Graham Oliphant, Managing Director of Harmony Fire’s consultancy business, examines MHCLG proposals on fibre cabling approvals and the fire compartmentation risks
A flurry of life safety consultations have been launched since the start of the year, including from the BSI, the Scottish Government and from The Ministry of Housing, Communities and Local Government (MHCLG).
It was one such consultation, from the MHCLG and published on 27 January, that particularly caught my eye, entitled ‘Improving proportionality and safety outcomes in building control: telecommunications work’.
In summary, this consultation seeks views from industry on proposals to streamline building control procedural requirements within higher risk building settings for the installation of fibre optic cabling and mobile masts.
In the case of fibre optic infrastructure, the open call also seeks feedback on potential building control approval changes for non-higher-risk buildings too.
The consultation considers ‘proposals to dispense with procedural requirements of building regulations for….building work related to the drilling of holes through internal fire-resisting walls for fibre optic cabling and work related to the installation and repair of mobile communications masts.
For these activities, the current building control procedural requirements may be unreasonable and disproportionate and can direct regulatory resources away from the types of building work that carry higher risk, such as new builds and remediation projects.’
Context in building control
The background to this consultation will be familiar to anyone in the housing sector since the introduction of the Building Safety Regulator (BSR).
We need not reopen the arguments going back and forth about the BSR’s role and impact on a sector that repeatedly and fatally has shown itself systemically incapable of consistently delivering safe buildings.
But this consultation makes it clear that greater pragmatism and proportionality may be required to facilitate wider and faster broadband roll out across the nation, as well as to support the BSR on its quest for consistent delivery to agreed service level agreements.
It’s reasonable to view fibre optic cables as a government test case for the BSR as it grapples with resourcing and talent challenges around the Gateway process set up post-Grenfell Tower disaster to ensure a mass casualty event can never happen again within our buildings.
Remediation work currently falls within the Gateway process and the backlog at the BSR continues to grow as work to make buildings safe for residents is regularly delayed beyond the 8-week Gateway 2 decision deadline.
The new leadership team at the BSR has indicated it’s actively looking at remediation activity with an announcement due imminently on a more streamlined process.
So why did this particular public consultation grab my attention? Well with unbelievable timing and coincidence, a colleague had just recently sent me an image with rolls of newly printed labels for a fire compartmentation project Harmony Fire is delivering in Scotland.
Staring out from the screen on my phone I’d just read ‘Fire Compartment Line – Do not alter, cut or breach this fire seal/compartment without permission.
Any damages must be reported and repaired immediately.’ We actually used this very image in our LinkedIn post highlighting the launch of the consultation.
The issue of maintaining fire compartmentation integrity is a constant challenge for everyone working in the life safety sector.
We have directly witnessed far too many egregious fire compartmentation breaches that render this front-line defence against the spread of smoke and fire ineffective and dangerous.
Compartmentation is a critical building safety feature, designed to slow the spread of fire and buy time for residents and emergency services to respond.
A combination of fire-resistant walls and ceilings, fire doors, fire stopping and cavity barriers all work together to create a sealed structure, and a failure in any one element dramatically escalates risk to life.
Training and site discipline
Education and enforcement around fire compartmentation is not consistent and this is why Harmony Fire has worked in partnership with our customers to develop a new behavioural and cultural approach to the issue of fire compartmentation integrity.
Moving the discussion away from tick-box compliance to real-life failure consequences is our starting point.
Maintaining the integrity of ‘the box’ saves lives and it’s therefore everyone’s responsibility to be vigilant, and to protect and challenge, if necessary, any activities that could compromise the system.
An all-encompassing education programme on the importance of compartmentation delivered to the landlord, residents, building managers, maintenance teams, suppliers, subcontractors and anyone regularly visiting sites means more focused eyes and greater vigilance.
By adopting the ‘hot works’ model used for those contractors working at height and using naked flames on buildings, a new permission-based authorisation system ensures that nobody is permitted to work in a way that could compromise fire compartmentation without prior approval and oversight.
The stickers of course represent the final ‘analogue’, but highly visible, stage of this new behavioural regime, reminding everyone of their joint responsibility for vigilance and urging action if something doesn’t look right.
Our vision to further evolve this regime with customers sees the increasing use of technology and digital accountability, through digitally locked BIM assets and a dedicated Permit to Breach (PTB) process incorporated into the existing Safe Systems of Work (SSoF) protocols.
Utilising PTBs underscores the high-risk nature of compartmentation breaches for our customers’ supply chains and wraps a robust legal framework around the compliant remediation of any work before a PTB can be closed and payments authorised.
The inescapable challenge that all parties to this conversation face is how to support sectors that bring services, like faster broadband, to communities that can drive prosperity, social mobility and productivity, while simultaneously protecting those same communities from the unintended consequences of policy decisions that may be a retrograde life safety step.
Compliance expectations remain
The consultation makes it clear that the drilling of holes in fire compartmentation to accommodate the installation of fibre optic cabling must still comply with requirements under the Building Regulations 2010 and for higher-risk buildings under Part 4 of the Building Safety Act 2022.
However, there is a significant risk that needs to be carefully discussed and considered around the optics of what this potential change may bring from a behavioural perspective.
Under the current legislative regime, anyone seeking to compromise fire compartmentation must submit an application via the BSR’s Gateway process.
This reflects the life safety significance of this activity and focuses applicants on the risks and the expected standards and quality of remedial activity required.
Today, we regularly see the consequences of people not adhering to these existing strict regulations, with genuine instances of compartmentation breaches within weeks of our own project completions.
In this context, we have serious concerns around the perception of a downgrade, or watering down, of the regulations associated with fibre optic cabling installation.
And let’s be clear in terms of behavioural response in a real-world application, the expectation of ‘mission creep’ is high.
If we can drill holes for fibre optic cabling, then surely there’s little difference for that coaxial or POE cable, right?
If it becomes a routine activity to drill holes in fire compartmentation and this is what people regularly witness up and down the country, do we not risk undermining all the hard work and the behavioural changes we have set in train to underscore the importance of fire compartmentation integrity?
Practical options and mitigations
The consultation process gives every audience the chance to have their say, and we should be grateful that views are being sought for this highly significant and consequential change.
But there are already measures and actions that can be taken today to make this less of a binary decision.
Across many of our compartmentation projects, we have introduced a simple future proofing measure that eliminates the need for future drilling.
By specifying firestop sleeves into our compartmentation designs, this provides a fully compliant and safe way for cables to be installed without the need for any additional interventions.
The greater adoption of asset-based technology solutions and existing safe working protocols linked to contractual payment terms offer an alternative vision.
Balancing demands, proportionality and appropriateness characterise this latest consultation process.
It’s vitally important that as many voices, from as many sides of this debate, are heard before the closing date on the 24 March.
This will ensure changes do not bring unintended consequences that ultimately set back resident life safety outcomes.
This move feels like a retrograde step and risks behavioural change in the wrong direction.
Let’s hope that diverse voices across the sector provide their own insights into how we can best balance the demand, while understanding our number one priority must remain focused on the safety and security of families relying on the absolute integrity of fire compartmentation.