Meeting the challenge of legislation by working together
HEVAC president Mike Nankivell considers the regulations relating to fire and smoke dampers, and considers how the challenges of meeting legislation on their use and maintenance are best met through cooperation between manufacturers, installers and end-users.
Fire dampers are one of those pieces of building services equipment that remain hidden from sight, but which must not be forgotten in spite of that. There are many reasons for regular checks on fire and smoke dampers, not least of these is having the confidence that they will work in the event of a fire and help to save lives and prevent property damage.
Fire dampers are one of the most important elements of passive fire protection in a building. Passive fire protection is built into the structure of a building. It limits the spread of fire and smoke by holding them in a single area. This in turn protects the building structure as well as keeping escape routes clear.
Because fire and smoke dampers play such an important role in non-dwellings, they are subject to a number of standards and regulations. It is vital for designers, installers and building owners to understand their obligations under these rules since non-compliance carries serious consequences.
Part B of the Building Regulations offers guidance on design standards for fire safety. There are also a number of documents that offer assistance and standards for design and installation including BS9999, which covers maintenance of ventilation and air conditioning ductwork. These documents cover key issues such as fire assessment and risk profile, means of escape and fire safety management.
BS9999 also requires that fire dampers should be tested by a competent person at regular intervals (which should be less than two years apart). This should be more frequent for dampers in areas where the risk of fire is greater.
Other relevant standards include those for testing of fire dampers. A joint guidance document produced by the HVCA (now B&ES) Ductwork Group and HEVAC advises that all fire dampers should be tested according to BS EN 1366-2 and classified according to BS EN 13501-3. The main reason for these recommendations is to ensure that dampers are only installed that have been tested in site conditions. This is to show how they will perform in different types of walls or ceilings, and under different pressures through the ventilation system.
The rules for fire dampers and smoke control dampers are slightly different, and installers need to be aware of this.
• Subject to UK regulations.
• Installation methods must be tested to EN standards.
• If installation methods are tested to BS476, they cannot be used to protect escape routes or areas with sleeping risk.
• Assess the installation site and ensure that there is space to use a tested installation method.
• Assessment after the installation has been carried out is very difficult.
Smoke control dampers
• Not specifically covered in UK regulations.
• Should be used with fire engineering to allow the realisation of smoke and heat extract.
• The duct becomes part of the fire compartment.
• Use of spring-return actuators is not permitted as failure in either direction can block the extract path, dilute fans or allow fire into another compartment.
While installers have to be aware of regulations on testing, building owners and managers need to ensure they comply with the Regulatory Reform Fire Safety Order (RRO) 2005. The RRO was introduced to draw together a range of legislation, which had often been developed in response to particularly tragic fires, into one document, to aid compliance and help businesses.
The RRO requires that a ‘responsible person’ takes ‘reasonably practical’ precautions that will ensure the safety of employees and others on the premises. These precautions include risk assessments and also maintenance. This second point is one that has a significant impact on fire dampers. The RRO requires that the premises and fire safety equipment are maintained efficiently and are in good working order.
The meaning of ‘responsible person’ is important. It encompasses the employer in a workplace, if that workplace ‘is to any extent under his control’. If this is not the case then the responsible person is the owner of the premises or the person who has control of the premises while carrying on a business there. Under the RRO, the responsible person can appoint ‘competent persons’ to help carry out work to meet the requirements of the RRO. It is the responsible person’s job to ensure that this team works together effectively.
Even if fire safety itself were not enough of an incentive to comply with RRO, there is also a fine of up to £10,000 for non-compliance; and the responsible person can face two years in prison. The local fire officer can also close down a premise if they are not assured that the rules have been followed.
Fire safety information
Building Regulation 38 is an important piece of legislation that also relies on the ‘responsible person’ concept and so is particularly relevant for installers and building owners or managers. Regulation 38 applies to new buildings and refurbishment projects. The person carrying out the work must give fire safety information to the responsible person on completion of the work or on occupation of the building.
This information should cover anything relating to the design and construction of the building (or extension) and any services, fittings or equipment which will help the responsible person meet their obligations on fire safety.
So, although fire and smoke dampers often remain out of site, they are some of the most important safety elements in a building. Regulations and guidance on these products are complex, and adherence is a challenge. However, HEVAC believes that by working together, manufacturers, installers and end-users can share information to ensure that buildings and the people in them continue to be safe from the hazards of fire and smoke.