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Recent legislation and regulations in the UK leads the trend from prescriptive solutions to those based on risk assessment. Keith Minster guides us through the current landscape in respect of fire detection and alarm systems, with reference to the British Standard code of practice, safety directives and product standards.
Introduced back in october 2006, the Regulatory Reform (Fire Safety) Order (RRFSO) was designed to address a number of shortcomings in earlier regulations relating to fire protection. Previous legislation was fragmented, inconsistent and in many cases difficult to understand. By contrast, in replacing two major overlapping pieces of legislation in particular – the Fire Precautions Act 1971 and Fire Precautions (Workplace) Regulations 1997 – as well as amending or superseding a further 118 fragmented pieces of legislation, the RRFSO provides an integrated regime of fire safety legislation for all commercial buildings.
At the same time, the RRFSO reflects two further critical shifts of emphasis in maintaining a consistent high level of protection of people and property. First, by adopting a risk assessment approach to fire safety, it recognised that the strongly prescriptive nature of the earlier regulatory regime was stifling innovation. Secondly, in moving away from a restrictive certification approach, there has been a shift in responsibility for ensuring that buildings meet the necessary compliance criteria under the new regulations. The RRFSO introduced the concept of the ‘responsible person’ – typically the employer, site manager or the owner of the building – who has a duty to undertake a full risk assessment and maintain fire precautions, in order to comply with the regulations.
This has a number of consequences. The nominated ‘responsible person’ is unlikely to be a fire safety expert and so will have to engage suitable specialists and take appropriate advice, in order to take the necessary preventative steps to ensure compliance with both EU and local regulations and standards. And increasingly in line with a broader shift in fire safety legislation manufacturers and their products, together with specifiers, installers and maintainers, will have to be third party accredited in order for the responsible persons to be able to show that they have taken the appropriate action. For its part, freed from the time consuming responsibility for visiting each new site to issue fire safety certificates, the local fire and rescue service can now concentrate its efforts on prevention – through education and the promotion of fire safety – in addition to enforcing the new legislation.
So what are the key areas of national and Europe-wide legislation which now impact on fire safety, and what demands do they put on those involved in the end-to-end provision of detection and alarm equipment?
Systems approach
First introduced in the UK more than 50 years ago, BS 5839-1 is the Code of Practice for system design, manufacture, installation, commissioning and maintenance. Over time it has developed to keep pace with contemporary custom, practice and technology and reflects how today’s fire alarm contracts work.
In line with legislation, the most recent update to the standard in 2002 is once again less prescriptive and more ‘user-friendly’ in its application. Similarly, it adopts a risk assessment approach in defining the level of protection required in each case and incorporates definitions for each of the roles within the process, including the responsible person, designer, installer and user.
BS 5839-1 identifies three categories of fire alarm system – Category M for manual only, Category L for protection of life and Category P for protection of property – and within these addresses specific areas such as corridors and stairways and high risk areas within a building. Many buildings will require a combined system: in the case of a warehouse for example, the main storage facility will require property protection with a manual or life protection system for the adjoining office area.
Having defined the relevant category, BS 5839-1 then provides a set of standardised best practice guidelines for each level and type of risk. This may include, for example, the spacing between detectors, sound output for sounders and where manual call points should be mounted, as well as detailed information as to how the detection and alarm system should be put together, how to minimise false alarms and even appropriate evacuation strategies. The standard refers to the latest fire protection technologies – including multi-sensor, carbon monoxide and video detection – and its less prescriptive approach is typified by the acceptance of ‘variation’ in applying the rules rather than the previous avoidance of ‘deviations’.
Product perspective
As the national installation standard in the UK, BS 5839-1 requires that all components comply with the relevant European standard, in this case, EN 54. This covers all aspects of fire protection equipment – including control and indication equipment (Part 2), audible fire alarm devices (Part 3), power supply equipment (Part 4) and visual alarm devices (Part 23). EN 54 is highly adaptable as it was developed to meet diverse approaches to fire protection systems across Europe. And, as part of this more flexible approach, EN 54 is still evolving to define new devices.
Individual standards are currently undergoing harmonisation across the EU and, once completed, every member state will work to these common rules and local rules will become obsolete. In particular, the control equipment standard (Part 2) was due to be harmonised across Europe in January. However, this has already been in place in the UK and major manufacturers’ equipment is typically built to meet EN 54 standards.
The value of EN 54 in providing a common set of standards for fire protection components is not, however, restricted to Europe. It has been adopted as the basis for an international standard by ISO (7240 Series) and is widely accepted by fire authorities across the globe, including those in Africa, the Middle East, Far East and Russia.
The overall purpose of such Directives is to provide a common harmonised approach to fire safety for the EC and EFTA, by preventing fire hazards, electric shocks and reducing EMC pollution. At the same time, in stating the legal objectives which must be met, they are designed to enable free passage of goods between member states. In short, the CE mark showing compliance with the applicable directive acts as a technical passport for any product throughout the EC, without having to clear any further local approval hurdles.
As all aspects of fire safety equipment become harmonised under EN 54, so they will become subject to the constraints of the Construction Products Directive (CPD). The scope of the directive covers all products which form part of a new building, so include components of fire detection and alarm systems and fixed fire suppression systems, but not products that are not fixed, such as portable fire extinguishers.
In the case of earlier regulations affecting fire safety equipment, such as the Low Voltage Directive (LVD), manufacturers have been able to achieve compliance through a process of self-certification, by undertaking a level of due diligence testing appropriate to their share of the market. The CPD, by contrast, requires manufacturers to go a step further, by having their products independently certified to EN 54 and ISO 9000 by a Notified Body (such the LPCB in the UK). A transition period is allowed for this to take place but at the present time the UK, Ireland and Sweden have opted out, as they have a large number of smaller manufacturers facing the high cost of achieving third party approval. Yet at the same time, the Fire Industry Association (FIA) in the UK strongly recommends certification and VdS, the national approvals agency in Germany, has imposed especially stringent local certification requirements.
It seems likely that that those countries opting out at the present time will come into line in the foreseeable future. And companies like Honeywell – supplying its Notifier and Morley-IAS products to the international market – have already ensured their products meet the tougher demands of the German market in order to ensure total acceptance throughout Europe.
Spirit of the law
In the case of the RoHS directive, aimed at removing hazardous substances from electrical products and components, the regulation would not, strictly speaking, appear to apply to fire alarm systems as they are fixed installations. Yet in complying with the spirit of the regulation, major manufacturers are moving toward RoHS compliance by eliminating lead from all components.
Similarly in the case of the WEEE directive, which seeks to regulate the responsible recycling and disposal of electrical and electronic products at the end of their useful life, it is still unclear as to how the regulation will operate with regard to fire safety equipment. However, in marking products appropriately as required by the directive, once again work is underway at an individual company and trade body level to ensure that, throughout the supply chain, companies meet their broader environmental obligations throughout the life of their products and beyond.
Finally, the industry is currently undergoing a transition period with regard to the Electromagnetic Compatibility (EMC) directive, which is due to come into force on 20 July 2009. The directive, which encompasses all fixed installations, requires the responsible person to ensure the compatibility of the complete fire alarm system with other on-site electrical equipment, such as telephony and computer systems, rather than on a component by component basis. This will require back-up technical documentation to support compliance, including evidence that the installer has adopted best practice with regard to cabling, bonding techniques and the use of CE marked equipment.
As elsewhere therefore, non-specialist ‘responsible persons’ must seek specialist advice to fulfil their obligations under the new regulations. A stronger emphasis is now placed on the use of high quality products and services, as increasingly end users must be able to show they have used third party accredited installers with independently approved fire safety products.
In taking expert advice from a fire safety provider, the rules generally are not onerous, nor do they typically involve the building owner or employer in additional expense. The procedures to ensure compliance may have been tightened, but in many cases these relates to actions which the responsible person should already have been taking under earlier legislation, most notably the Fire Precautions (Workplace) Regulations. In short, if the risk assessment is undertaken properly with the right people involved, the process of securing compliance should be relatively straightforward in low risk premises.
Keith Minster is sales manager UK & Ireland, at Morley-IAS by Honeywell