Chief Fire and Rescue Officer

Written submission from the Glass and Glazing Federation (CFRA 02)

 The Glass and Glazing Federation (GGF)’s Fire-Resistant Glazing Group (FRGG) is committed to the development and advancement of best practice in the manufacture, testing, specification, application and installation of fire-resistant glazed systems. The FRGG’s goal is to achieve the optimum fire protection in the UK’s built environment given the importance of glass in today’s buildings, the vulnerability of standard glass products to fire exposure and the uncertainties of fire.

As such, in response to the Communities and Local Government Committee’s call for evidence, the FRGG has a number of key issues and questions to put to the Minister and Chief Fire and Rescue Adviser, as outlined below.

Fire-resistant glazing is a passive fire protection (PFP) product. Such products do not need any special actioning or signal to operate in the case of a fire. PFP measures are long-lasting and require little, if any, maintenance, providing excellent protection for both lives and property in the event of fire. Such measures should be naturally built into the structure so that they are an inherent part of the building itself. In that respect they are vitally important in securing the basic resilience of a building against fire.

Concerns over "Value Engineering"

The cost of testing fire-resistant glass and glazing systems is a significant but necessary investment in helping to ensure that installed glazed systems are fit for their intended purpose, i.e. to prevent fire spreading rapidly, protect occupants along safe escape routes and provide safe firefighter access. Such fire-resistant glazed systems are specifically developed by world class glass companies to function effectively in challenging fire conditions, based on specific technologies, rigorous furnace fire testing and extensive R&D, and are manufactured under specific technical control processes.

However, in an increasing number of cases the GGF is aware that specifically developed fire-resistant glazed systems are being "engineered out" by Fire Safety Engineers (FSEs), who are often intentionally substituting these systems with less tested or untested alternatives, based on unwarranted assumptions concerning the sensitivity of standard glass products in fire.

The FRGG believes that FSEs are not sufficiently challenged to justify and validate such measures, applied as they are under the ill-defined blanket term "risk-based judgment." The response from the control authorities in such cases before sign off should be straightforward: "Please show us the applicable system test report."

The FRGG, as the UK’s glazing industry centre of expertise for glass and fire, is customarily not consulted in such cases, and believes that the practice of fire safety engineering must be more transparent, exposed to peer review and constructive input from other stakeholders in the fire safety sector who have the applicable fire safety and product expertise and experience, as well as those under the provisions of the Fire Safety Order, 2005, who may carry personal responsibility when the building is occupied.

Question: Does the Minister/ Chief Fire and Rescue Adviser agree that fire protection systems used in the building fabric to contain fire should have their fitness for purpose put to the test according to applicable and appropriate standards?

Question: Would the Minister/ Chief Fire and Rescue Adviser support action to make the application of fire safety engineering more transparent in individual projects, open to peer review and constructive input from other stakeholders in the fire safety sector who have core interests in advancing fire safety practice and who are able to contribute through their specialist particular knowledge?

Compliance with established practice

The Lakanal House fire tragedy demonstrates the potentially severe consequences of complacency in placing materials without a properly evaluated fire performance in buildings where they are at risk of significant fire exposure (the composite panels beneath the bedroom window glazing were a major material cause of rapid fire spread from one flat to another).

The fire environment is a hostile one for all materials; and the occurrence and development of fire is unpredictable and subject to chance. It is therefore critical that the specification, selection, and installation of fire-resistant glazed systems are all carried out with close attention to detail. It is also vital that these steps are correctly enforced at all points along the supply chain, including traceability of the individual glazing products and confirmation that they are made to a suitable and appropriate precise property specification. There should be no short cuts concerning fire safety provisions.

However, there is no overarching body to check competency and as a result each part of the work stream (from design through specification, approval and purchase to supply and installation), essentially has to be self-regulating and dependent on the individual duty of care of the professionals involved in the extended chain.

Question: Does the Minister/ Chief Fire and Rescue Adviser think that there is sufficient and adequate compliance with current fire safety regulatory guidance and legislation?

Question: What action is the Minister/ Chief Fire and Rescue Adviser considering to ensure that each part of the work stream from design through specification, approval and purchase to supply and installation has the necessary competencies, and that appropriate checks are in place to ensure proficiency in the exercising of those competencies?

The importance of test evidence

Applicable guidance in Approved Document B (AD B) requires that the material, product or structure as installed should be in accordance with an applicable design or specification that has been shown by test to be capable of meeting the desired and claimed performance.

AD B requires that the performance in terms of fire resistance for elements of structure, doors and other constructions be determined by reference to either British or European tests. That requirement is rigorously met by fire-resistant glazed systems provided by members of the FRGG under Best Practice Guidance introduced and endorsed by the FRGG.

This is not the case, however, for substitute systems that are being increasingly introduced by FSEs, which are not validated by equivalent standard test methods. In effect those who own and occupy buildings, as well as approval authorities who may be asked to take on fire safety responsibilities, are being asked to take fire performance on trust.

Question: Does the Minister/ Chief Fire and Rescue Adviser think that testing requirements as outlined in Approved Document B should include substitute systems increasingly introduced by fire safety engineers so that all glazed systems intended to provide functional fire resistance containment, of whatever type, have an applicable test report for the element as installed attesting to its performance?

FRGG Principles

The FRGG has developed a five point code of core governing principles for all glass and glazing system products that have the stated purpose safety in case of fire, as follows:

· The glazed element - as designed and specified to be installed, including named components - must be tested as an applicable system, under scrutiny by a notified test body according to approved common test standards to establish level of performance.

· The system as installed must faithfully follow the relevant approval, based on either test or assessment referred to applicable and suitable test evidence, carried out by an accredited notified body.

· The main components (e.g. glass, frame and sealants) of the glazed system must be produced to a defined individual product specification including the key individual product control properties, confirmed by the manufacturer.

· The manufacturer must be able to demonstrate that they operate the appropriate production quality control system to consistently meet that defined specification, and that they exercise appropriate care as the responsible manufacturer.

· The scope of application of the proposed glazed system must be backed up by properly constituted independent third party certification schemes attesting to product consistency, including the necessary provision for independent product auditing, if necessary.

The FRGG believe that whilst industry is capable of policing itself, there does need to be government and industry support for adherence to these principles in order for this guidance to be sufficiently recognised and respected at large within the design, construction and risk assessment sectors outside the glass and glazing sector. We are therefore seeking your support for, and endorsement of, these principles.

PFP measures, including fire-resistant glazing, are vital in ensuring the UK has a safe building stock which is able to mitigate threats to life and minimise damage to property and businesses in the event of a fire. The effects of fire safety engineering and a lack of enforcement are problems which could have a significant impact on the safety of our buildings, however with support for these principles from industry and government the FRGG believes that we can help to create a safe and stable built environment.

Question: Would the Minister/ Chief Fire and Rescue Adviser commend and endorse the FRGG core principles?

Question: Would the Minister/ Chief Fire and Rescue Adviser support industry initiatives which recommend best practice for the encouragement of higher levels of competency, duty of care, and awareness of responsibilities for professionals along the design, specification, installation chain?

April 2013