FIRE SAFETY (ii) – Means of Escape for disabled people – new report…

The aims of the project were to assess the current provisions in Approved Document B (AD B) and review alternative approaches in providing means of escape for people with disabilities.

(Note: MHCLG states that any views expressed in the report are not necessarily those of MHCLG.)

The report’s review of current regulations and guidance:

Current regulations and guidance were reviewed, not only for means of escape from fire (such as AD B, Fire Safety Risk Assessment Supplementary Guide Means of Escape for Disabled People (Regulatory Reform (Fire Safety) Order (RR(FS)O) Guide for disabled people), and BS 9999:2017), but also other documents including Approved Document M Access to and use of buildings (2015), and the Equality Act 2010.  

Approved Document B (2019) contains little in terms of guidance on building design or management specifically addressing means of escape for disabled people.  In paragraph 0.8, there is mention of Inclusive Design and sections on Detection and Alarm, Emergency Lighting, Refuges and Management.  In common with the approach throughout AD B, these sections refer the reader to other documents for guidance (for example British Standards for alarms and lighting, BS 9999 for design, management and use of buildings).  In order to improve AD B, it may be necessary to also revise the cited documents to produce a consistent and coherent set of guidance that covers any identified gaps.

The AD B guidance (AD B sections 3.4 to 3.9) with respect to the number and sizing of refuges is questioned in light of the literature review and Focus Groups’ feedback on current demographic trends, use of buildings, potential users of refuges and implications of inappropriate sizing.  The suggestion in AD B clause 3.4c that the number of refuge spaces does not need to equal the number of wheelchair users who may be in a building since a single refuge may be occupied by more than one person during the evacuation procedure should be questioned also in light of literature review highlighting reliance on management and resources required for assisted escape.  The idea that one user will enter a refuge as another leaves, is based on the assumption that the first user will be efficiently removed from the refuge before the other user needs to use it to remain safe, for example if the fire is on that floor.

AD B mentions that evacuation lifts may (not should) be used, and again refers to BS 9999 for further details.

As examples of the above:

• The first two points are closely linked.  Approved Document B has a short paragraph on Inclusive Design (paragraph 0.8), but this does no more than state some very general principles.  In order to actually undertake such a design, more guidance would be needed.  There is a lack of such guidance in a single cohesive document that AD B can refer to.  At the very least, Approved Document M should be mentioned at this point.  Note that Sport England has some helpful management guidance under development, which builds on the approach taken in the RR(FS)O Guide for disabled people on PEEPs.

• AD B covers provision of refuges (paragraphs 3.4 to 3.9 and diagrams 3.1 and  3.2), but the number and/or size of these may be insufficient (the largest wheelchairs may exceed the minimum size of a refuge area, and such a refuge could certainly not accommodate two at once).  By linking the refuge size to a wheelchair, this may lead to misconceptions that refuges are only for wheelchair users.

• Provision of communication systems for refuges (paragraph 3.7) may be insufficient (as one Focus Group participant stated, “if the comms link is to the reception desk, what happens when reception closes at 5pm?”), although this may be more due to failings in building management rather than AD B per se.  However, it does raise the issue that AD B should encourage building design that does not rely on management to fix problems.

• Relying on the use of evacuation chairs presents many challenges, for example, some people are unable or unwilling to be moved in this way, and they are not suitable for some steps. Evacuation chairs are not mentioned in AD B (it would be a management decision to provide them and ensure sufficient trained operators); however, they are mentioned in BS 9999: 2017, which is referred to by AD B.

• Evacuation lifts are mentioned by AD B (paragraph 5.32, and reference to BS 9999: 2017), although the tone is permissive rather than encouraging designers to adopt them.  There are no recommendations on the number of lifts that might be needed for a particular population of building occupants, for example.  Instead, the management plan is left to make the best use of such facilities that are available. The type of evacuation lifts described in BS 9999 are suitable for the assisted evacuation of a building since the lift described needs to be controlled by a lift driver to go to the floors from which people are awaiting evacuation.  However, there may be problems if buildings do not have in place trained people who can take control of the lift and manage the evacuation of people unable to use the stairs.
• Building management is covered by a single paragraph (paragraph 0.6) and then sporadically mentioned elsewhere.  There is reference to the Regulatory Reform (Fire Safety) Order 2005, but no reference to BS 9999 in this context, despite the Standard covering design, management and use of buildings.