AnthonyB

Detector location is off too. Easiest thing would be to sack them unless a large sum of money is involved. You'd need an expert witness report cross referencing BS5839-1 (including old editions to show how long things didn't meet the standard, if ever), the FRA and Articles 5(3) & (4), 8, 13, 17 of the Fire Safety Order.

The guidance is vague because the expectation is a post 1991 conversion from commercial to residential would be to Approved Document B with Building Regs approval and a stay put policy so no common alarm. In the real world some conversions do have to use a fire engineered approach outside of Approved Document B & operate an evacuate policy with common alarm and these are usually based around Part 1 of BS5839 as they often borrow from ADB volume 2 (which includes residential other and commercial sleeping risk) The Lacors guide which uses Grade A Part 6 systems for conversions into flats is intended primarily for houses converted into flats as these are often traditionally under the radar of local authority Housing Officers as lead enforcers and can be HMO's for s257 of the Housing Act and be liable for licensing if an authority desires under additional licensing if less than 2/3 owner occupied.

One for the lawyers to examine their leases. Their FRA should have considered other relevant persons in the premises affected by a fire in their demise which should have looked at the ceiling, but would at best all would be expected would be a 30 minute ceiling or linked building wide fire alarm and even they they could argue the unit should have been compliant when they moved in - the 60 minutes requirement is purely connected with the new development and as such the developer is likely to be expected to pay.

The installer is not the risk assessor - try another one if they are being difficult, they should design to the specification provided. It's semantics really as even if Part 6 it would be a Grade A system that essentially uses the same equipment as a part 1 system. Part 6 cannot provide a suitable system design for the commercial areas whereas a Part 1 system can incorporate sleeping accommodation as well as commercial so Part 1 would suit the project. The guidance is just that - guidance - not prescriptive otherwise there would be no need for a risk assessment and it would not be unreasonable for this scenario to use Part 1

Legally it's not necessary and you could push it to tribunal as there is nothing for them to test - HMO teams are not fire safety experts and probably don't have a copy of the relevant latest BS guidance. It's up to you how far you want to push back or whether you want to roll over and pay an electrician to essentially not do anything much!

If the block has internal common areas it has been legally obliged to have a fire risk assessment since 2006 (Regulatory Reform (Fire Safety) Order 2005 ) if all flats have external entrances with no common areas the law was clarified 4 years ago (Fire Safety Act 2021) to explicitly include the external structure of buildings containing 2 or more dwellings so would still have been required to have a fire risk assessment. A summary of the legislation for smaller blocks and how to carry out an FRA is here https://www.gov.uk/government/publications/making-your-small-block-of-flats-safe-from-fire If remedial action is indicated then the Management Company will need to ensure this occurs - if it would affect a sale is dependant on what, if anything, needs to be done. External risk assessors are an option (but choose carefully for someone with flats experience that assess risk not prescriptively tick boxes from a guide)pragmatically but is not currently mandatory. They report to the Responsible Person and would not inform the authorities unless there was an immediate and severe danger to life and an unwillingness of the RP to act on the risk in which case some may morally feel they have to notify (but they are not legally obliged to)

In theory you could do the three hour in house, if you are competent to test briefly each month then the main difference is duration which shouldn't affect ability to test for the longer period

A sprinkler system is one of the slowest systems to react, slower than heat and smoke detectors, and so there would be considerable production of hazardous fire effluent before activation, which would be a risk to life. Fire doors are still required and the only relaxation was the fitting of self closers to bedrooms, however this approach has been proven to be flawed and as part of Building Regulation changes requiring mandatory sprinkler protection to new or altered care homes this relaxation has been removed.

You would need to refer to BS7273-4 but they don't have the required failsafe's of a Category A/Critical rated hold open as if there are faults on the fire alarm they won't release and are only rated to Category B/Standard actuation at best, Category C/Indirect at worst, meaning critical locations (such as doors onto stairways) would be vulnerable.

In theory if these are the original correct hinges fitted as part of the fire doorset at the time of installation and are in good order and shut the door flush in frame then they remain acceptable. If truly adjustable they are an improvement on single chain door closers (which aren't) and aren't explicitly forbidden like a traditional rising butt hinge would be. However they are deprecated in some industry guidance so the fire risk assessor should set the acceptable benchmark. If any are worn beyond adjustment then they could be replaced like for like as still sold and do have test evidence although replacement with standard fire door hinges and a separate EN1154 closer may be preferred. https://www.ironmongerydirect.co.uk/product/adjustable-self-closing-fire-door-spring-hinge-102-x-76-x-3mm-polished-chrome-pack-of-3-692924?vat=1&GSP=true&gad_source=1&gclid=CjwKCAjwwLO_BhB2EiwAx2e-3xZjdaWmx_G4CPBW-VTNHS1EbwQua2O8OZedFbdegbS8FR5xUh4vaBoCvCAQAvD_BwE

Get a new fire risk assessor that has access to and reads current standards. Grade D & Grade F smoke & heat alarms require no formal maintenance beyond user monthly checks unless linked to a telecare system (e.g. warden call or Tunstall) as there is actually nothing to service and the test smoke poles used on commercial detection are actually cautioned against by several manufacturers of domestic detection as they can damage them. The current edition of the standard BS 5839-6:2019+A1:2020 "Fire detection and fire alarm systems for buildings - Code of practice for the design, installation, commissioning and maintenance of fire detection and fire alarm systems in domestic premises" details this

How do you get in and out normally then? If you have a door to the street from your bottom stair landing in a terrace you don't require usually a rear garden fire exit route.

That's the current (albeit outdated and under revision) version. Under the current edition of BS5839-6 a Grade D system requires no maintenance beyond user monthly tests unless part of a telecare enabled system (e.g. linked to a warden call or Tunstall system) as there isn't actually anything to service and several manufacturers caution against smoke pole testing as it can damage a smoke alarm.

Absolutely - they are accepted by the fire service (& indeed get specific mention in London Fire Brigades guidance) and fully comply with the extinguisher manufacturing, performance & safety standard BS EN3. Because they reduce the number and type of extinguishers required, thus simplifying training and saving money as well as be inspected in house, saving money, the fire extinguisher industry has written it's voluntary guidance (BS5306) to try and stop them and will spin all sorts of yarns to ty to stop you using them - just remember you must carry out the annual user inspection to comply with Article 17 of the Fire Safety Order - they aren't fit and forget.

1 lux to the centre line (BS5266). When designing the lighting for an emergency escape route it is advised that achieving even distribution of illuminance throughout the escape route with 1 lux as a minimum level on the centre of line.

Only to the extent of what parts of the premises are a workplace for the staff. However the Fire Safety Order is not the only legislation that requires an assessment of risk (including fire) depending on the status of the care given - it's not clear cut and is better explained in this https://nfcc.org.uk/wp-content/uploads/2023/08/NFCC_Specialised_Housing_Guidance_-_Copy.pdf

The door blanks are only ever labelled as FD30/60/90/120 and it's the completed door set, including the seals used, that determine if the 'S' suffix is applicable. The manufacturer's data should state which seals are OK for use in an 'S' scenario in line with the test data & certification.

As Stuart has linked, the way the legislation has been worded would pull your block into requiring an FRA for the external structure - although many believe this was never intended it's the way it stands in law. It's pretty low risk in the grand scale of things, but is something expected by lenders and conveyancers

If the conversion, usually due to the age/layout/listing, cannot meet the guidance in Approved Document B with respect to compartmentation and smoke control it cannot operate a 'stay put' policy and needs to evacuate as a whole in the event of fire. It is vital in such vulnerable properties to raise the alarm before the fire breaks out of the flat and affects the common parts thus endangering everyone else in the building. To this end the communal fire alarm requires a heat detector & sounder in each flat to raise the alarm whilst the fire is still in the flat and for the common alarm to be loud enough to wake everyone even if asleep. It's not there to save the life of the person in the flat where the fire starts as it uses a heat detector (so if you burn toast or leave the bathroom door open with a particularly steamy shower you won't tip out the whole block) hence why you still have your own local smoke alarm - it's there to save everyone else's lives. Fire safety legislation is functional with broad general requirements supported by guidance that has legal standing and which the FRA should be based on. Unless they can demonstrate how safety can be still maintained then by not following the guidance (which from your information the FRA has followed) that tends to prove that the legislation has not been complied with and this would be presented in court. So the alarm is likely to be required to meet the function requirements of the law - with the increased use of wireless technology it's not a disruptive or messy thing to install.

If there is just the electric meter and access can be restricted to stop any storage then local enclosure of the meter is an option if an existing HMO, although if it's going through Building Regs you may find they will insist on following the guidance in Approved Document B

Fire Risk Assessments have no expiry date in law if the premises have not changed - as this should address the external wall (either to say it is low risk or that it needs an FRAEW) it should suffice. An FRAEW can run into four figures or more to obtain and in a small traditional build like this would be disproportionate, however some lenders and solicitors are out of touch from reality in the current climate.

Depends on the results of the Fire Risk Assessment. Having done a few like this the usual outcome is that upgraded heritage doors are acceptable along with the lack of smoke control as part of a simultaneous evacuation strategy supported by an adequate common fire detection & warning system that extends into the flats. If the doors were not part of any listing then usually the expectation would have been to replace them at the time of conversion.

Then Mike is reflecting the current situation in English Building Regs guidance

Traditionally no, but as it's flats the Government's response to the Emergency Evacuation Information Sharing Plus (EEIS+) consultation and Residential PEEPs policy does appear to allow fire service rescue as an option from common areas as long as the PEEP is sufficient to enable independent evacuation from the flats where the fire is.

That's an unusual way around! That would be one of the steps to mitigate the solution, yes.