Water Bill

Written evidence submitted by the Council and members of the British Automatic Fire Sprinkler Association (WB 28)

Consultation on the Draft Flood and Water Management Bill

Proposed amendment to Section 57 of the Water Industry Act 1991

I am writing to you on behalf of the Council and members of the British Automatic Fire Sprinkler Association (BAFSA), and in response to your call for written evidence regarding the Water Bill.

BAFSA is the UK’s trade association for the fire sprinkler industry and has been in existence for almost forty years. Our members come from a wide variety of related industries and professions including: manufacturers, installers, insurers, designers, local authorities and fire & rescue services. Importantly, BAFSA is a member of the Water Liaison Group.

The Water Liaison Group’s purpose is to try and resolve the ongoing issues and difficulties arising from a need for the economic and effective installation of automatic fire sprinkler systems. The Group is made up of bodies representing the fire sprinkler industry, the UK National and European Fire Sprinkler Networks, Fire & Rescue Authorities, Scottish Building Standards, CLG, Defra Drinking Water Inspectorate, Water UK and water companies.

BAFSA supports the work of the Water Liaison Group and would like you to consider a proposal to make changes to the Water Industry Act (WIA) (1991) under section 4.4 of the consultation on Draft Floods and Water Management Bill consultation process.

Specifically, we would suggest that a proposed change to Section 57 on the provision of water for firefighting is necessary so as to recognise the growing interest for automatic fire sprinkler protection and consequently reduce the delays and conflict regularly experienced by BAFSA installer members on behalf of clients ( home owners etc) , when liaising with water company officials.

Unfortunately, the problems that arise can often delay construction or occupation of a building, increase costs incurred by contractors and property owners alike and can give rise to a negative image of sprinkler systems – particularly in the domestic and social housing area where such fire protection is being installed because of risks to vulnerable persons and the increasing dangers of fire in modern homes (e.g. timber framed construction) .

Section 57 covers the duty to provide water for firefighting and currently this duty could be interpreted as limited solely to providing water from designated fire hydrants. Increasingly householders are seeing the benefit of installing sprinkler systems, which will lead to significant reductions in fire deaths and injuries if they could be more widely used. Under the current legislation, such supplies to such systems are classified as non-domestic supplies and are subject to agreement of terms and conditions on a case by case basis.

An amendment of section 57 to include as firefighting water that taken from service pipes connected to a sprinkler system, will clarify the status of connections to the water system for automatic fire sprinkler purposes. The current ambiguity is a barrier to the wider use of sprinkler systems.

Finally, we believe that this simple change is vital to ensure that legislators who are introducing more requirements for automatic fire sprinklers systems, such as the Welsh Government, do not, as a consequence of their legislation, face unnecessary criticism and complaints because of an ill prepared water industry.

If BAFSA can be of any further assistance on this matter, please do not hesitate to contact me.

December 2013

Prepared 18th December 2013