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Level 6 Certificate in Fire Safety for

Building Control
– Complex Buildings

COHORT 5

Wayne Carter
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List of Abbreviations

AD Approved Document

ADBV2 Approved Document B: volume 2 2019

AFD Automatic fire detection

AI Approved inspector

ASET Available Safe Egress Time

BA Building Act 1984

BAIR Building (Approved Inspectors) Regulations 2010

BC Building control

BCA Building Control Alliance

BICoF Building Inspector Competence Framework

BR Building Regulations

BS British Standards

BSA Building Safety Act 2022

BSI The British Standards Institute

CDM The Construction (Design and Management) Regulations 2015

CICAIR Construction Industry Council Approved Inspectors Register

CPD Continuous professional development

DBIS Department for Business Innovation & Skills

DLUHC Department for Levelling Up, Housing and Communities

FA Fire authority

FE Fire engineer

FRSA Fire and Rescue Services Act 2004

FS Fire strategy
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HMFSI HM Fire Service Inspectorate

HSE Health and Safety Executive

LA Local authority

LATP Local Authority Technical Panel

MHCLG Ministry of Housing, Communities & Local Government

m-1 Section factor

MOE Means of escape

NFCC National Fire Chiefs Council

PEEPs Personal Emergency Evacuation Plans

PIBS Premises information boxes

RC Regulators Code

RRO Regulatory Reform Order

SSRI Site-Specific Risk Information (SSRI)

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1A - Describe the nature of the defective work and its context in

relation to the complex building and explain why you think it will be
suitable for the assignment. You should identify if there are any
weaknesses in the example chosen where a full response to the
tasks set may not be possible.

The scheme was a reversion from an AI concerning the installation of a 6 storey tiered racking
system and two storey mezzanine within a single storey commercial unit with a floor area of
2397m2. A plans certificate did not accompany the Regulation 18 notice (BCA, 2023) but the
reasoning for the cancellation was detailed.

For the purposes of this assignment we are focusing solely on the lack of fire protection to the
tiered racking and the mezzanine however, this element alone cannot be scrutinised without
an examination of other factors that are affected by the provision of passive fire protection.

The structural frame was completed when the

cancellation notice was deposited, and work
would continue (and completed) during the
design development. The phasing of work
presents many complexities as the flow of
information and construction programme did not
follow a recognised development pattern to allow
input and cooperation between all stakeholders
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for project delivery in a timely manner (RIBA 2021). Instead, it impeded design flexibility to
formulate solutions.

The following illustration provides a more in-depth indication of the workflow pattern for
building control. This project would not follow this course of events and the build would proceed
at the risk of the service users.
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An overview of the scheme is as follows:

• The project was a material alteration therefore the building work had to comply with
the functional requirements of the BR and the remaining construction should be no
worse than before (Reg 4, BR 2010).
• I believed the racking was a floor structure therefore the formation of additional levels
required a review of B1 through to B5 which would include a review of the existing
building.
• Notable issues included the following:
o Protected staircases were required,
o Travel distances were excessive,
o There was no fire protection,
o The building was no longer classified as a single storey unit, therefore,
compartmentation was required as the volume exceeded 20,000m2 (Table 8.1,
DLUHC, 2022b),
o Fire brigade was no longer in accordance with Table 15.1 (DLUHC, 2022b
p111).

As explained, our focus is the fire protection to the floor. Table B4 would be applicable, notably,
90 minutes RIE was required. The complexity arose from the pursuit of an unprotected frame
and how this could be demonstrated as being ‘reasonable provision’ when departing from
prescribed solutions in the form of ADBV2 or BS 9999. As Law (2023) eloquently states…
‘what does reasonable look like?’ The varying nature of fire engineering and mix of attitudes
combined with the plethora of solutions can spawn diverse outcomes.

It is further complicated when one considers the possible implications that one departure may
have on other prescribed solutions within the various codes of practice. As indicated, this
scheme would initially lack any fire safety provisions but as the concept developed, further
issues presented with the aspiration of an unprotected floor, including:

• Adjoining protected staircases would be fixed to the structure, which would likely result
in progressive collapse with the premature failure of the floor,
• It was proposed that a required compartment wall would be formed from a fire resisting
fabric, however, concerns were raised over the possibility of the floor prematurely
failing and penetrating the fabric,
• There had been no scrutiny of the type of goods being stored within the structure and
what affect that may have on escape times,
• The safety of fire personnel operating in and around the area had not been considered;
possible assumptions that might be made when entering such a building had not been
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reviewed and there was no attempt to understand what risks existed with the decisions
being proposed by the FE.

These intertwined variables, combined with the complexity of fire engineering manifest as a
complicated scheme for analysis. Setting aside everything, this project also a challenging
project simply because it spawned many issues that I had not encountered before in my career
(e.g. appraising a fire engineered solution) and because of the actors involved – the latter is
something that has not been considered in any appraisal/definition of ‘complex buildings work’
(HSE, 2023b).

The constrained word limit confines this assessment to an overview of the subject matter
delving into the procedural, material, regulatory and behavioural complications associated with
fire safety in complex buildings. Arguably, it is also confined to my own knowledge limitations
and that of the material that was presented for the building application submission. The FE did
not, in my opinion, offer a sophisticated analysis of the problem preventing a more in depth
focus into the subject; this may have allowed for a broader exploration of the theoretical
principles spawning from the post war studies (Law 2023) and the work of Ingberg concerning
‘fire severity’ (cited by Evans et al 2001 and Harmathy,1974) and how these concepts manifest
in the real world.

A timeline of events is captured overleaf in Figure 5 for the readers understanding. It can be
seen that the course of the proceedings would not follow that which is shown in Figures 3 and
4.

Figure 5: Flow chart of events (Carter; 2023).

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Events are further complicated by the number of actors involved - and only a simple account
of events can be offered in this study.

There was intervention from three different fire officers during the course of proceedings.

• Officer 1 originally met with myself and the client on site to review my concerns and
offer advice. Officer 1 did not perceive any issues under the RRO with the incorporation
of an L1 system as a mitigation feature (the officer’s suggestion).
• Officer 2 would assume the role later in the build when a formal consultation was
launched with the FA. They did not wish to engage in the process until the client had
fully developed a compliant strategy but disapproved of the scheme.
• Officer 3 would intervene, following an appeal from myself, to offer fire engineering
advice, so that I could understand what operational complications would arise from the
proposed strategy.
• Several agents were involved. This report is unable to probe deeply into proceedings
but, as an overview, agent 1 initially developed a strategy following my request for
detailed plans and specification. Agent 1 would later be disposed of in favour of Agent
2 who would work alongside a newly appointed FE to expedite matters.

The design concept would encompass many revisions. Figures 6 and 7 depicts one of the
early proposals created by the Agent 2. It was evident that the compartmentation was not a
consideration at the time, as such, it is not shown. A later revision of the fire engineered report
(one of many) is contained in Appendix A. This edition captures later strategies which
incorporate elements of compartmentation and fire protection to the staircases. It was only
the threat of enforcement that finally spawned a solution which would include fire protection to
the mezzanine and dismantling of the tiered racking system to form a single storey mezzanine.
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1B - Justify your conclusion why the work identified was deficient.

Evidence your view through assessment of relevant documentation
and research/investigation.

Building Regulations ‘are minimum standards’ (Planning Portal, 2022). ‘Those carrying out
building work… are responsible for ensuring that the work complies’ (CICAIR, 2022). There
was no design concept or documentation to enable a compliance assessment. A supporting
account alone from the AI outlined how the proposals could potentially be justified adopting
fire engineering (see RIBA, 2021; Regulation 19, BAIR 2010) but no plans certificate had been
issued (BCA, 2023).

B3 of Schedule 1 is a functional standard requiring a structure to maintain stability ‘for a

reasonable period’, Figure 8 (BA, 1984). Allied to this is Regulation 7, controlling materials and
workmanship (MHCLG, 2018.) The ADs provide supporting guidance on how the requirement
may be satisfied ‘in common situations’. Importantly, they may not be appropriate for unusual
buildings (MHCLG, 2020, p22). This is reinforced in a DLUHC (2022a) circular reinforcing the
expectation that unusual designs should be challenged.

ADBV2 (2019) establishes performance classifications which are evidenced through the
application of European/British Standards which outline the test criteria to be followed. Three
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accepted means of verifying compliance are cited, Figure 9 (Appendix B, DLUHC, 2022b). In
the absence of any nominated standard I applied the guidance within ADV2 to reference my
plan appraisal as ‘proof of compliance with such a document may be relied on as tending to
negative liability’ (BA, 1984, s7) but predominantly to illustrate that the scenario was unusual
(see piii ADBV2, 2019).

Elements of structure are required to achieve a minimum level of fire resistance, expressed in
time, determined by location/occupancy and height. This is a measurement of load bearing
capacity, integrity and insulation (REI) following BS 13501-1 (2018). The provisions for the
racking (a structural frame/floor) with a height of 12.7m requires 90 minutes (Table B3/B4).

Turning to BRE Digest 487, four methods for achieving fire protection to steel structures are
cited (Bailey, 2004).

1. Passive protection,
2. Encapsulation with concrete supported by recognised design guides,
3. Design calculation to demonstrate ‘an element is able to satisfy the relevant criteria of
the standard test in order to satisfy the design fire resistance needs’ (Stollard and
Johnston, 1994, p107),
4. Finite element modelling.

In the absence of any data to inform the decision-making process, item 3 emerged as the only
possibility for exhibiting compliance for the unprotected members.
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The digest cites Eurocodes 3/4 which covers the methodology for concluding the failure of
steel in a fire, calculated applying either ‘fire resistance’ utilising a test furnace or through a
more complex methodology analysing a ‘natural fire’ through the scrutiny of specific:

• loadings (fire and structural),

• ventilation and
• temperature profile,

(Wainman and Kirby, 1987) further exemplify the intricacies associated with steel fire
performance identifying the determinants of fire outcomes, including: restraint, geometry,
material quality and exposure (see also Newman, 1999; Paroc, 2018). This precludes any
possibility of the existence of proprietary certification for an unprotected steel frame through
an accredited UKAS body. A ‘declaration of performance’ would not be able to account for the
multitude of variables that require a bespoke assessment (see Blackmore 2012; Colwell,
2016). Regulation 7 also establishes a need to demonstrate the adequacy of a material for its
proposed function during changes in environmental conditions which would encompass
temperature changes in a fire where a material is expected to perform a designated function
(MHCLG, 2018, p6).

Importantly, there was no data to inform a decision and it was also apparent that justification,
through the application of approach 3 (applying the ‘fire resistance’ methodology), utilising
standard test variables for unprotected steel, would not achieve ratings greater than 30
minutes resistance meaning, this could be discounted (Bailey, 2004).

I would then turn to exploring the feasibility of applying BS9999 applying a ‘risk-based design
[to]… take account of varying physical and human factors’ (BSI, 2017, px). In doing so, very
broad assumptions were made on my part, concerning aspects such as fire growth (Figure
10), which would need to be substantiated through the submission of evidence. It would
immediately be identified that an A4 Risk profile is outside the scope of the guidance without
some form of fire suppression. For completeness, if some form of fire risk assessment could
have validated an A3 classification, or if fire suppression had been introduced, a 90 minute
REI would still have been required under this code (Table 23, BSI 2017) irrespective of the
ventilation conditions.
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Finally, it should be borne in mind that B3 is not an individual component, it interacts with other
fire safety requirements to deliver a holistic approach to fire safety (see Holland et al, 2016,
Stollard and Lawrence 1994). In particular, the risk associated with search and rescue
operations was a concern and had not been scrutinised through any consultation with the FA
(RRO,2005).

In conclusion, reasonable provision had not been provided in my opinion.

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1C - Evaluate how the solution would be proposed and remedied.

It was important to exercise professionalism, ethics and to not assume design liability for the
solution. CDM 2015 advises that ‘designers can be…anyone who specifies and alters designs
as part of their work’ (HSE, 2023a). Tortious liability also exists through a succession of
caselaw including Donoghue v Stevenson (1932), Anns v London Borough of Merton (1978)
and Murphy V Brentwood DC (1991), to name but a few. Liability can encompass physical
injury, damage and extends to negligent statements (see Hedley Byrne & Co Ltd v Heller &
Partners Ltd, 1964) which can amount to economic loss (cited by Adriaanse,2007). ‘The duty
of [BC] is to provide an independent third party assessment’ (CICAIR , 2022).

Respecting these principals and my obligations under the RC to support the client, I met with
the service user before presenting an appraisal of the issues, identifying possible solutions
that might be explored (arguably, assisting beyond my duties) but guided by the designers –
(see DBIS, 2014). These paralleled that illustrated previously and covered in Steel for life
(2020). This would instigate a series of non-code compliant submissions - see 0.9 ADB vol 2
(DLUHC, 2022b). Unfortunately, it was only the threat of enforcement that instigated the
development of a fire engineered methodology, deterring positive engagement. This would
need to follow the framework in BS 7974.

Communication is important in facilitating decision-making and to explore solutions. I was keen

to promote dialogue and early engagement with the FA to understand the operational
implications associated with the design. Regrettably, an invitation to attend a design meeting
was declined until the scheme had been developed; this was in part, because apprehensive
concerning liability and inexperience.

This impeded my abilities to offer deeper design evaluation due to my limited knowledge in
this field. Of particular concern was the risks to firefighters and how they would be known. This
would be one of many questions put to the design team for addressing. Debatably, this
hindered the process and conflicts with the procedural guidance where early engagement with
the FA is recommended (see 4.2.2. LABC, ACAI, NFCC (2020). It was only later in the design
development that formal discussions took place between myself and the brigades FE to offer
a third party review. (see CROSS, 2022; Warringtonfire, 2023)

English (2013, p12) writes that ‘it’s widely accepted that the main fire risks to life safety in
small buildings arise during the evacuation periods when heat and toxic products spread
rapidly throughout the building’. He acknowledges that disproportionate failure of a structure
is sometimes a ‘secondary concern’ for fire engineers particularly where there is no sleeping
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risk. This ideology (the belief that MoE is the prevailing principal) appears to be prevalent in
a variety of literature concerning fire engineering and is somewhat at odds with Schedule 1.

In our example, it may be reasonable to assume occupants would be ambulant, alert and
familiar with the environment because of the work activities. Furthermore, the premise is
regulated under the RRO (2005) where risks are expected to be competently managed. It
therefore might have been acceptable to conclude that reasonable provision had been
afforded with the availability and length of travel coupled with low occupancy numbers.

The saliant point is that it would be me making this case rather than justification through
qualitative assessment (HMFSI, 2004) deliberated within a strategy, following a defined
framework referencing BS 7974 (2019); this meant I would be assuming design responsibility.
Instead, I sought to challenge the report where it departed from the guidance or where it was
silent on matters (Law, 2023). Indeed, the report was confined to simplistic statements
confirming compliance with ADB (where this was the case) and was plagued by conflicting
statements throughout. There was no analysis of a management strategy, evacuation times,
fire loads/spread of flame or the risk of premature collapse that might have affected the
compartment wall/stairs; furthermore, it failed to quantify the merits of the mitigating L1 alarm
system.

The current expectation to offer impartial

guidance and serve as an independent third
party checker germinates complexity
particularly with the communication of defects.
Certainly, concerns were identified but I
believed it was their responsibility to debate in
turn each departure to reason the solution as
illustrated in Figure 11 (BSI 2019, p 14).
Complicating matters is the inevitable human
variables that feed into such situations. Of
course, any assessment should be impartial
and factual, nevertheless, the attitude of an
actor, particularly where this may be negative
or obstructive, can instil scepticism which
further thwarted my confidence with the
proposals, particularly as the fire strategy
would later be led by the designer (see LABC,
2023a, Law 2023).
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We reached an impasse where a valid case would not emerge. A reminder of design liabilities
would compel the designer to progress the project, culminating in a solution that entailed
reducing the height of the racking to below 5m and providing fire protection to the two storey
mezzanine.

1D - Validate your reasoning for accepting the solution.

The mezzanine protection would take the form of a fire rated ceiling evidenced in the form of
test certification to enable interrogation of the Declaration of Performance. Regulation 7
outlines the criteria for accepting a product. In this particular example, it followed a harmonised
EU product standard (LABC 2023f; BRE 2008).The document was produced by
Warringtonfire and was correctly formatted (LABC 2023e). The organisations accreditation
number can be populated into the UKAS database where it can be seen that the laboratory is
approved to undertake testing in accordance with BS EN 13501-2. By inspection and material
receipts, it would be demonstrated that this had been installed correctly. A fire resisting ceiling
should ‘not be easily demountable’ but the system had been approved without clips and it was
a managed premise. The columns would be protected using a detail adopted from the White
Book 2022 p388; The FE stated that this achieved 90 minutes fire protection.

At the time, I had accepted this statement without further scrutiny on the premise that it was
an approved detail and because it had been presented by the FE. Random areas were
examined on site to check the spacing of fixings on the premise that reasonable steps needed
to be taken on my part to ascertain compliance (Cooper, 2004).
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This solution could not be adopted for the racking system. It was neither desirable or
technically feasible, primarily, as purported, because of the extent of the frame members.
Originally, the proposition by the FE was that this was not controllable under the BR – this was
rejected. The definition of a multistorey in Appendix A, ADBVol2 (2019) would not offer any
definitive guidance but the information in paragraph 7.6 would serve as a supportive reference.
It advises that fire resistance in Table B4 may be relaxed if the structure conforms to the
criteria in paragraph 7.7. By inference, our example would therefore require protection and,
in consultation with the FA, we deemed this to be a storey.

The fire report failed to evaluate the risks associated with the departures offering no rationale
for acceptance of the scheme, void of any comparative analysis and omitting any qualitative
or quantitative judgements (HMFSI, 2004). A core concern was the risk posed by the possibility
of premature structural collapse which would likely penetrate a REI 90 fabric fire barrier and
the protected stair. The increased risk for firefighters operating on an unprotected floor had
also not been probed (see ODPM, 2004). Figure 13 provides a simple overview of the sort of
analysis expected (Christian, 2003, p26).

Parallels can be found in CROSS UK Report 1029 (2022), namely the methodology of the fire
engineer to justify departures in structural fire integrity. In this example, the deviation from the
regulations were reasoned through the production of a Required Egress Time Model alone,
demonstrating that the building occupants could evacuate in under six minutes. In doing so, it
failed to critique the implications of not affording fire protection, compartmentation and spread
of flame, particularly concerning firefighting activities and ‘the holistic nature of the functional
requirements’. The case exemplifies the importance of consultation with stakeholders, such
as structural engineers, to thoroughly scrutinise outcomes and a need for third-party peer
reviews. In our example, a critique of ASET times had not been presented and there had been
no dialogue with a structural engineer to evaluate the risks. I am also assuming that operatives
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would be ambulant, but it is not beyond the realms of possibility that activities, such as
stocktaking, may be performed by persons with mobility issues.

Report 921 pertaining to hot/cold reeled steel structures is another example again highlighting
the importance of engagement with all consultants, particularly when there is a requirement
for a building to maintain integrity after burnout (CROSS, 2021).

Peer reviews are the expected methodology for checking an engineered strategy; guidance
on the level of competence expected for such reviews is offered below (Christian, 2003, p25).

What constitutes a minar/major variotions is subjective along with my own abilities. Yes, I am
able to to offer challenge but I was very aware that I was unfamiliar with the content of an
acceptable solution - see Table 2, BS 7974 (BSI, 2019); BICoF (HSE, 2023b) has now been
published and provides clarity on the competency expectations for such scinarios. Consiocus
of my own limitations I engaged the input of another FE from the FA to support the process
(see also 4.1 BSI, 2019). It would be concluded that my initial observations were reasonable
and that compliance had not be demonstrated with the BR but the FA considered the
provisons, for the purposes of the RRO, were defensible on the premise that fire personnel
would not be comitted to fire fighting activities.

In the absence of detail, and the repercussions of enforcement, the designer proposed to
reduce the height of the remaining structures to below 5m.
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Suggestive comments by the AI have not encouraged early design intervention, frustrating the
process, particularly as there was no specification; unfortunately, approval prior to
commencement is not a necessity and remains so in the future for most buildings (see Pedro
et al, 2010; BSA, 2022). In pursing an engineered solution, the scheme would be subjected to
qualitative critique which will vary between actors, exemplified with my differing interpretation
and the conflicting advice received from the FA (showcasing differing attitudes regarding risk).
The difficulties that have arisen highlight why performance specifications (in lieu of prescriptive
notes) carry additional risk (RICS, 2013; Swaddle, 2021; Kendall, 2023) .

It is debatable whether I should have offered more certainty concerning the plausibility of
exploring a FE solution, particularly as significant resources would have to be attributed to a
solution pursuant with BS 7974 and that, already, the design was lacking in intent. As I would
learn, FE is a dynamic and complex process requiring cooperation between all stakeholders
where no single problem can be viewed in isolation. I engaged with participants in a timely
manner conveying my analysis for collective scrutiny and transparency, as the lead authority
(Tricker & Alford, 2018); when the FA originally endorsed a solution lacking rationale, I correctly
refrained from capitulating my stance.

The complexity of the solution had possibly been underestimated on my part and its form was
not understood to me at the time - perhaps something I should have, at least, headed a
warning. It encompasses facets such as ‘burnout’, standard/actual fires, fuel loads and the
performance of materials. Khan et al (2021, p42) showcases the variety of modelling available
for structural fire resistance (Figure 15) culminating in prescriptive and performance-based
methodologies (Charlier, 2001). Chitty (2010, p2) appraises the multiple approaches to design
involving a range of inputs from calculations derived from standards through to complex
modelling. As with any aspect of design, it is not foolproof and ‘there is the possibility that a
model can be misused and give unsafe results. This may be due to an ill-informed user who
does not understand the model’s capabilities, poor documentation, or the use of inappropriate
input data’. Care in how information is presented and disseminated by others is important as
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it can manifest in unpredictable outcomes in a fire and impact on firefighter safety (NFCC,
2023; ODPM, 2004).

Matters were further frustrated when the FA inexplicably conceded their challenge. A series of
exchanges between the FE/FA debated some of the concerns but the content lacked detail
and was not audited within the FS (see Regulation 38, BR 2010). A warning was also headed,
despite the omittance of an SSRI (see NFCC, 2023 and Fraser-Mitchell and Taylor 2014),
confirming that, in the event of a fire, personnel would not be deployed to tackle a fire - this
is seemingly at odds with the duty to fight a fire (Sec 6 FRSA 2004 ). Had ASET times been
proven acceptable, perhaps there was scope for accepting the scheme on the premise that
safe escape was affordable (Purser 2004, Lennon, 2004)? Certainly, had I known that PIBS
were an established practice, complimented with PEEPS, it may have offered reassurance
with some of my concerns (NFCC, 2020; DCLG, 2015). Nevertheless, Angus (2023)
advocates that B2 is the prevalent matter concerning FE and this had not been properly
evaluated; interesting, this conflicts with the teachings of many that B1 should be the primary
focus (Cooper, 2004).

The free availability of BS was also a hindrance, impeding my research. Nevertheless, I

interrogated what I could source as whilst this was not my responsibility, it was incumbent on
me to partake in CPD and explore my concern stemming from the affiliation between fire
protection and compartmentation, such is the complexity of the issues at heart, to further my
argument. It can be seen that there is a wealth of free academic material available but,
ultimately, decisions boil down to the skill and judgement of the stakeholders.
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Poignantly, I was unable to identify a definitive source addressing the integrity concerns
associated with a potential breach of the adjacent fire curtain compartmentation following a
premature collapse of the floor. BS 8524 covers fire-resistance assemblies and includes a
100Nm impact test (Smith, 2023), simulating the force of a person (A1S Group, 2023), far
below that which could be experienced. The FE was defiant this was not controllable, and no
analysis was offered. I could only draw upon a parallel referenced in SCI P313 where a citation
exists concerning the need for a non-load bearing fire wall to maintain its stability in the event
of a roof collapse (Simms and Newman 2002, p 288).

To broaden the scope of scrutiny, the scheme would be presented to the LATP, mainly, to
ensure I was not acting in ultra vires but also, my challenge was impeded by the contrast in
professional qualifications between myself and the FE and my department’s inexperience to
competently peer review the various arguments. Feedback was limited but supportive. This
showcases the importance in developing professional networks for support (LABC, 2023d)
and to recognise ones’ limitations.

There is an ideology to facilitate clients and adopt a consultative approach to enforcement

which can be incongruous with responsibilities in the legal framework - significantly, the lack
of powers enjoyed by BC to control the sequence of events/work, succumbing to the mercy of
the skill, organisation and care of those undertaking the work (LABC, 2023b); this is a familiar
concern and one identified by (Hackitt, 2018). Communication would be through recorded
meetings and emails to convey matters and offer direction where possible, referencing
evidence/examples; it was also borne in mind that this may escalate to formal intervention
necessitating a clear audit trail (LABC 2023c). There was a repeated failure to respond, and
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items would be dismissively rejected. It may have supported my stance had some of the
information within this assignment been referenced as a means of educating (e.g. Cross
Reports and Law, 2023). In doing so, it may have supported a behavioural change (LABC,
2023a) to induce a more fruitful exploration of solutions.

It would be reinforced that my role would be one of recording until evidence, verifying
compliance, was submitted…it proceeded at risk (Wadood, 2020, p39). As part of this
reflection I discovered, having probed deeper, that there was a significant yet hidden caveat
pertaining to the fire engineer’s endorsement of the column protection that I had overlooked.
The steel Hp/A factor and not been checked. Referencing Promat (2017) to review BS EN
10210 steel sizes, we can see that, assuming a worst case scenario, a 120 x 120 member
affords 260 m-1, meaning that 60 rather than 90 REI was achieved. Fortunately, this is no
longer relevant following the amendments but it demonstrates why suitable time and resources
need to be apportioned to workload allocations and reinforces why it is important to follow up
site inspections with written correspondence (DCLG, 2012, p2).

On reflection, my role was to challenge rather than guide the design, therefore I could never
reasonably foresee the required input. I believe reasonable provision may have been possible
but such a case has only been presented through this analysis rather than the strategy.
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Adriaanse, J., 2007. Construction Contract Law. The Essentials. 2nd ed. Basingstoke:
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British Standards Institution, 2013. BS 8524-1 Active fire curtain barrier assemblies - Part 1:
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Appendix A

A copy of one of the fire strategy. This would undergo many revisions.
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