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Amendments to the Approved Document B

Proposals to reduce the trigger height for sprinklers provision in new high-rise blocks of flats in England.

Objectives of the consultation

In December 2018 the Government issued a call for evidence on the technical review of Approved Document B of the Building Regulations, seeking views to help set the agenda, terms of reference and programme for the technical review. The call for evidence closed on 15 March 2019.

Responses to the call for evidence showed that a large majority considered that action should be taken to install sprinkler systems in a wider range of flats, and that the trigger height requirement is currently set too high. Responses also showed that people viewed the provision of sprinklers to have multiple benefits in providing personal protection of individuals, limiting fire spread, providing protection for property and fittings, and protecting means of escape.

Having considered the views submitted as part of the call for evidence, the Government intends to proceed with a change to fire safety guidance to require sprinkler systems in a wider range of new high-rise blocks of flats. A reduction from the current trigger height of 30 metres to 18 metres would be consistent with the ban on combustible materials in external walls and the proposed scope of the building safety regime, so this is the Government’s preferred option. However, lower trigger heights apply in Scotland and Wales.

This consultation was therefore seeking views and evidence on the appropriate trigger height options, noting that the provision of sprinklers will contribute to a reduction in deaths and serious injuries alongside considerable benefits in terms of property protection. It was also seeking views on proposals to improve wayfinding signage within blocks of flats and to install evacuation alert systems for use by fire and rescue services.

The consultation closed on 28 November 2019.

Supporting papers

To download the consultation document, please follow the link below.

CIBSE response

CIBSE agrees that the height threshold for sprinkler provision in new blocks of flats should be reduced. However, the Institution has concerns about the selection of any trigger height. The evidence base for the selection of either 18m or 11m is limited and may be related to the heights of historic fire fighting appliances and equipment.

CIBSE believes that, if the AD is a guidance, it should be recognised that BS 9251 is one way of demonstrating compliance with a requirement for automatic fire suppression systems, but this should not be the only way. Other options could be to recognise NFPA Standard 13 R, which is a less onerous standard for non-residential buildings.

CIBSE agrees that there should be a transitional period and if a broader scope for the proposed requirement is implemented, there may also be a need for introducing a phased approach to enable industry to respond to changes effectively.

CIBSE agrees that there should be a more consistent approach to wayfinding for Fire and Rescue Services. However, occupants should be able to evacuate themselves and need clear wayfinding information too. There should also be detailed guidance for changing the stay put policy to simultaneous evacuation, which is normal outside the UK.

CIBSE believes there should be a regulatory requirement for an emergency evacuation system if there is no automatic alarm system. The requirement for two staircases should be considered where the apartment building exceeds 4 stories or 16 units.

To read the full CIBSE response, please follow the link below.