AnthonyB

- refer to current Building Regulations -

The following may be of use: https://historicengland.org.uk/images-books/publications/fire-resistance-historic-timber-panel-doors/ https://envirograf.com/product-category/fire-doors/

From your questions it's clear that you have not had a fire risk assessment carried out by a competent person, something you must do by law. This would answer every question. You won't need hose reels. You will need extinguishers - the size and type will be based on: - Floor area in square metres of your premises - Exposed surface area of the biggest fryers - Any areas of special electrical risk. This information would help decide how many water/CO2/wet chemical (or just water mist for simplicity)you need. Everything but the tiniest restaurant would need as a minimum a manual fire alarm system of manual call points, sounders and control panel - depending on layout and size automatic detection would be required too. Don't forget the emergency lighting and maintained internally illuminated exit signs too!

22m means you should really have a back door! It's too far for a single exit under current guidance - however the draft of new guidance for small premises looks like it will increase the maximum distance to 25m so I wouldn't worry too much. A single exit is still a maximum of 60. Your floor area matters too - for every 1 sq.m. of dining area you can have 1 person, for every 0.7 sq.m. of queuing space you can have 1 person - in a small premises this may limit you to less than the 60 your exit allows.

As each cluster and other common areas are usually under the control of the same client I do it as one - never had any problems. If a whole cluster is under different ownership (rather than the leasehold of individual bedrooms which is a common model, all shared space retained by the freeholder) then it would be different.

If the flats are separated from the retail then I would be looking to see if the system was needed at all. Purpose built flats only normally need communal detection to operate smoke control measures and need no sounders or call points. If there is a defect that cannot be realistically be remedied that requires a full evacuation policy is required you would also need a Part 1 system but with the required extra detection coverage in flat hallways, common area call points and sounders to flat hallways and common parts. If it was a flat conversion not compliant to Building Regs (often pre 1991 and a s257 HMO) then you would have a Grade A system to the common parts which also should have call points to each landing, but some licensing councils accept a single one at the exit in smaller blocks.

To be fair BS9999 was primarily for new building design as an alternative to ADB (& devolved equivalents) and there were too many people cherry picking the 'best bits' out without the premises complying to all aspects of the standard when using it on existing premises (I know the author and he confirms my interpretation) so I can understand their reticence. However if you are doing a full strip to shell & redevelopment that's virtually the same as building then there is more chance of implementing BS9999 in full and thus it should really be accepted.

One of these days I'll have to start invoicing you! ??? Glad to help.

There are a lot of factors (including why is the alarm there in the first place). If the system is installed under Part 1 of BS5839 for simultaneous evacuation then the expectation would be for call points to each floor (Part 6 has more leeway) however there may have been an agreed variation in the design accepting the one MCP

It would be reasonable to say they should, but you cant say they must unless double swing.

I've come across this before - are sprinklers installed (every PRU or similar I've assessed has been)? Are the correct legal Deprivation of Liberty arrangements in place to allow additional security measures? Is there automatic detection everywhere? In these situations it's usually allowed to have less of the escape failsafe's than a standard school.

Overlay with polycarbonate sheeting (as used in riot shields). As long as it doesn't affect the integrity or insulation of the door then any surface spread of flame only risk should be OK (& the right polycarbonate isn't readily ignited anyway as riot shields get firebombed)

It's been a staple of guidance from back in FP Act days and ADB Table B4 still has a 60 minute requirement for basements (going up to 90 minutes where you go deeper than 10m) and the top & bottom door thing has been around for similar years. As the guidance dates back to the late 20th century it dates from when fire alarm systems were generally manual with limited detection (& even then mostly heat until the 70's) so it's not unsurprising that detection can be used to justify deviation (but I'd expect the whole basement as you aren't just deviating on the door, plus the lobby approach is a form of smoke control that a detector can't compensate for and also you are having a lower FR for the whole ceiling). A few years ago I dealt with a mill that had unprotected gappy wooden floors that in theory should have been 30 minute and imperforate to smoke on the upper floors and 60 to the basement - this would have been financially impossible as it would have required tenants relocating, false ceilings removed, services re routed and effectively site redevelopment. The sprinklers were too neglected to use, so I proposed a new L1 system (benchmark would be M) as the alarm was non compliant & ancient anyway and upgrading the protection to the internal & external escapes as TDs weren't too bad and it was an awake occupancy familiar with the building. An Enforcement Notice was served during the protracted period of trying to cost and get approval, citing the same issues I'd picked up so any solution has to satisfy them too. After lengthy meetings (& am interrogation!) they agreed with the alternate solution with one exception - the basement ceiling had to be 60 minutes. Considering the savings on the other floors and the fact a notice compliance clock was ticking the client and myself agreed. The FR Assessor is correct following the traditional benchmarks. BC shouldn't be suggesting non standard solutions but determining if they will accept the ones suggested by the architect (or in reality their fire engineers) as any alternate solution needs to detail why it's acceptable in a fire strategy (or at least FR assessment) so during the life of the building the methodology is understood and maintained. Also once BC have passed it then it's no longer their problem and becomes a fire service enforcement issue - if a few years down the line an audit picks up the differences, finds them too high a risk they will want the mitigation as to why it's OK - and saying BC passed it holds far less water than it used to due to the amount of things passed that actually don't comply for various reasons. You don't want to underdrawn the basement ceiling again if you can avoid it, therefore you need to have something that will explain why & how the non benchmark solution is acceptable not just for Building Regulations purposes but for Fire Safety Order ones as well - if you can get that you should be fine for both the immediacy of BC purposes but long term as well. If it's a smaller old building then it may well have had lesser standards in place for a long time as it won't have needed a fire certificate and whilst there were still requirements to be met and the guidance book was broadly the same in benchmarks to the one for certification these premises were rarely if ever inspected.

Open kitchen or in it's own sub-compartment? I'm trying to work out why they may have gone for this. The UK is a bit behind with kitchens though, the US has mandated suppression systems for all frying/grill ranges regardless of size for decades.

The flat front doors is easy, it's always been a 30 minute self closing doorset with (since the late 80's) intumescent strips and cold smoke seals. Similarly flat internal doors other than the bathroom should be (at least) 20 minute fire doors without closers (it has changed a lot over the last 60 years of flat fire safety standards)

Expect, yes, for them actually to, far less so.

This isn't a planning law forum, however if in doubt it's probably better to apply and not need it than the other way around! More important is the submission to Building Control for the work which you will have to do regardless of planning.

In theory he is within his rights as you should have had a system of maintenance in place over the years so that it did not become unsafe, just because it has been neglected doesn't mean it's OK to do away with it. BS9999 is an alternative to Approved Document B for designing a building and isn't meant for existing building assessment unless it meets all sections of the document and couldn't help you anyway as the additional % allowed for various matters only apply where fire precautions are above the minimum and an L2 system is determined as the minimum for your type of premises and the other option to extend TD (sprinklers) is no easier than replacing the escape. I can't see where upgrading the basement alone justified the TD of the floors above - even where the normal TD are used you would expect the doors to be 30 minute and the ceiling 60 (I have no idea where the 120 he advised came from). The accepted methodology for fire risk assessment (PAS 79-1) determines that TD are not set in stone and minor variations should be acceptable - it's whether 3 metres would be minor or not. Your options are: If you think there is no deficiency and no risk and that the Notice is inappropriate: See if the fire authority will agree to an informal review of the decision to issue an notice, failing that you can appeal to your local magistrates’ court within 21 days of receiving a notice. If you agree there is a need to improve fire precautions but disagree on the technical solution to be used (as in this case): See if the fire authority will agree to refer the issue to the Secretary of State for independent determination under article 36 of the Fire Safety Order (this should be done as soon as possible and ideally before a formal notice is issued). Of the four determinations so far the fire service's solution have won 2, the responsible person's the other 2. or, if you feel you are unlikely to win, carry out the work. Possible solutions to TD include - upgrading fire alarm to L1, or fitting sprinklers.

It's quite simple - as your building contains two or more dwellings (i.e. flats) then it is covered by the Fire Safety Order 2005 (as amended by the Fire Safety Act 2021) and covers the entire exterior of the building, the internal common areas and internal boundaries with the common areas (to include the front doors of flats) The Responsible Person under this legislation is the Freeholder (& any Managing Agent exercising control of the premises on their behalf) who has to carry out a Fire Risk Assessment of parts of the premises as covered by the legislation which will in turn determine the necessary fire precautions. This should be carried out by a competent person, ideally an accredited fire risk assessor. Depending on the age when the conversion occurred, the structural compartmentation, nature of fire doors (including flat front doors), provision or otherwise of smoke control measures, etc the assessment will decide that either: - No common fire alarm is required and stay put is OK - The above is possible subject to some improvement works that are reasonably achievable - A common fire alarm system including detection and alarm devices in flat hallways (to raise the alarm before the fire or smoke breaks out of the flat of origin trapping others) is required along with a full simultaneous evacuation policy for the whole building. Also the building could be a s257 HMO under the Housing Act as it is a conversion from a house - the additional criteria are if the conversion doesn't comply with Building Regulations (most older ones didn't) and if less than two thirds (50% in some council areas) of the flats are owner occupied. This would, depending on the local Councils additional licensing scheme criteria, mean it requires a license in addition to all the other fire precautions. Anthony Registered Fire Risk Assessor

It's quite simple - as your building contains two or more dwellings (i.e. flats) then it is covered by the Fire Safety Order 2005 (as amended by the Fire Safety Act 2021) and covers the entire exterior of the building, the internal common areas and internal boundaries with the common areas (to include the front doors of flats) The Responsible Person under this legislation is the Freeholder (& any Managing Agent exercising control of the premises on their behalf) who has to carry out a Fire Risk Assessment of parts of the premises as covered by the legislation which will in turn determine the necessary fire precautions. This should be carried out by a competent person, ideally an accredited fire risk assessor. Depending on the age when the conversion occurred, the structural compartmentation, nature of fire doors (including flat front doors), provision or otherwise of smoke control measures, etc the assessment will decide that either: - No common fire alarm is required and stay put is OK - The above is possible subject to some improvement works that are reasonably achievable - A common fire alarm system including detection and alarm devices in flat hallways (to raise the alarm before the fire or smoke breaks out of the flat of origin trapping others) is required along with a full simultaneous evacuation policy for the whole building. Also the building could be a s257 HMO under the Housing Act as it is a conversion from a house - the additional criteria are if the conversion doesn't comply with Building Regulations (most older ones didn't) and if less than two thirds (50% in some council areas) of the flats are owner occupied. This would, depending on the local Councils additional licensing scheme criteria, mean it requires a license in addition to all the other fire precautions. Anthony Registered Fire Risk Assessor

I suggest checking direct with the manufacturer: https://www.phoenixsafe.co.uk/

Not necessarily - if you have an assembly area that has exit doors opening into corridors or stairs before reaching the final exits that may be used by over 60 persons then the interior fire doors separating these areas would also be expected to open outwards etc. Otherwise you will still get the fatal crush just deeper in the building.

Assuming that the distance from the back of the shop to the front door doesn't exceed around 18m and you aren't planning to have more than 60 people inside it isn't a problem.

The local authority enforce the Housing Act which covers all types of rented housing to varying degrees and has far more wide ranging powers (particularly powers of entry) than the fire safety legislation that principally covers the common parts. It's mostly for rented premises. Being a s257 HMO only covers if the premises can be covered, if the local authority wishes, by additional licensing, but even if a license isn't required the Housing Act applies as does the Fire Safety Order as amended by the Fire Safety Act as there are 2 or more dwellings in the building (regardless of if they are rented or not) The fault for all this lies with whoever did the illegal conversion but that doesn't change the current situation. If it's not considered to minimum safe standards both types of legislation allow remedies up to and including prohibition & prosecution. Fire doesn't care if the premises are owner occupied or not and if the structural standards are such that a proper alarm is required then it's either that or renovate so the right fire separation and smoke control associated with stay put is provided. If it was the case that a fire in one flat wasn't an immediate risk to the lives in the other flats then each occupier (if not rented) could make their own decision to live or not by providing local smoke alarms, but it's the fact (as far as the enforcers are concerned, I've not seen the premises) that it is which leads to the current situation.

Potentially yes - anyone using common sense would want to cover the electrical riser anyway, whereas there would be an argument to exclude the water riser as a variation if it only contains water pipes.