DFS 10 - Residential Sprinkler Association

My apology for the late submission of this response to your letter of March 19^th inviting comment on the proposed National Assembly for Wales (Legislative Competence)(No7) Order 2008, relating to fire sprinkler systems in new residential premises.

I, as the Secretary General of the then Residential Sprinkler Association, gave evidence on several occasions to the Assembly prior to the publication of the “Wired for Safety” report in 2002. Together with my then colleague Roy Young, we gave presentations and demonstrations of fire sprinkler effectiveness to Assembly representatives, and we were therefore pleased that the Assembly was prepared to be so innovative and support the use of fire sprinklers in domestic and residential premises. We were equally disappointed that the initiative seemed to stall, apparently on the issue of cost. I am therefore most pleased that the initiative has been rekindled and am hopeful that the previous problems can be resolved.

Referring to your particular questions-

We would concur with the Fire Brigades Union and the National Fire Sprinkler Association that legislative competence should be conferred on the Assembly for all of the reasons given. The safety of the people of Wales should after all be the prime responsibility of the Assembly and the Assembly should therefore have the legislative power to do all that is necessary to achieve that.

I do not believe we have the competence to comment on the terms of the proposed Order.

Within the wider Fire Safety Industry there is a distinct lack of clarity as to exactly what constitutes a Fire Sprinkler System. During the past 10 years we have seen a variety of systems introduced that have no background of independent testing or recognised Standards. On the other hand we also see extra restrictions added to existing sprinkler standards that simply serve to drive up costs with little or no improvement to the reliability or efficacy of the system. We would therefore hope that this time the type of sprinkler system will be clearly defined.

Residential Sprinkler Systems are described in BS9251:2005, which evolved from DD251:2000, first published 8 years ago. Unfortunately the Standard contains restrictions on room size and building height that were introduced without any supporting evidence and we would therefore contend are inappropriate. In the same vein, sprinkler flow requirements and areas of coverage for sprinklers are specified in the Standard that fly in the face of the Manufacturers’ and the Approvals Body’s test data and specifications - and we contend that these are inappropriate also. The removal of these unnecessary restrictions will reduce the cost of installation substantially and would therefore, we hope, go a long way to resolving the problems encountered after the publication of “Wired for Safety” referred to above.

Another major (and probably greater) factor in excessive cost is that charged by the water companies. In 2004 The Fire Prevention Association published a document “Guidelines for the Supply of Water to Fire Sprinkler Systems”, which was the result of several years of consultation between the Water Industry and the Fire Sprinkler Industry. Amongst other matters the document recommends sprinkler systems should be connected directly to the mains whenever possibly, both for reliability of water supply and minimal cost of connection.

We understand that the water authorities in Wales are not prepared to abide by this agreement and are insisting on a pump and tank arrangement being installed for every sprinkler system. Moreover they are also charging considerable sums to make the connection; considerably more than could be regarded as simple recovery of cost as was set out in the Water Act. To put this into some context – whereas the cost of a sprinkler system in a 3-bed house might be in the region of, give or take, £2,000, the cost of the water supply can be at least as much again and has in many cases exceeded this by a factor of 2 or more. Thus the water supply, that should cost a few hundred pounds or less, has ended up costing several thousand.

Whenever legislation is introduced we have seen attempts to circumvent its requirements by “interpretation” of the wording. For instance, in some countries legislation has been introduced to require sprinklers in buildings over a specific height. This has led to buildings being built that are just smaller than that size and/or installation of the sprinklers only in that part of the building that exceeded the limit; neither of which were the intention of the legislation.

A similar thing has occurred in the UK with the legislation requiring sprinklers in single storey retail premises. In some cases stores have been artificially subdivided and in others sprinklers have only been fitted to the part of the store that exceed the limit of size.

We therefore feel that these terms should be clearly defined. Fortunately  there are widely-accepted definitions already in existence. We would therefore suggest that the same definition for “new residential premises” is used as is in the Building Regulations and that the sprinkler systems be defined as complying with BS9251:2005 or such succeeding British or European Standard as is appropriate. In fact we would go further and suggest that sprinkler be required in all new residential premises and also those being modified and which require approval under the Building Regulations.

We would also concur with others who suggest that the range of buildings to which the Order refers should be enlarged to include all the highest risk premises. As such BS9251:2005 contains a useful list of such premises as does the latest version of the Building Regulations. In our opinion top of that list should be Care Homes.

Again our apologies for the lateness of this submission, which was caused by circumstances beyond our control. We understood that responses were required by April 25^th but see that the committee is actually hearing evidence tomorrow April 22^nd. I would have gladly attended if required but it would seem time is now too short.

If we can be of any further assistance please let me know.

Yours Sincerely,

Sir George Pigot, Bt.

Administrator