RIBA proposed “Fire Plan of Work”

27 Sep 2018

On the 18th of September RIBA launched a consultation on their proposed Plan of Work for Fire Safety.


The RIBA plan of work is used throughout the construction industry to define the various stages of a project and to describe the deliverables expected from the various members of the design and construction team at each stage. The inclusion of fire safety is therefore a logical addition to the Plan of Work. Rather than define current practice the proposed plan of work attempts to implement the recommendations of the Dame Judith Hackitt’s report, “Building a Safer Future – Independent Review of Building Regulations and Fire Safety: Final Report”, which was published on 17th May 2018.

MPA The Concrete Centre Supports the aims of the proposed Plan of Work. The inclusion of the Gateways, proposed by Hackitt, and the deliverables required from the various members of the team to pass each gate, is important in developing the detail around Hackitt. There should be debate between the professions as to where responsibility for certain activities is best held and the proposal forms a basis to start that debate. It is however important to note that ultimately the level of detail required at each Gateway can only be agreed once the Joint Competency Authority proposed by Hackitt, or similar, is formed.

The proposed Plan of Work includes the Users/Residents in the defining of the brief and the concept design. This is important for refurbishment projects and the proposal suggests that for new build focus groups of potential users should be consulted. Whilst the use of focus groups will be helpful for some types of housing in many private developments the market effectively defines the users needs and there needs to be some flexibility around this. Conversely the focus groups should not be relied on to ensure basic levels of safety are provided.

Prior to the start of construction approval at Gateway 2 is required. Gateway 2 requires “detailed plans” that demonstrate that the “fire safety design is complete”. It is acknowledged in the Plan of Work that to reach this level of design specialist contractor design will be required. What is less clear is the level of detail required for that design. It is not unusual for specialist contractors to work with “standard detail” drawings which are then modified on site to match the actual conditions and, when required, record drawings made.

This reflects the difficulties in achieving the very high level of co-ordination required to enable all the details to be drawn out prior to construction. However, it is often at the non-typical interfaces where non-compliances occur. There is a balance to be struck between the level of detail provided at Gateway 2 and risk to future gateway approval if generic details are used. The fire protection of concrete structures is normally fully defined by the Structural Engineer’s drawings and does not rely on early involvement of specialist contractors.

This significantly reduces the risks associated with co-ordination, delays to get approvals and site-based changes. One area that the proposed Plan of Work does not adequately consider is the need for a robust change control process during construction. The Hackitt report defines two types of change and envisages that “minor” changes will be agreed post construction, at the Gateway prior to occupation, whereas “major” changes would be agreed during construction. Hackitt does not define “minor” nor “major” and to some degree this will be dictated by the risk associated with waiting until completion before attempting to get agreement for the change.

The responsibilities for this change control process should be set out in the plan of work. There are only a few parameters that define the fire safety of concrete structures and they are well understood so the risks of late changes to a concrete structure are relatively easy to manage.

Post occupation the Plan of Work sets out the responsibilities of the team in terms of maintaining and updating the Fire Safety Assessment. One activity missing from those listed in the proposed Plan of Work is the need to inspect flats to ensure that fire safety precautions are still effective. For example, the removal of door closers would affect the safety of more than just the occupants of the flat concerned, as would damage to the fire protection to structure. As the fire protection to concrete is both integral with the structure and robust it presents a lower risk of damage in these ongoing assessments.

The proposed Plan of Work incorporates many of the recommendations of Hackitt and starts to provide the necessary detail as to how her recommendations may work. Whist some difficulties and omissions are discussed above this is an important document to start the debate on how the Hackitt report can be implemented.

Principal Structural Engineer - Tony Jones