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It has been a year since the third phase of the Disabilities Discrimination Act was introduced. Bob Choppen, product manager at Fulleon, guides us through a complex regulatory landscape and questions whether the fire industry is coping.
So many questions and so few answers – a situation that is commonly faced when new legislation is introduced.
October 2005 sees the first anniversary of the introduction of the latest phase of the Disabilities Discrimination Act, which requires that service providers make reasonable adjustments to their premises to overcome barriers to access. In reality, the legislation is about much more than just access issues, as it covers a wide range of situations for both the general public and employees too.
The definition of a disability is “a physical or mental impairment that has a substantial and long-term adverse effect on the ability to carry out normal, day-to-day activities”. As well as obvious disabilities, the legislation is intended to cover hidden disabilities, such as severe cases of dyslexia, epilepsy and some progressive conditions, for example, cancer and multiple sclerosis.
The DDA also affects employers and the rights of the disabled to equal employment opportunities. However the legislation is also about being reasonable and, as a result, it is therefore open to varying interpretations. To back up the legislation, the government has created the Disabilities Rights Commission (DRC) to offer advice and also police the implementation of the Act. There can be few who would argue against the intentions of the DDA – providing it is applied with reasonable and even handed judgement.
How does this influence fire detection and alarm systems? The areas the industry needs to consider are those where fire detection and alarm systems interact with people. This means the Act may have an effect on the initiation of an alarm (via manual call points) and will affect the way in which an alarm is communicated.
The two main documents that deal with the legislation and buildings are Approved Document M of the Building Regulations (ADM); and BS 8300: 2001: Design of buildings and their approaches to meet the needs of disabled people. Both documents are firmly focused on provisions for access, the width of doors to allow for wheelchairs and so on. Although making only brief mention of requirements for fire systems, it does cover the following:
– visual alarms in sleeping accommodation, sanitary accommodation and kitchens;
– fire doors, particularly those in corridors, are held open with electro-magnetic devices but close when activated by a smoke detector system;
– for the hearing impaired, consideration should be given to using flashing beacons and vibrating devices. Care should be taken with beacons not to cause confusion or disorientation for those susceptible to epileptic fits.
Apart from the above, for any further guidance we have to resort to fire alarm industry’s trusted staple: BS5839-1 2002: Fire detection and alarm systems for buildings Part 1: Code of practice for design, installation, commissioning and maintenance, although it must be noted that this document is not cross-referenced by either BS 8300: 2001 or ADM.
Manual call points are dealt with in section 20 of BS 5839-1, where allowances in mounting height and location are dealt with. Section 18 specifically deals with “fire alarm warnings alarms for people with impaired hearing”, while section 17 covers the use of “visual-alarm signals”.
Visual alarm devices are not the only alarm devices that may be employed according to the standard; it also allows tactile alarms, whether moveable or portable. Portable devices are those that may be carried on the person and can use radio, induction loop or infrared technology. They should, however, be considered as a supplement to the primary alarm sounders as a means of giving an alarm.
The use of sounders is well documented by BS5839-1, so by following its recommendations a workable system is achievable. If, however, we begin to look at other types of alarm, then the lack of good information is soon evident and the chances of everybody having a consistent view is poor.
Information Deficit
Considering the content of the DDA was known well in advance of the implementation of its third part, it is perhaps surprising that the fire detection industry finds itself in exactly the same position it did 12 months ago, which is many opinions and not too much in the way of hard facts.
This is not to say there has been inactivity or lack of interest. Quite the contrary, a great deal of effort has been expended trying to assess the impact of the legislation on all aspects of the industry. Part of the problem lies in trying to get to the root of what was intended when the various documents were compiled.
As visual alarms seem to be causing a great deal of discussion, it is worth using them as an illustration of the situations that face the system designer.
They are needed in specific areas, according to BS 8300:2001 and ADM, but is it reasonable to apply this advice to all such areas of a large hotel? And would it apply to a small guesthouse, where it might be reasonable for the proprietors to visit individual rooms to assist disabled guests during an emergency?
A large hotel may have 300 rooms but regardless of its financial resources, equipping all rooms with visual alarms would be a considerable commitment. Instead, it may be deemed reasonable that, for example, 10 per cent of the rooms were specifically allocated to disabled guests. This type of solution poses other questions, such as: at what point does the hotel start allocating disabled rooms to able-bodied guests, or what happens if the disabled quota is exceeded? Are other special arrangements required?
The next question (assuming the extent of coverage in the premises is agreed) is how to apply the visual alarms in a specific environment? This leads to a chain of questions for which there are no definitive answers.
Firstly, how bright does the beacon need to be? Does it have to wake a sleeping person, or is it to reinforce the normal alarm sounders? Almost certainly, different light outputs will be required in each type of area.
If a required light output could be agreed, then other characteristics of the beacon also need to be determined. If an area requires a beacon with, for example, a rating of 15Cd, at what position should the 15Cd be placed and what variation is allowed at other positions around the beacon? Once these characteristics are set, the next problem is how many beacons to use in a particular room? Like alarm sounders, light levels diminish the further away someone is from the source. But unlike sounders – which can be heard even if out of sight – light does not travel around corners. This, of course, makes positioning critical. If the room is large, will one very bright beacon equate to two of lower output? Further considerations may also be needed to minimise the possible effects of beacons on photosensitive epileptics.
For the installer and commissioning engineer, who need to sign off the system as complying to prescribed standards, how do they verify that the light output in a certain location meets the required level? For alarm sounders, a sound level meter of a given specification can be used. However, there is no equivalent equipment to measure the fast flash produced by a xenon beacon, which is then converted to an equivalent brightness perceived by a human observer.
Questions such as those highlighted above need to be resolved quickly, but there is a distinct lack of background information on which opinion can be based. The only viable source appears to be work performed in the USA to support the Americans with Disabilities Act (ADA), which has similar aims to the DDA. But does the UK simply adopt American practice wholesale, which would be the quickest and easiest option, or take a more considered view that cherry picks parts of the American experience with a view to verifying a more comprehensive set of data with local UK funded research?
Answers will take time to formulate; the extent of coverage, for example, will have to be agreed with a number of organisations that it will effect. This will certainly include Building Control, the Fire Brigades, the DRC, the ODPM as the legislators, and the BFPSA as representative of the fire alarm industry. Manufacturers will be required to produce compliant designs but before that can happen, there must be a standard against which the product can be assessed. EN54-23 Fire detection and fire alarm systems Part 23: fire alarm devices – visual alarms is in preparation, but still lacks the vital information that would make it fit for DDA use. The difficulties in checking the performance of installed beacons will probably be addressed by rating beacons into performance bands, so that the spacing and light output in a particular space can be calculated from tables, in a similar manner to that used for products in the US.
The American information is now mature, but is still being refined. It does, however, seem to offer a secure and proven way to help satisfy UK requirements.
But American alarms systems are different in architecture to those in the UK. Wholesale adoption of their practices would have a massive impact on systems, due to the extra power that would be needed to service the xenon beacons that are specified under their legislation.
Although this all relates to visual signals, there are parallel considerations for other devices, like vibrating pagers, that also have the added complications of the security of the radio link, battery life and levels of vibration that should be produced.
As the DDA is effectively retrospective, people installing systems now which are later shown to be sub-standard, could be faced with the possibility of replacing or further upgrading facilities at potentially considerable cost. So it is vital that clarification of requirements is published, or at least agreed, as soon as possible.
While this period of confusion exists, reputable companies will aim to provide systems they believe are compliant, but may subsequently be shown to be lacking. There will also be those who exploit the situation by deliberately providing unsuitable equipment that will later have to be replaced. Until we have coherent guidance, there will not be the level playing field most would desire, and it is possible that vulnerable groups will be indirectly exploited by a whole gamut of opportunists.