Inner bedrooms in Social Housing – a disaster waiting to happen!

Introduction

Ranch-style layouts are common in much rented accommodation, including social housing, but can throw up some difficult issues for fire safety. These kinds of layouts feature few interior walls and combine several areas so that, in the case of a fire, escape from bedrooms is often through the living/dining/kitchen area. This is clearly against the guidance under two pieces of major legislation introduced in 2004-5, specifically the Housing Act 2004 and the Regulatory Reform (Fire Safety) Order 2005. The legislation introduced new responsibilities for landlords and housing organisations. Sometimes confusing or apparently in conflict, the meaning of these laws has since been clarified by a document known as the LACoRS guide, published by the Local Government Association and endorsed by the Under Secretaries of State for both Housing and Fire Safety, and the Chief Fire Officers’ Association. A key aspect of the new legislation is to ensure that rented properties have adequate fire escape routes and fire safety in general, and the LACoRS guide lays out how this may be achieved.

Some key facts:

·         Although the LACoRS guide itself does not have legal force, it is now regarded as the standard interpretation manual for the new legislation.

·         Unlike changes to building regulations, the new legislation applies retrospectively to all rented properties.

·         Properties that don’t meet the new standards may remain in use only where it is “not reasonably practicable” for the landlord to remedy the problem.

·         Landlords found to be in violation of the new laws can be imprisoned or face an unlimited fine.

Inner Bedrooms – What’s the Problem?

The LACoRS guide defines an inner room as a room where the only escape route is through another “access” room; such rooms pose a risk to the occupier if a fire starts unnoticed in the access room.

Figure 1: Example social housing property layout featuring an inner bedroom

Figure 1 shows a social housing property layout featuring an inner bedroom, based on a real example. Inner bedrooms are particularly dangerous as an inhabitant may be deeply asleep and perhaps also intoxicated when a fire starts in the outer room. A closed bedroom door is a mixed blessing – although it may hold back smoke for a time, it also reduces the sound level of any alarm sounding in the outer room. Slow to rouse, the sleeper may awaken to discover a major fire and thick smoke on the exit route.

Section 12.2 of the LACoRS guide makes it quite clear that inner bedrooms and even living rooms “should be avoided wherever possible” above first floor level:

[Inner rooms] should be avoided wherever possible. However, where unavoidable it may be accepted where the inner room is a kitchen, laundry or utility room, a dressing room, bathroom, WC or shower room.

Where the inner room is any other type of habitable room (for example a living room, sleeping room, workroom or study) it should only be accepted if:

·         the inner room has access to a suitable door opening onto an alternative safe route of escape, or it is situated on a floor which is not more than 4.5m above ground level and has an escape window leading directly to a place of ultimate safety [and]

·         an adequate automatic fire detection and warning system is in place; and

·         a fire-resisting door of an appropriate standard is fitted between the inner and outer rooms (typically FD30S standard for non-high-risk outer rooms).

What can be done?

Provision of automatic fire suppression is allowable as a compensatory feature against such layout shortcomings. The LACoRS guide states:

… provision of a suitable water suppression system can, in some circumstances, allow for relaxed provision of certain other fire safety measures [such as] relaxed requirements for inner rooms.

A fire suppression device aims to control and suppress fires, significantly reducing the risk of injury, loss of life and property damage by maintaining tenable conditions for as long as possible while occupants evacuate. This is achieved in several ways:

·       

·         Reduction of smoke and toxic gases. Water mist devices achieve this by the production of copious amounts of inert steam in the immediate vicinity of the fire, locally excluding oxygen, reducing temperatures and thus slowing the oxidation reactions of the fire.

·         Flashover prevention. By constraining room temperatures to around 100°C or less, flashover (the rapid ignition of combustible items in the room) is prevented.

·         Providing cooling to structural elements of the home that are in the spray path, allowing them to resist the fire for longer.

In the immediate years following the introduction of the new legislation, the cost of retrofitting sprinklers to properties with dangerous layouts was absolutely prohibitive. Not only would housing associations face huge installation costs; disruption to families would also be enormous. It was therefore straightforward to argue that there was no reasonably practicable solution available to address poor layout. But this is no longer the case..

Retrofittable fire protection

Several innovative water suppression devices have now emerged onto the market, each designed to provide affordable, effective, retrofittable fire protection within the frameworks both of the new legislation and building regulations.  Automist from Plumis is one such solution and is the first active fire protection system that combines low cost and ease of retrofit with excellent aesthetics. Intended as a more practical and affordable alternative to sprinklers, Automist uses a high pressure pump to generate a fine water mist from nozzles mounted under a kitchen monobloc  tap, on a work surface or in a wall. In an extensive BRE test programme, Automist was found to render a lethal environment survivable.  An Automist unit installed in an open plan living area greatly improves the safety of users of inner rooms off that space. Versions are available for protecting living rooms, kitchens, and open or semi-open kitchen/diners.

In the event of a fire, the system is triggered automatically by a heat alarm or a fire panel output.  The use of heat detection, already the standard in kitchens, effectively eliminates nuisance activation. Unlike conventional sprinklers, Automist can be stopped manually by pressing a button on its control panel. As Automist uses much less water than a traditional sprinkler system, water damage in the event of activation is minimised. Where desired, manual activation can also be provided through a manual call point.

Once triggered, a pump drives mains water through the unique nozzle unit, quickly filling the room volume with a dense fog. Water mist removes heat and displaces oxygen from the fire zone, resulting in fire control, suppression or extinguishment. The intention is to lower the temperature and the accumulation of toxic gases, thereby reducing damage and increasing survivability.

Automist is safe to use in kitchen areas. Adding water to a cooking oil fire can greatly exacerbate the fire; the same is not true for water mist, as the up-draught from the flame and the evaporation of the tiny droplets prevents water from reaching and collecting in the pan.

Fitness for Purpose and Fire Engineering Principles

Fire protection must be ‘fit for purpose’. PD7974 (Application of fire safety engineering principles to the design of buildings) allows design flexibility through a careful analysis of where the fire risks are, how fire and smoke will spread, and how passive and active fire protection and detection/alarm systems will function in a given layout. PD7974 highlights the most important aspects that must be considered in this “fitness for purpose” assessment; the most relevant for residential settings are listed below:

a.      What are the fire characteristics of the area to be protected?

In an inner bedroom there is more fire risk than in a room with ready access to the outside.

b.      What are the objectives of protecting the area?

To suppress the fire so that it does not spread and flash-over, so that heat and smoke output is limited and occupants can safely escape.

c.      What impact will the environment have on the suppression system and vice-versa?

Electrical fires can result in power loss to suppression systems that plug into a mains socket.  Some suppression systems can be very aesthetically obtrusive to domestic environments, independent of the risk or coverage.

d.      Is there a likely conflict with processes within the protected environment?

As with all domestic suppression systems, an alarm should indicate the presence of fire and should not hinder in any way the means of escape.

e.      What is the impact of a false discharge?

Traditional sprinklers can output over 100 litres per minute whereas alternatives can be effective in a fire scenario with much less water damage.  The robustness to false alarms is very important; water mist suppression systems are much more reliable than smoke alarms in this regard because they are heat triggered.

Conclusion

Landlords and housing officials who fail to address these inner bedroom and living room configurations risk prosecution, unlimited fines and even prison sentences.

The legislation requires the responsible person including the landlord, occupier or sometimes a combination of the two, to carry out a fire safety risk assessment and implement appropriate fire precautionary and protection measures and to maintain a fire management plan.

Breaching fire safety regulations can have serious consequences. Two property landlords in Haringey, Greater London, were sentenced to six months’ imprisonment and ordered to pay £5,000 costs each because a fire in their property had revealed inadequate fire safety measures. A case in Suffolk resulted in a prison sentence and a fine of £204,000 in 2008 for failing to ensure that a hotel met vital fire safety standards. The ground floor function room had been sub-divided into three bedrooms and the conversion was arranged so that one bedroom could only be reached by going through another room. In the event of a fire in the outer room, anyone in the inner bedroom could be trapped without an escape route. 

Cases such as these highlight the importance of recent developments in water mist fire suppression systems such as Plumis’s Automist, which offer a viable and cost-effective solution to problem layouts with inner bedrooms and living spaces. Individuals and organisations with a duty of care should give active consideration to these systems. The previous defence that no viable solution exists is no longer sustainable: there is no excuse for not taking adequate precautions!

Retrofittable fire suppression solutions are now available at affordable prices without compromising layout or aesthetics and with minimal disruption. With such solutions available, housing groups and local authorities who continue to permit these layouts without adequate fire safety measures do so at their peril.