What are the responsibilities of the ‘responsible person’ when it comes to smoke control maintenance?
The Government has produced an important piece of advice that is only three pages long and will tell you all the essentials you need to know. You can read it here.
Simply having a smoke-control system in your building is not enough.
It must be properly maintained if it is to operate effectively during a fire. With this in mind, and following the tragedy of Grenfell, the Government published advice in February telling building owners what they must do.
This advice is mainly aimed at those who are responsible for residential buildings that are 18m or more tall. But it may also apply to you as the owner of other types of buildings, if those buildings have, or should have, smoke control systems.
If you are the owner of one of these buildings, it is essential that you know what the guidance contains.
To start with, it lays out what a smoke control system is and explains where they are likely to be sited and how they operate.
It explains that if you are the responsible person under the Regulatory Reform (Fire Safety) Order 2005, then you have a duty to ensure that appropriate fire measures are in place. It is also your duty to carry out a fire risk assessment. The order is the definitive guide to your responsibilities.
The document talks about maintenance, explaining that the standards are set out in BS EN 12101 and BS 9999. You should test your smoke control systems weekly to make sure that they are working. In addition, you should have a full maintenance inspection and test annually, carried out by a competent person.
The guidance explains the problems that can occur with electromagnetic holding devices, saying ‘It is therefore recommended that the use of electromagnetic holding devices as part of any smoke ventilation shaft installation should be reviewed as part of fire risk assessments with consideration being given to replacing these devices with a more robust form of vent actuator.’ Our recommendation is to use products CE marked to EN12101 wherever practicable as these are designed, tested and manufactured to operate as a smoke control product.
Similarly, it warns that you need to review manual override controls for automatic smoke control systems to make sure that they are working and that fire fighters can find them easily.
Next the guidance tells you what to do if you discover that there is a problem. Ideally, of course, it should be remedied immediately. But if it can’t be, then you should carry out an assessment to consider/decide if fire mitigation measures need to be put in place. Some of these may have knock-on effects on other elements of fire safety and it is important to consider these.
And finally, the advice says, you can get professional advice ‘from a qualified engineer with relevant experience in fire safety and the installation and maintenance of smoke control systems. They will normally be a chartered professional registered with the Institution of Fire Engineers but may include registered professionals from another built environment profession specialising in fire safety’. You must get this advice from somebody who is deemed to be competent in the field.
Put simply, this guidance tells you:
* that smoke control is important
* that you are responsible
* that you should check your system regularly
* that you should have proper annual maintenance done
* that if anything is wrong you should put it right
* and that you should get advice from a competent professional.
It is all too easy to ignore these responsibilities. But if you do, and if there is a fire, you could be legally held responsible for people’s deaths or their ill health due to smoke inhalation. And of course, even if there are no casualties, you may still be responsible for considerable damage to property.
The Government-produced piece of advice is only three pages long. Be sure to read it here.
If you are in any doubt about your responsibilities when it comes to smoke control maintenance or if you need a competent servicer to maintain your systems, contact us.