Fire Risk Assessment National Register

Fire Safety (England) Regulations 2022
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Today’s breaking news of the full evacuation at Notting Hill Genesis Paragon Estate in Brentford highlights the role of the Fire Risk Assessment in Building Safety.

The Regulatory Reform Fire Safety Order (2005) states that properties covered by the order should have a ‘suitable and sufficient’ Fire Risk Assessment. In relation to housing it does not currently say anything about sharing the Fire Risk Assessment with residents.

Putting the sharing point to one side for a moment. The key question is: “how can a Fire Risk Assessment be deemed to be ‘suitable and sufficient’ in a Higher-risk building when the assessor has no evidence of passive fire protection measures being present or correctly installed?”

Responsible persons (building managers and owners) should consider the risk profile of each of their buildings. If the state of these critical and hidden fire protection measures are unknown, they must conduct an intrusive (Type 4) Fire Risk Assessment.

Turning to the Paragon Estate as an example, from a risk perspective this would rank high on most measures:

  • Up to 17 storeys
  • Modular construction
  • Student accommodation
  • The developer has known fire issues in other developments

The reason given by NHG for the evacuation of the site is due to issues found during intrusive surveys that require further investigation. So the key question is:

“When were the intrusive surveys conducted and therefore how long have residents been living in accommodation that was known to be unsafe and has now been evacuated?”

To answer this question we need to know the chronology of fire risk assessment for the block, their Types, who conducted the surveys, were the recommendations followed etc. Quite a bit of forensic activity but all super easy to do if the development had a Digital System of Record (aka Golden Thread). This information could all be seamlessly shared between Building Managers, Fire and Rescue Service and Ministry of Housing (until the new regulator is established).

Imagine though needing this level of insight and more to regulate over 13,000 such HRBs. Well, back in November 2018 we wrote to the Secretary of State for Housing offering an immediate deployment of the TrackMyRisks platform. That would have enabled the gathering of this information, assessing risk and helping to deliver Building Safety for all. 

It is, therefore, hugely disappointing that this type of solution (doesn’t have to be ours) has not yet been implemented. From our perspective, we haven’t even had a chance yet to demonstrate to officials how powerful it is.

How many more disasters like Grenfell Tower or near misses like Paragon Estate do we have to endure before urgency and meaningful change is forthcoming? Our door remains open and we are ready to implement immediately.

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