The Fire Services Act of 1981(2003) recognises the establishment of Fire Authorities/Planning Authorities. However it does not prescribe that these authorities are subject to a higher authority, it certainly facilities it will or may be in the future, to date this has not happened. Fire Authorities/Planning Authorities have autonomy; they act as individual power basses, and are subject only to the Health & Safety Authority when a fatality occurs (Lower Dargle Road in Bray, in September 2007). Where a pick and mix approach is allowed, how can an integrated system exist, in my opinion the claim of compliance is misleading. Where a guidance (TGD B 2006) allows a limited trade off one fire protection measure against another within a limited framework beyond to which the level is greater to a standard of fire safety engineering to be allowed it is to be applauded, and one would expect this guidance would should be straight forward to use, but were this same flexibility allows alternative interpretations, it will certainly facilitate an educated debate and an informed decision, however if it also allows a sinister use of this inbuilt flexibility to support a use of revoked standard and guidelines. In my opinion by accepting these revoked standard and guidelines the Fire Authorities/Planning Authorities are complicit in this action. The abusers of this flexibility will claim compliance in unison, and it has become a mantra, �We Are Compliant�. In support of my opinion I refer to where the TGD B 2006 includes a reference to a technical specification the reference is to the latest edition current at the time of the publication of TGD B. However, if that version of the technical specification is subsequently revised or updated by the issuing body, the new version �may� be used as a source of guidance provided that it continues to address the relevant requirements of the Building Regulations. For the record in your statement above you state, �It is also open to designers to use alternative approaches, premised on the use of fire safety engineering principles, to meet fire safety requirements provided compliance with the requirements of the Building Regulations can be demonstrated.� You are unwittingly accepting that designers can use the standards quoted in TGD that have been superseded and revoked, and this has been happening by designers stating that �may� allows them that choice. I suggest you go back to the civil servant who provided your response and ask a direct question - Are designers using revoked standards and guidelines in there submissions for Fire Certificates, and are the Planning Departments accepting these submissions with the revoked standard listed as the standards they will be meeting, and on that basis granting the Fire Certificates. The answer is simply a YES or NO. This practice is dangerous and puts lives at risk, it is unacceptable and that flexibility must be revisited and amended as a prescriptive guide. To claim full compliance will mean full compliance, including compliance with current standards and guidelines.
Paddy McDonnell
Posted on 13 Mar 2012 7:49 pm
The Fire Services Act of 1981(2003) recognises the establishment of Fire Authorities/Planning Authorities. However it does not prescribe that these authorities are subject to a higher authority, it certainly facilities it will or may be in the future, to date this has not happened. Fire Authorities/Planning Authorities have autonomy; they act as individual power basses, and are subject only to the Health & Safety Authority when a fatality occurs (Lower Dargle Road in Bray, in September 2007). Where a pick and mix approach is allowed, how can an integrated system exist, in my opinion the claim of compliance is misleading. Where a guidance (TGD B 2006) allows a limited trade off one fire protection measure against another within a limited framework beyond to which the level is greater to a standard of fire safety engineering to be allowed it is to be applauded, and one would expect this guidance would should be straight forward to use, but were this same flexibility allows alternative interpretations, it will certainly facilitate an educated debate and an informed decision, however if it also allows a sinister use of this inbuilt flexibility to support a use of revoked standard and guidelines. In my opinion by accepting these revoked standard and guidelines the Fire Authorities/Planning Authorities are complicit in this action. The abusers of this flexibility will claim compliance in unison, and it has become a mantra, �We Are Compliant�. In support of my opinion I refer to where the TGD B 2006 includes a reference to a technical specification the reference is to the latest edition current at the time of the publication of TGD B. However, if that version of the technical specification is subsequently revised or updated by the issuing body, the new version �may� be used as a source of guidance provided that it continues to address the relevant requirements of the Building Regulations. For the record in your statement above you state, �It is also open to designers to use alternative approaches, premised on the use of fire safety engineering principles, to meet fire safety requirements provided compliance with the requirements of the Building Regulations can be demonstrated.� You are unwittingly accepting that designers can use the standards quoted in TGD that have been superseded and revoked, and this has been happening by designers stating that �may� allows them that choice. I suggest you go back to the civil servant who provided your response and ask a direct question - Are designers using revoked standards and guidelines in there submissions for Fire Certificates, and are the Planning Departments accepting these submissions with the revoked standard listed as the standards they will be meeting, and on that basis granting the Fire Certificates. The answer is simply a YES or NO. This practice is dangerous and puts lives at risk, it is unacceptable and that flexibility must be revisited and amended as a prescriptive guide. To claim full compliance will mean full compliance, including compliance with current standards and guidelines.