in or opening onto column parts. Paul, do you want to start off quickly with what we saw?

Paul: Yes, we do have a firefighting stairs which have FD30 doors attached.

Richard: FD30? In between protecting the...that sounds a little bit under.

Paul: Yes, so in this situation you'd be expecting FD60 doors with obviously the associated fixture fittings.

Richard: Where are we measuring the risk? Where's the risk in this? Why would we need FD60s? What are we taking into account with that?

Paul: So it's a requirement under obviously the building regulations at the time of building.

Richard: Yes, but so in terms of the risk  is in the flats mostly here.That's where we're going to be calculating from, isn't it?

Jonathan: It's a stay put strategy and with the stay put strategy that as I mentioned earlier, the key piece is that we want people to be able to evacuate if they feel threatened by a fire. In all other cases it's probably safer to stay put, but if your doors are giving up too early in the fire, you're going to get smoke ingress into the staircase and now nobody's able to use that safely. So there's a reason there and also for the safety of firefighters to make sure that staircase is adequately protected is really important. Is there anything you want to add to that?

Paul: No, so you're also looking at the sort of time from the fire to the fire brigade actually entering the building as well. There was, adding to that, there was damage to the doors, certain doors which had glazing replaced which never had any markings on them. Right, yeah, we didn’t see any etching.

Steffan: Going back to the fire resistance of the staircase doors, would I be right in saying they need to be FD60 because there's a requirement under the building regulations for 90 minute protection between the flat and the staircase? Is that the reason we're specifying 60? So it'd be like a 30 minute flat door and a 60 minute staircase door giving 90 minutes?

Paul: Generally yes, the guidance for what is a firefighting shaft or firefighting stairs gives specifically a rating to the door. That's the same for flat entrance doors as well, it has to require a standard rating of an FD30.

Jonathan: So to get up 60 and 30 generally means 90 minutes. That rating changes with the height of the building as you get higher and higher and you increase the fire resistance

that's associated with it.  So it's not universally 90.

Richard: Is it in appendix to it or is it in the book?

Paul: There is guidance in Table A2 on Approved Document Part B. It gives you situations where shafts also should have special locations where you need to have fire doors. Sure. And the ratings to be able to.

Richard: Okay, so in terms of disrepair, I saw quite a bit that were pretty poorly formed doors. There were some that had had additional strips added to them where we're not really sure if they're going to be particularly great at functioning as a fire door under fire conditions. What else did we see?

Steffan: Excessive gaps. So even though they'd added these strips, they were still kind of gaps.

Poorly done, wasn't it?

Jonathan: Saw some UPVC door handles on some of the doors. We saw doors that didn't close at all. We saw one of the staircase doors that had a broken self-closer.

Richard: I think I saw some hinges with one screw per hinge. Saw a screw per hinge.

There were loads of screws missing around. It wasn't good, was it?

Jonathan: Oh, we saw the spy holes missing in two doors and dropping out of one.

Richard; One door looked to flat, looked like it had been attempted to be levered open by some ne'er-do-well.

Paul: It's also worth mentioning there was also a special requirement For duplex flats inside blocks. In this case, we had two doors leading out of the duplex flats on each level.

Richard: Yeah, we saw quite a low headroom there, didn't we?

Paul: There was a low headroom to the second door.

Richard: And it chopped. So the actual door itself, they'd actually chopped straight across the corner of one.

Paul: Oh, so the door was compromised, yes. Normally you'd be looking at what

testing has been taken with these doors.

Richard: Okay, I'm going to stop us there and just say that's a pretty clear three for me.

Yeah, I agree.

Very similar to what the worked example scored as well. Okay, so back on to our next relevant matter. We've got the waste hoppers, so non-fire-resistant waste hoppers.We haven't got any in our building, not saw any, did we? We had external bins, people

took them out themselves. So, score that as a zero, let's move on. Sources of fuel, rubbish or other flammable material, whether external or internal. So, what are we really

referring to here, Steffan? Any skips full of waste outside near the building?

Steffan: In this block, we did have some, there was an understairs cupboard.

Yeah, that's right. With paint and some of the combustibles stored there.

I think there were also...

Richard: Any ignition source in there as well?

Steffan: There were ignition sources, a lot of electrics in there.

Richard: Yeah, I think the main feed cable was in there.

Steffan: We also had Some combustibles stored in the service shaft.

Richard: Yes. I think we also had, obviously in that, we mentioned it in the smoke control thing, we actually had combustibles lining some parts of that second smoke shaft, didn't we? It's probably covered elsewhere, so we probably wouldn't rate that, would we?

The combustibles we saw

stored in service shafts.

Richard: We saw that bike exercise site, didn't we? Struggled to set fire to that, didn't we?

Not really covered elsewhere.

Jonathan: Not that much of an obstruction really, still a metre clear width, three flats.

Steffan: he thing is, the HHSRS is concerned with defects to elements of a building.

I don't think you could include... It's questionable whether or not they should be in there.

Richard: There possibly are some things that...Unless it's inherent to where

the bins were stored or something like pushed up against the...

Jonathan: If you think of the buckets, right, in the service shaft, they are there as a result of the leaking roof, probably. But the buckets aren't part of the building, so...

I don't know. I find this area really cramped.

Steffan: Some problems possibly clutching at straws.

Jonathan: Okay, that's fine.

Richard: How much of the...It's any building feature that allows that to take place, really, isn't it? So if you had a bin complex like we saw in the north of the country, where it was positioned outside, underneath an undercroft, then you might want to say something about that here, I'm going to guess. Although it could also be fire starting arson.

Steffan: Just not counting it twice, really, isn't it? Or if you had problems with people dumping rubbish, because there wasn't anywhere else for them to keep it, because that would be down to a problem with the building itself. But it's just people's behaviour. There's nothing really with the building I'm going to suggest.

Richard: There was a bit of stuff around the building.

Jonathan: There were some combustibles, but they were totally moveable and management issues.

Richard: Okay, I'm going to just propose zero. I find nothing really. Okay, moving on. Inadequate waste storage. Again, we've just talked about waste storage. There's a few that overlap.

Jonathan: But this waste storage wasn't part of the building, was it? It's far away.

Paul: The refuge was by the vehicle access, wasn't it?

Steffan: It was external.

Richard: Could they have pushed? I don't know, this probably comes

underneath arson, but perhaps you could push a paladin against, turn it over.

It's coming onto us. But realistically the external skin is brick so it's not going to go straight into the building is it? It's not really an option is it? Okay so I'm going to score that a zero. So moving on to the next one which is opportunities for external intentional fire starting arson. So external intentional. So what have we got Jon?

Jonathan: I'll start with the fact that the site itself then wasn't that secure.

Richard: No it wasn't, no.

Jonathan: There was a gate to the car park at the rear. There was a lock around the gate post

but the gate was open and it looked like it probably remained open. So there was ready access to the site. You've already said that there's opportunity maybe for paladins close to the building so that's a thing. And there was evidence of fires having been started in the undergrowth. There were scorched leaves and plants. So it's foreseeable I think as a risk.

Richard: But there was also a pathway around the outside wasn't there?

Jonathan: And of course you've got the gas meters around the outside so if someone  decides to set a fire in a gas meter. Try and pinch the copper. I've seen that before.

Richard: Okay so we've got some issues there. Quite bad. Worse than average?

Jonathan: Worse than average?

Richard: Two.

Steffan: Yeah I'd agree with that.

Richard: Great stuff. Okay moving on to the next one. External unintentional fire starting. So a car fire pushed up against the wall system.

Jonathan: There was one car parking space up about close to the building. All the others were quite far away. And that was the one space that was still a bit of a distance away and it was against a brick predominantly. But we did see those barbecues on balconies so there's potential there. The light fittings is mostly about balconies I think. Or a passing train on the

line that burst into flame.

Richard: Yeah come on let’s not be silly. Okay I'm going to call that as a one, too concerned.

No, not pushing back. The balconies themselves weren't ideally suited for barbecues. We did see one on there but that's probably a very hardened barbecuer isn't it? We didn't see a multitude of them around there and they were in quite tight spaces weren't they? So I would think most people wouldn't really want to barbecue on there.

Jonathan: Yeah most people probably want a disposable one. Yeah but even worse.

Richard: And we do see sometimes scorch marks.

Steffan: So there's potential for them to be used as barbecues if they really need to.

Richard:

If they were really intent on doing it. We'll consider over the next 12 months maybe.

Jonathan: I'm happy with the one, I'm not pushing back.

Richard: Lack of controlled access or other security measures to the building allowing unauthorised access or parts of? Jon, you mentioned this previously didn't you?

Jonathan: There was a rear exit door that was not secured in any way, it was not lockable and anybody could wander in off the street and get access to the building. I remember looking at the actual solid jammed screw into it.

Richard: Ok, so that's a pretty, and we've got ASB in the area.Once you're in you had

access to the whole building.

Jonathan: There's no floor locks. No other security measures in there. The entrance lobby had a bin in it and a notice board.

Richard: here was a couple of fire shaft doors that weren’t locked as well wasn't there? The one that was taped together. Yes. You didn't mention that earlier but

yeah, there's weaknesses isn't there?

Jonathan: I managed to lock it.

Richard: Oh, well that's good. Ok, I'm going to propose...

Jonathan: I think with the arson outside and the insecure building that it appears to mean that there was an arsonist somewhere in the area. I'd go above 1.

Richard: 2? 2?

Steffan: Maybe 3. You could even push it up to a 3 because anybody can just walk in off the street  and get straight into the building, into the staircase and all of those.

All: Yeah, yeah.

Richard: 3? Ok, 3. Change that to 3. Right, lightning protection system. Did we see anything when you got onto the roof?

Jonathan: I saw something round the perimeter. I saw a earthling run points round the perimeter.

Richard: It seemed to be going down the cavity.

Jonathan: I think maybe they were. A metal buzz bar or whatever you call it. I don't think we've seen any certificates relating to the safety of the lightning protection system. What would we expect? I can't remember the acronym for it.  Atlas?

Richard: Atlas. Atlas, that's one of them I think. There's possibly others as well. There's a lightning association. But we haven't seen anything associated with it. Ok. So if we've got nothing obviously wrong. Normally go with a 1. Go with a 1. Yeah. Let's move on. Issues with building design. Means of escape, lobbies, increased fire loading, common parts.

Jonathan: There's no firefighting lift. It's part of the design. It's just a regular passenger lift.

Richard: Yeah. Although there was a key next

to it saying that it was...

Jonathan:  No there wasn't. There was a key box.

Richard: There was a key box. So key for firefighting lift. The key box was empty. The key box was empty and it wasn't a firefighting lift. So yeah, that's pretty bad. So why would that be a risk?

Jonathan: It's about the ability of the fire service to get their equipment to the upper floors, which just makes for a speedier rescue. So they don’t run out of breath.

Paul: It might be in the basement, but did anybody see any secondary supplies?

No. Didn't see any, no. No.

Richard: So why would you have a secondary supply?

Paul: So if there was a fault with the primary supply. Power cut.  Power cut, disconnection, damage.  Well, it would be for a firefighting lift and emergency lighting. It could be for life

safety systems such as AOVs.

Richard: You'd probably see two large diameter pipes going into it.

Paul: Well, you'd normally see a transfer box, but also the secondary supplies can obviously be generators as well.

Richard: Yeah.  I've seen a few of those. Okay, I'm going to say no

firefighting lift over 18 metres. It is a requirement, isn't it? I'm going to put this down as a three. I'd probably go, I'd accept a two, but I, yeah.

Jonathan In terms of the design, would this be an appropriate place to put the failure of the smoke shaft to extend above the roof line?  As long as you're not double counting it,

because we've counted that already. But it feels like a better place to put it because all the smoke stuff we've spoken about already feels like it's about means of escape and people. Yeah, so this is a building design piece, where it doesn't come higher.

Richard: Yeah, we could move it down from the upper section of the report.

Jonathan: For me, I would make it a three.

Richard: Okay, let's go with three then. Okay, electrical fire hazards, installation

meters, fuses, wiring and sockets, etc. So we saw some water ingress near

electrical switches and wiring.  Saw some damp electrical switches. We saw some damp on the sockets, on the fire smoke shaft controls. Anything else?

Steffan: The electrical certificates, they identified deficiencies in the system.

Richard: Not good. Okay, I'm going to propose a three to this. Three.

It's a real day long, isn't it?  Nailed on.  Okay, moving onwards. Complexity of the building. It wasn't complex. I don't think I even need to ask you this.

Jonathan: No, it's a complex roof layout. It's complex to describe, but in itself,

in its layout, not complex at all.

Steffan: I agree. And any complexity doesn't have an effect on fire risk in this block.

Jonathan: Yeah. Safety of residents.

Richard: When might we rate this as a three?

Steffan: Well, not three, but things that you might want to include in this is if there's commercial premises beneath, if it's got three-story basement, yeah underground car park, yeah, anything that's in addition to your usual residential yeah premises.

Richard: Okay moving on to our final one which is site-specific issues in flats that are not identified above, so sort of ignition sources, things like that in flats.

Paul:  I mean there are gas hobs and gas ovens.

Richard:  I think it was electric but I agree on gas hobs, yeah what did you see in yours?

Steffan: It could be a gas hob, I didn't have a look at the oven but I think it was gas hobs, yeah it seemed to be,



Richard: when I asked the tenant she said it was an electric oven, gas hob

Steffan: I think it was probably a higher fire risk associated with gas hobs than with electric Hobs. Site-specific issues with common parts not identified above, no particular fire issues noted no real issues,



Richard: okay so that sort of concludes the first part of this and now we're going to move on to the harm outcomes so here we are now considering our relevant matters for the harm outcomes so we've got the two tabs at the bottom here, so likelihood and harm outcomes, so we've basically set up our spreadsheet so that it pastes the answers that we gave and the

evidence that we had for the relevant matter for likelihood onto the harm outcomes so

there's not really much point in me wasting your time when this is actually pasted in

from the other, so I'm going to quickly go through this so we've got a score of

a 2, a 2, a 0, a 0 these are exact pastes from the other part of it so what we've

actually done is actually highlighted just in this box here the relevant matters that

we do need to actually detail which are slightly different from the likelihoods

so if I then sit down back down so the first one that we're going to consider

is the single route of escape to a place of safety or issues with the availability

of alternative escape routes, Jon do you want to talk about the single escape route?

Jonathan: Well there was just the one escape stair, accessing escape stair and firefighting stair once you got to the foot of the staircase there was a front door right in front of you and there was a rear exit through that back residential corridor that's the one that was unlocked and available to anyone. So anybody descending from the upper floors, I think without question, would go through the front door. If there was a problem in the staircase

enclosed, then anybody living in the back corridor could easily go out the back exit. Everybody else would have to pass through the staircase.

Richard: Presume they could also jump over their balconies, worst comes to the worst. Yeah. Pass the kids over.

Jonathan:  Anybody else from the upper floors would have to come down through that staircase in every respect.

Richard:  So what sort of risks does that pose to our harm outcomes? So our harm outcomes is it's sort of preloaded into the actual spreadsheet, isn't it? So when we do our calculation, is

it likely to increase the risk of death, for example, if we've only got one way out of the building?

Jonathan: Yeah, if that way out of the building is compromised with smoke or with fire, or there's a heat layer at some point and somebody has to pass through, absolutely they might not get out of there. So yeah, I think it contributes and that's why the safety of the staircase is so important and why on our likelihood, we were talking about 60 minute fire doors to protect the staircase. It's all a part of making sure that anybody who wants to descend it can do so in safety.

Richard: So thinking around this issue in terms of if we had a, say, a two or three storey basement with a fire down there, they would definitely have to pass through that heat layer, wouldn't they?  That smoke layer.  So that might be something to call it a three. We've only got one escape route, so I'm kind of happy with a two here rather than a three.

Steffan: Possibly a three if you didn't have a two direction escape at ground floor level.

Yeah, because we're going through one door. But still, the single

staircase, it doesn't mean...

Jonathan: It wasn't a terribly high building.

Richard: It wasn't, no.  We've only got sort of a ground floor.

Jonathan: It's only just over the threshold to the exit.

Steffan: But having a single staircase, it still increases the risk of people having to escape through smoke from that.

Richard: That's right. Yeah. That two's about right. That two's about right, yeah. So the next one is narrow route escape to places of safety. So I think we measured this, didn't we? Because we thought it was slightly encroached into the building regulations.

Jonathan: It was a touch narrow for a firefighting staircase. So you might think the fire service, and they do have to get lots of equipment up to the different floor plates, and they

should be able to use the firefighting lift.  But if the fire is on first or second

floor, they'll operate from the ground. And taking that equipment up the

staircase, it had a couple of pinch points that just narrowed it down by 10

centimetres, which doesn't sound a lot, but it might be enough for them not to

get certain pieces of equipment or to struggle a little bit getting up there. Yeah, but in terms of resident safety. Not all that much. The only issue, if it's particularly narrow

because the fire service is going to lead its hose up the staircase, it will snake

up there and it can make it more hazardous for people coming down if they want to.

Richard: If you had a particularly tight corner then where you had to get it round, very limited width, could you get kinking in those?

Jonathan: Yeah you could. The hose will tend to snake. It's not a straight line and it's

very difficult to lead it up the staircase in a straight fashion. It can cause some problems but it's later in an operational incident.

Richard: Okay so it's more narrow than building regulations by 10 centimetres. What is the actual building regulation? 110. 110. So it's a metre wide. If it was a simultaneous evacuation

policy there, so this isn't our building but if it was, and you've got a child

and a parent, width wise is that wide enough for them both to walk down?

Jonathan: I would assess it's probably wide enough for the number of people we had in that building even if you wanted to walk side by side with an infant. More of an issue if you've

got really tall buildings. The taller it is the worse it gets. The higher the number of

people the worse it gets.

Richard: So we've reached this is a 1? I think I agree with that. It's only just under the requirements. Moving on to the next one then. Obstructions to the route of escape

such as mobility scooters, prams, pushchairs, the presence of which may

indicate a lack of storage within flats. It's just the exercise bike.  It's not one exercise bike.

It's temporary there. I think it was rubbish.

Seffan: It was more there because somebody decidedto throw it out rather than they haven’t got enough room.

Richard: Flats weren’t too bad sized actually really. So I've scored that as a 0.

I fully agree on that. The next one in yellow is absence of or disrepair to emergency lighting. So this is the first time we've mentioned emergency lighting isn't it?

Jonathan: It is yes. I guess I suppose because the harms would increase if you can't see to find your way out.

You're going to linger in those affected areas for longer. The emergency lighting was fine. There was a good provision of emergency lighting throughout the premises including outside exit doors which was spot on. We tested it. I think on the third floor there was a little test point.  I got my fish key out and tested it and it was fine on that floor. So we've still got the issues with the damp but the emergency lighting worked when tested. So I don't know if you would see that get worse over the next 12 months or I don't know how you want to view that. But I thought it was okay.

Richard: So localised issues with subluminaries. Is this what we're talking about with

not seeing a charge light or something? I don't know.

Steffan: I think it was possibly plastic to one of the subluminaries, it was a bit opaque.

Yeah, kind of.  But I don't think it was too wet. Not so much that it was wet, it

was actually, okay, fair enough.

Richard: So we've seen the test certificate and it says it is okay. So we're going to score that as a zero.  And then down to lack of suitable access to the building for firefighters. So Jon, you can tell us a bit more about this than I.

Jonathan: I think it happens a lot, in particular in London areas, where there are real constraints to the site. And things get difficult for getting vehicle access to a building.  But there really wasn't much vehicle access to this one. There was the front elevation,

that was fine, the main road runs past it, no issues with that. But if you wanted to get to the side or to the rear, you really weren't going to get an appliance around.

Richard: You'd probably have to shoot your jet of water from the front and back really, aren't you?

Jonathan: It's on foot and it's making  the best of a bad job really. Maybe working from ladders, confining pitches, things like that.

Steffan: There was a car park at the side. There was. I think the access gate was narrow

for fire service access, wasn't it?

Richard: We measured 2.7 metres, I think, wasn't it?  And we need 3.1. So 40 centimetres is probably going to stop any fire from getting down.  Even chopping off the gate post, I

think we're going to struggle in there. So we scored that as a 2, I think.

Steffan: Because I think there should have been at least 50% vehicle access and it was probably around 25%.

Richard: Moving on to the next one, inadequate external lighting. No issue, pretty adequate. I think we saw it during the day but sometimes it's difficult to tell. We saw enough luminaries

around the car park, etc. Lights around every exit door, streetlights, things like that. So we scored that as a zero. Inadequate signage on what to do in case of fire and routes of escape. Now, over to you.

Jonathan: Not really. There were a couple of fire  action notices in place. There's one on the top floor, which only served one flat in any case. But it told people in a state-cut environment

that they should raise the alarm using the nearest call point, that they should

go to the assembly point and report to the manager of the assembly point. Well, there wasn't an assembly point, there was no manager and there were no call points. So, pretty inaccurate fire action notice. There was a second version of that notice, haphazardly adhered to a smoke control door, I think on floor two, which is kind of a jaunty angle and just, I don't know, it looked like somebody had slapped it on there. And then there was a third notice on

an A4 printed piece of paper attached to the notice board, wasn't there? And that one was a proper stay put policy fire action notice. So I suppose the majority of people

would see that one, it's ground floor, it's where they pick up the mail. And fewer people would see the top one, but it was confused through the whole building and just it wasn't

clear and there were some inaccuracies.

Richard: Okay, I'm going to suggest we put a two for that. Okay, a two. Confusing. Almost does exactly what it shouldn't do. Confuses people. I mean, you could put three for that. How bad can it be before you,



Jonathan:  I suppose it contradicts the actual stay put. An example where you have a stay put and there's a simultaneous alarm in place. I think that gets really confusing.

Steffan; In this one, at least they're not going to get a false signal. That is something we come across sometimes. It's like somebody's just gone ahead and stuck out a new notice. Totally conflicts with what the actual policy should be.

Richard: Okay, let's move on. I'm going to put a two down for that. Inadequate distance between the building and external place of safety.  That was adequate as far as I was concerned.  Do you want to talk a little bit about that?

Jonathan: They've got a bus depot immediately opposite the front of the building. So you could literally come out of the building and catch a bus. It's ideal. So no issues with that.

My only issue would have been if the access gate was ever locked. So you have the padlock around the gate post. If that gets locked at night, for example, and people were to use the rear exit, they could find themselves trapped in the car park and unable to escape. But then I think they could get around the building to the front, couldn't they, from the other side. So not really an issue for me.

Richard: Okay, site-specific issues. We scored that as a zero, by the way. So site-specific issue not identified above. So we mentioned water damage, didn't we? Yeah, we've already discussed that. We've discussed that already. Exactly. So we've got water damage that

could affect the smoke ventilation system over the next 12 months. We saw some slight drips

down the front of the wing. It looked like it dried up. Okay, that concludes this section.

Steffan: Okay, so now we're going to score the hazard of fire for the building. The first thing we need to do isdecide what age is this building.

So we've got 2005, I should think.

Jonathan: 2005.

Richard: I think that was our planning, we've checked the planning system didn't we?

Steffan: Yes, so first thing we need to consider is what kind of dwelling it is. The age of the dwelling, posted in 1979.

Yeah, agreed. And so that brings up the averages for that kind of building.

Richard: So the national average on the left hand side there is 1800, that's the mid-scale point isn't it?

Steffan: Yeah, one in 1800. So we need to consider that, how our building

compares with that, and try and decide on the likelihood of harm for this building.

Richard: Likelihood of harm, yeah.

Steffan: Yeah, likelihood of harm and then we have to consider the spread of harm.

Richard: Okay, yeah.  So, how much worse than an average building is this?

Steffan: It's quite a bit worse. It should be called post-1979. We've also got a worked example to help us decide what the likelihood is, so we need to consider that as well. In the worked example, I think the likelihood was one in 180. On that block, I think it was

completely clad in Category 3 ACM. There were quite a few other

deficiencies on the block as well.

 Richard: From memory it had fire doors with letter boxes in, that weren't intumescent letter boxes.

Steffan: That's right, so we've got defective fire doors to all flats.

Oh, we've got that. Our doors don't close and we've got various issues with that. I think they had problems with bin chutes opening into the staircase or the corridor, and possibly there was a problem with the doors to the bin chutes. Like that.

Richard: We've got a lot of ASB into the property, haven't we? I mean that's something that is an issue. We've got evidence of arson. We've got kids probably playing with,

who knows what on the common parts.

Steffan: The worked example of it, the block was a lot taller and again single staircase.

Jonathan: Yeah, ours wasn't that tall and it wasn't covered in ACM.

Richard: No, so how much of an issue is the external wall system? I guess it's one of the most

important relevant matters for us.

Jonathan: It's got panels on it, burny  stuff, but the burny stuff is in kind of quite discreet locations. So even if you set fire to it, it's really not going to spread around the building. And it's difficult to envisage (a) how effective. fire might get into it in the first place,

and, if it does get into the cladding system, it's very difficult to see how

that will subsequently affect people,  certainly in the early stages of the fire. If you allow the fire to develop uninhibited and fire service don't turn up for 40 minutes, then maybe there are some issues. But assuming things work reasonably as they should, it's very difficult to see  how the presence of the cladding in this particular case is a hazard in itself.

Richard: So I think that we've got a lot of lower level issues, slightly, I mean the fire doors are a big issue. So there's a lot of lower level issues, more issues than there is in the worked example. If I can just point towards our worked example is 1 in 180 here isn't it?

Steffan: Yeah, and another big difference, possibly the biggest difference, the worked example is totally clad in category 3 ACM you could easily get, you know there's

windows everywhere, so you could easily get a flat fire getting into that

cladding and spreading it on the block.But we're not so concerned with

the external walls for this fire.  

Richard: So I'm kind of thinking there, but then we've got a lot of things at lower level. So I'm kind of thinking we're moving more towards about 320.

Steffan: It's definitely not as bad as the worked example, so lower than 180.

Richard: We certainly haven't got anything up here have we? There's nothing to indicate we need to be.

Steffan: It's still quite a bit worse than the national average. So yeah, 1 in 320 sounds about right.

Richard: 1 in 320, I'm happy with 320.  So if we can just move that downwards then. So our harm outcomes, which are these, so this is 1, 2, 3 and 4. This is sort of 100 minus these three.

 So what do we know about this building? So it's been pre-loaded, taking into

account the typical injury from a building of this age, is that right?

Steffan: This age and this type of dwelling, so post-1979 flat.

Richard: So the national average is 4.6 for a Class 1, so it tends to be death or  disablement, that sort of thing isn't it? Class 1. So it tends to be death doesn't it?

Steffan:  That's right. Most of the things we've just discussed about the likelihood, they're just as applicable to the harm outcomes. So it definitely needs to be...

Richard: It's definitely up from the national average. Are you happy with that?

Steffan: Yeah, but again not as bad as the worked example. The worked example for Class 1 arms is 21.5.

Richard: So, it's not as bad as that is it?

Jonathan: No, this is not as bad as the average of an entire ACM-clad building. That fire is breaking into every window, every flat. It does that at night while people sleep. It's dreadful. I think the worst case for our stay put policy is that you might affect one floor of people, but it's not spreading up the building or around the building. So, it's sort of one corridor, so

maybe three flats at most might be affected by a single fire. Not many more. So, still a bit worse than your average? Your average, I would argue, should

be a single flat is affected. Maybe it bounces up the building into the  next one, but that should be a minor kind of fire compared to the burnouts underneath. So, we're a little worse

than that I would suggest.

Steffan: So, worse than the national average. Not as bad as the worked example.

So, you'd say we're in the middle?

Steffan: Yeah, we should move up to 10 I think.

Richard: So, class 2 is rather interesting isn't it?

Because this tends to represent quite serious burn injuries which  might be permanently disfiguring. You can imagine what a severe burn is like. It's quite nasty. And it's interesting that the stats for when they actually generated it are as low as they are because it's effectively

saying there's no chance of serious burn.

Steffan: Yeah, in your average flats of this age, national average is zero. Which is interesting.

Which is quite strange.

Richard: Very interesting. So, I think there's a fair chance.

Jonathan: I think that's because most people are going to be asphyxiated by the smoke long before they become burned.

Richard: Exactly. I 'm not sure that the stats take into account people who are found in common parts rather than just flat. Because if you're in the flat

at the source of the fire, you tend to either die or get out.

Yeah.  It's an interesting  statistical anomaly I think. But back on to how we'd score it.

Steffan: Yeah, in this block I say it's going to be worse than the national average, class 2 burn.

Richard: Yeah. How far up would you go?

Steffan: I think the working example gives 0.5 for a class 2 burn. So, again, not as bad as the working example. Possibly a 2

Richard: Yeah. It's good. And then class 3, what sort of injuries have we got with class 3?

Steffan: Smoke inhalation. Smoke inhalation? Less serious burns.

Richard: Yeah, it's probably like an arm burn rather than your entire body, which would be class 2.

Entire body would get it. Yeah, it would tend to be long term. Right, so national average is 21.5.

Steffan: Yeah, so again, same reason again. I think the... It would be worse than the national average.

Jonathan: Worse than the national average. It's only worse than the work example. It would be better than the work example.

Steffan: Better than the worked example. Worse than the national average. Worse than the national average. Better than the work example.



Richard: Okay, so 31.6 or?

Steffan: 31.6 I'd say.

 

Richard: Okay, and that should auto-populate the class 4 harms, which is a hospital trip for maybe mild smoke inhalation where it's discharged quite quickly. So that, if we move downwards, gives us a hazard rating of Band E. How does that sort of compare against other buildings that you'd expect to see stuff happen? You think that's about right?

Steffan: Yeah, thinking about previous blocks where we've scored it, it does seem that our feeling about the level of risk in this block is round about right, I think.

Richard: What did the work example do?

Steffan: That was band C, it's about 1,200 or 1,300. So not that bad. I mean, not as bad as the work example, but quite a bit worse than the national average. I've got the average like you, I'm not quite sure what that is, but it won't be as bad as it would be.

Richard:  Okay, we're now just going to talk through how we've come to an overall total of 345. So, for a class 1 harm, the weighting that is reprogrammed into the HHSRS is 10,000.

We're going to multiply that by the chosen likelihood, which we have chosen to be 1 in 320. That's then multiplied by 10, which is class of harm, which we've chosen. for our class 1. So all that maths together  gives us a total of 312.5. For class 2 harms the weighting is 1000

multiplied by 1 over 320 so that's an obviously fraction multiply that by our 0.2

which gives us 0.63 so there's not an awful lot of increase in the score because of that.

Then we've got class 3 harms so the weighting that's included in the HHSRS is 300. We multiply that by 1 over 320 fraction. We then multiply that by 31.6 which is

what we've chosen for class 3 which gives us 29.63 and the remnants of the 100 minus

those three gives us 58.2 so we multiply 10 which is the weighting for class 4 harms

multiply that by 1 over 320 and then multiply that by 58.2 gives us a total of 1.82. We then sum that which gives us 345 which if we compare that in the operating guidance to the hazard bands gives us an E which is a category 2 hazard so any future enforcement action if we were to serve an improvement notice for example would be under section 12 of the Housing Act so that's the importance of why it's a category 2 hazard.

Okay, thanks for your time today gentlemen and hopefully we'll move on and do some rigorous enforcement on this building.