Department /Agency:
Department for Children, Schools and Families (DCSF) / Title:
Impact Assessment of Building Bulletin 100 - BB100 Design for Fire Safety in Schools
Stage: Implementation / Version: Final / Date: 5 November 2007
Related Publications: Approved Document B to the Building Regulations (England & Wales)
Available to view or download at:
http://www.teachernet.gov.uk/fire
Contact for enquiries: / Telephone: 0207 273 6690
What is the problem under consideration? Why is government intervention necessary?
Figures from Communities and Local Government (CLG) show that there are over 1,300 school fires a year in England and Wales which are attended by local authority Fire and Rescue Services. Around 60% of these are started deliberately. It is therefore necessary to greatly reduce the risk of fires occurring in schools and, when a fire does occur, reduce the risk of it spreading. Although Building Regulations (specifically Part B) include requirements for the management of fire risks in buildings it was felt that BB100 needed to address the particular problems of school fires.
What are the policy objectives and the intended effects?
While the primary concern is for the safety of the users of school buildings, a fire can have a serious impact on children’s education due to disruption and loss of course work. The important roles that schools play in the community means that losses incurred as a result of fire can have severe social consequences. As such, it is particularly important that property protection be considered during the design period and throughout the working life of these buildings. BB100, therefore gives advice on property protection as well as life safety issues.
What policy options have been considered? Please justify any preferred option.
Approved Document (AD) B contains technical guidance on meeting the functional requirements of Part B which relate to the management of the health and safety risks associated with fires in buildings. It does not contain additional guidance on property protection. Therefore, the three options considered were: (i) Put the guidance for schools in AD(B); (ii) Put the guidance for schools in AD(B) and encourage property protection; and (iii) Prepare BB100 to address the particular fire risks associated with schools including the issue of property protection. Option (iii) was the preferred option.
When will the policy be reviewed to establish the actual costs and benefits and the achievement of the desired effects? AD B is reviewed approximately every 5 years and at that time it would be sensible to review the DCSF sprinkler policy for property protection.
Ministerial Sign-off For SELECT STAGEconsultation stagefinal proposal/implementation stage Impact Assessments:
I have read the Impact Assessment and I am satisfied that, given the available evidence, it represents a reasonable view of the likely costs, benefits and impact of the leading options.
Signed by the responsible Minister:
Jim Knight
Date:
Summary: Analysis & Evidence
Policy Option: (iii) / Description: Prepare BB100 to address fire risks in schools
COSTS / ANNUAL COSTS / Description and scale of key monetised costs by ‘main
affected groups’ These costs relate to the need to undertake a fire risk assessment and to install sprinklers in schools where deemed necessary in accordance with DCSF policy together with costs of annual maintenance of sprinklers.
One-off (Transition) / Yrs
£ 0 / 20
Average Annual Cost
(excluding one-off)
£ 24.3m / Total Cost (PV) / £ 486m
Other key non-monetised costs by ‘main affected groups’ None
BENEFITS / ANNUAL BENEFITS / Description and scale of key monetised benefits by ‘main
affected groups’ These benefits relate to the cash savings generated through improvements to life safety as well as reductions in the risk of injury, property damage, business interuption and insurance premiums.
One-off / Yrs
£ 0 / 20
Average Annual Benefit
(excluding one-off)
£ 31.2m / Total Benefit (PV) / £ 625m
Other key non-monetised benefits by ‘main affected groups’ Benefits not quantified here include potential savings in construction costs because of trade-off as well as social impacts such as distress, loss of teaching aids and students' coursework, higher future security costs, etc.
Key Assumptions/Sensitivities/Risks A discussion of the broad assumptions is given in the evidence base below, but the main approach was to use the DCSF sprinkler cost-benefit model.
Price Base
Year 2007 / Time Period
Years 20 / Net Benefit Range (NPV)
£ -£13 to +£291m / NET BENEFIT (NPV Best estimate)
£ +139m
What is the geographic coverage of the policy/option? / England & Wales
On what date will the policy be implemented? / October 2007
Which organisation(s) will enforce the policy? / DCSF
What is the total annual cost of enforcement for these organisations? / £ Minimal
Does enforcement comply with Hampton principles? / Yes/NoYesNo
Will implementation go beyond minimum EU requirements? / Yes/NoYesNoN/A
What is the value of the proposed offsetting measure per year? / £ 0
What is the value of changes in greenhouse gas emissions? / £ 0
Will the proposal have a significant impact on competition? / Yes/NoYesNo
Annual cost (£-£) per organisation
(excluding one-off) / Micro
/ Small
/ Medium
/ Large
Are any of these organisations exempt? / Yes/NoYesNo / Yes/NoYesNo / N/A / N/A
Impact on Admin Burdens Baseline (2005 Prices) / (Increase - Decrease)
Increase of / £ / Decrease of / £ / Net Impact / £
Key: / Annual costs and benefits: Constant Prices / (Net) Present Value
Evidence Base (for summary sheets)
[Use this space (with a recommended maximum of 30 pages) to set out the evidence, analysis and detailed narrative from which you have generated your policy options or proposal. Ensure that the information is organised in such a way as to explain clearly the summary information on the preceding pages of this form.]
1
BACKGROUND
Risk assessment
The number of deaths in school fires is very small. During the period 1994-2002, only one person died, in approximately 14,700 fires. Despite the statistics, it is important to avoid complacency as there is always the possibility of a death in a school fire or even multiple deaths.
The number of injuries in school fires is also quite small. During the period 1994-2002, 461 people were injured, an average of 51 per year, and 0.03 injuries per fire. Not all injuries are severe. In 2002, there were 46 injuries which included people suffering from smoke inhalation, burns, shock, etc.
The real problem with fires in schools is the scale of the property losses. It is significant and rising: in 1998 it was a little under £30m but by 2002 it was nearly £100m. These are just the direct losses (insurance claims) – the true cost is likely to be even higher because there are other kinds of uninsured losses that may occur, for example:
· The hire of temporary accommodation during the rebuild – which can be up to five years
· Additional costs if pupils need to be transported to another school site
· General disruption, including children’s education
· Loss of teaching aids
· Loss of coursework – which will have to be redone by the pupils
· Loss of personal items owned by pupils and staff
· Loss of facilities for the community, e.g. for Scouts, Guides, football and other sports, evening classes, polling station, council meetings, centre for emergency accommodation, etc.
· Additional costs from insurers requiring more security to prevent repeat incidents
· Stress will be high, particularly for senior staff
· Loss of reputation with implications for recruitment and retention of staff as well as pupil applications.
In 2003 CLG (Communities and Local Government) reported that “The number of arson attacks has increased steadily over the years. It is now the largest single cause of fires in schools, with 70% classified as deliberate. Recent research by the Association of British Insurers (ABI) and the London Fire and Emergency Planning Authority indicate that as many as one in eight schools nationally suffer some form of arson attack each year”.
Further details on fire risks in schools can be found in BB100.
Rationale for government intervention
It is necessary to greatly reduce the risk of fires occurring in schools and, when a fire does occur, reduce the risk of it spreading. Although Building Regulations (specifically Part B) include requirements for the management of fire risks in buildings it was felt that BB100 needed to address the particular problems of school fires.
The intervention is particularly timely and relevant in the light of the Building Schools for the Future (BSF) school building programme which represents a new approach to capital investment. BSF is bringing together significant investment in buildings and in ICT (Information and Communications Technology) over the coming years to support the Government’s educational reform agenda (see http://www.bsf.gov.uk/).
The Government is also devolving significant funds to local authorities (LAs) and schools to spend on maintaining and improving their school buildings. It wants to promote a step-change in the quality of provision which is the focus of BSF. The programme – worth £2.2 billion in its first year (2005-6) – aims to ensure that secondary pupil learns in 21st-century facilities. Investment will be rolled out to every part of England over 15 waves, subject to future public spending decisions.
· By 2011, every LA in England will have received funding to renew at least the school in greatest need – many will have major rebuilding and remodelling projects (at least three schools) underway through BSF and the remainder will have received resources through the Academies programme or Targeted Capital Fund.
· By 2016, major rebuilding and remodelling projects (at least three schools) will have started in every LA.
Building Regulations and Part B
The Building Regulations 2000 (as amended) apply to most building work in England and Wales, typically the erection, extension or material alteration of a building and are the responsibility of Communities and Local Government (CLG). (Separate legislation applies in Scotland and Northern Ireland.) Building Regulations may be made for a number of purposes but Regulation 8 currently limits the locus of many of the Parts, including Part B, to ensuring reasonable standards of health and safety of persons in and around buildings. In other words, it does not contain additional guidance on property protection.
The five existing requirements of Part B are written in a functional manner requiring the building work to achieve a performance that is adequate, reasonable or appropriate. These are broadly:
1. To provide appropriate means of warning and escape
2. To adequately resist internal fire spread (linings)
3. To adequately resist internal fire spread (structure)
4. To adequately resist external fire spread
5. To provide reasonable access and facilities for the Fire and Rescue Service.
New and substantially refurbished schools need to meet Requirements B1 to B5.
The technical guidance in Approved Document (AD) B which shows how these requirements can be met was recently subject to an extensive review and public consultation, and a new edition came into force in April 2007 (see http://www.planningportal.gov.uk/england/professionals/en/1115314683691.html). This was supported by a Regulatory Impact Assessment (RIA) – see http://www.communities.gov.uk/publications/planningandbuilding/regulatoryimpactassessment10.
Building Bulletin 100
The previous fire guidance on schools was contained in BB7 which was integrated into the 2000 edition of Part B. (Before this time schools were exempt from the Building Regulations.) The latest edition of Part B no longer contains guidance on schools; instead it refers to the guidance in BB100 which, if followed, will demonstrate compliance with Requirements B1 to B5. BB100 was drafted by DCSF in conjunction with its consultants and has been reviewed by CLG.
As noted above, while the primary concern is for the safety of the users of school buildings, a fire can have a serious impact on children’s education due to disruption and loss of course work. The important roles that schools play in the community means that losses incurred as a result of fire can have particularly severe social consequences. As such, it is particularly important that property protection be considered during the design period and throughout the working life of these buildings. BB100, therefore gives advice on property protection as well as life safety issues.
An early draft of BB100 was subject to public consultation during October to November 2005. This document attracted a fair degree of adverse criticism: the majority of respondents felt that life safety issues would have been better addressed if AD(B) remained as the primary source of guidance. Another frequently made comment was that the draft was too difficult to follow due to its poor structuring and that in its current format it was unsuitable as a design document. The inclusion of provisions aimed at property protection were generally welcomed, although a number of respondents highlighted the need for these extra requirements to be distinguished from those concerned with life safety. This is because the life safety requirements (compliance with the Building Regulations) are legally binding, whereas property protection is not. A report summarising the consultation responses can be found on the DCSF Fire Safety website www.teachernet.gov.uk/fire.
As a consequence, BB100 was substantially re-drafted. In particular it has been structured around Requirements B1 to B5 with technical guidance to show how each of these requirements can be met. In addition, the document makes a series of recommendations with regard to property protection for each of the requirements which are clearly identified as such since these are all voluntary. (These property protection measures are summarised in Annex A to this IA.) The intention of BB100 is to address both life safety needs and property protection at the same time. This dual approach will allow designers to tailor their strategy to the location, use and risks identified. For the purposes of BB100, the objectives of property fire protection include:
· minimising the effects of fire on the operation of the school (primarily, teaching);
· limiting the effects of interruption to operation of the school;
· seeking to have the school operational within 24 hours; and
· protecting the buildings.
A designer is not required to follow the guidance in BB100, but may adopt an alternative approach, possibly based on Fire Safety Engineering. This is a risk-based approach, with the aim of providing an acceptable level of safety that gives good value for money. The onus is on the designer to demonstrate that the design results in an appropriate safety level, as good as or better than that achieved by following the detailed design guidance.