Ashleigh Timms

Dear Mr Irvine,

REGULATION 28 PREVENTION OF FUTURE DEATH REPORT (1) REF: 108578 I am writing in response to your report dated 26 April 2022 (under the above reference) concerning the death of Ashlie Clare Liana TIMMS, which was initially sent to Deputy Assistant Commissioner Stephen Norman who gave evidence into the inquest. In your report you noted six areas of concern which were:
1. The operator of the premises failed to ensure that staff on duty were competent to carry out a fire evacuation. Despite reflection and remediation in policies, processes and training multiple staff members who gave evidence to the inquest, remained unable to describe the proper action to take in the event of a fire alarm.
2. Fire alarms in three units operated Sequence Care Group remain non-compliant with the 2013 British Standard guidance, which recommends that they should have a link to an Alarm Receiving Centre (“ARC”) which automatically contacts the emergency services when a fire alarm is activated.
3. The London Fire Brigade conducted fire safety audits at the premises which assessed the unit as displaying the highest standard of fire safety compliance. These findings were found to be entirely incongruent with procedures, equipment and staff training in place before and at the time of the fire. The London Fire Brigade have reviewed and changed processes since 2018 but they remain incomplete.
4. No clear and practical guidance exists on how specialist housing operators should manage the use of high-risk electrical devices such as portable electric fan heaters.
5. No clear guidance exists regarding the fitting of digital keypads on doors in specialist housing.
6. Insufficient emphasis is placed upon recommendations contained within British Standards regarding automatic connections to ARCs in fire alarms fitted in specialist accommodation. It may be helpful to note at the outset, that for matters of concern numbered 4, 5 and 6, the Secretary of State for the Home Office is under a statutory duty in Article 50 of the Regulatory Reform (Fire Safety) Order 2005 (the FSO) to “…ensure that such guidance as he considers appropriate, is available to assist responsible persons in the discharge of their duties…”. Insofar as the matters of concern relate to parts of premises to which the FSO applies, it may be appropriate for these concerns to be drawn to the attention of Home Office ministers. My understanding is that the Home Office are currently engaged in a programme of refreshing national fire safety guidance documents that are used by both responsible persons and the authorities enforcing it. Similarly, the Secretary of State for the Department for Levelling Up, Housing and Communities has responsibility for the Housing, Health and Safety Rating System enforced by local authorities and which is applicable to the private domestic areas of many residential properties (where the FSO does The London Fire Commissioner is the fire and rescue authority for London

Date: 20 June 2022

not apply). The Secretary of State has a duty to provide guidance on the assessment of hazards and enforcement against them in section 9 of the Housing Act 2004 and also provides other guidance for landlords and property-related professionals. There is a need for all guidance on these matters to be co-ordinated, clear and readily available across all reasonable sources. Consequently, I would suggest that your concerns in this regard are also raised directly with the relevant Secretaries of State. I have addressed each of the matters of concern below:
1. The operator of the premises failed to ensure that staff on duty were competent to carry out a fire evacuation. Despite reflection and remediation in policies, processes and training multiple staff members who gave evidence to the inquest, remained unable to describe the proper action to take in the event of a fire alarm. This raises a concern that premises management is not compliant with duties under the FSO, in particular the duty in Article 15 concerning appropriate procedures to be followed in the event of serious and imminent danger to relevant persons. The FSO is a self-compliance regime with the duty for compliance placed firmly with the responsible person. As the London Fire Commissioner, I have a duty to enforce those regulations. In enforcing the FSO my officers must act in accordance with the requirements of the statutory Regulators Code. LFB Fire Safety Inspecting Officers plan to attend the premises shortly after the end of the 56 day reply period to conduct a regulatory audit under the FSO. This will consider whether there is compliance with the FSO including Article 15.
2. Fire alarms in three units operated by Sequence Care Group remain non-compliant with the 2013 British Standard guidance, which recommends that they should have a link to an Alarm Receiving Centre (“ARC”) which automatically contacts the emergency services when a fire alarm is activated. Regulators cannot directly enforce the recommendations of a British Standard unless it is cited as a required standard in relevant legislation or unless the arrangements actually in place can be shown to create a “risk gap” from the level expected by that standard. I understand the suggestion here was that the alarm did not include a link to an ARC because the premises had 24/7 staffing in place. LFB might consider this to be non-compliance with Article 13 of the FSO, although this would have to be considered in the light of the circumstances of an individual premises including the arrangements for staff training and testing of the arrangement. It would then be raised with the responsible person as part of any follow up to the regulatory audit. Making the recommendations of at least some British Standards directly enforceable is a matter that has been raised by other Coroners through regulation 28 reports with the relevant Secretaries of State, with support of the fire service. I would urge you to join them in to doing so.
3. The London Fire Brigade conducted fire safety audits at the premises which assessed the unit as displaying the highest standard of fire safety compliance. These findings were found to be entirely incongruent with procedures, equipment and staff training in place before and at the time of the fire. The London Fire Brigade have reviewed and changed processes since 2018 but they remain incomplete. I would firstly refer you to the statement of DAC dated 8 April 2022 and his live evidence to the inquest on 11 April 2022. In the year before the death of Ashleigh Timms, LFB had changed its policy on the vetting/review of fire safety regulatory audits by managers so as to include all audits of sleeping and vulnerable

sleeping accommodation regardless of the audit outcome. We have now undertaken a review of that element of policy and concluded that due to the ordering of paragraphs in the policy document a potential degree of ambiguity may have remained. That drafting has been addressed to place the matter beyond doubt and this has been promulgated to all staff working in the technical fire safety function. We have also amended our audit form to ensure improved justifications are stated for the overall scoring of an audit and for each article. This should better ensure there are records setting out exactly why the FSIO has deemed it to have been or complied with (or not). Over the course of the past two years LFB’s Central Regulatory Enforcement Group have been conducting bespoke training for regulatory fire safety team leaders on the management vetting of their team’s audit forms and Enforcement Notices to increase team leaders’ knowledge and skills. LFB has now brought in additional resources to assist with that and develop and roll out a new training package for all staff involved in the management vetting process. We expect to complete this over the course of the next six to twelve months. Deputy Assistant Commissioner Steve Norman drew your attention to work undertaken to educate staff on the risk arising in specialised housing and to our work running a series of external seminars for the managers of care homes. LFB’s Fire Prevention and Protection Department (P&P) are currently developing a new training needs analysis for LFB’s inspecting officers. Over the next six months P&P will conduct a full review of the training and continuous professional development (CPD) material used for all forms of vulnerable sleeping risk premises including care homes, extra care schemes and sheltered housing and supported living schemes. From this, over the next twelve months we will develop and roll out refreshed CPD covering the specific risks arising for these premises types. That CPD will be mandatory for all staff involved in the audit of these premises types and will form part of mandatory refresher training through our Development and Maintenance of Operational Professionalism (DaMOP) framework. LFB is also committed to applying the new national scheme of third-party accreditation of the competency of fire safety inspecting officers whose work involves the audit or provision of advice to higher risk premises. All such staff have achieved or are working towards an NVQ level 4 Diploma qualification after which they will be assessed though a new scheme operated by the Institution of Fire Engineers in conjunction with the Engineering Council. Achieving this level of accreditation for all Fire Safety Inspectors will take some time, potentially four to five years as there is currently a lack of approved assessors across the country. We expect the first tranche of Inspectors to be assessed over the coming 18 months.
4. No clear and practical guidance exists on how specialist housing operators should manage the use of high-risk electrical devices such as portable electric fan heaters.

Although there is some guidance contained in government approved and National Fire Chief Council guidance, we believe this is a matter that should be expanded on as part of the Government review of guidance to the public.

From the London Fire Brigade perspective, use of portable heaters forms part of the considerations under our home fire safety visits and the guidance documents we issue for fire safety in the home for example https://www.london-fire.gov.uk/safety/the-home/portable-heaters-gas-fires-and-open- fires/

We are currently reviewing our own guidance and I have instructed staff to include this issue in that review over the course of 2022.

We also operate a number of primary authority partnerships with housing providers and work with the G15 group of providers. Now that the inquest findings are available officers will highlight the issue to those we work with. However, you will recognise that under existing terms of lease or tenancy, the options for them to act in relation to their tenants may be limited and it is not something that my officers have a power to enforce.

5. No clear guidance exists regarding the fitting of digital keypads on doors in specialist housing.

Although there is some guidance contained in government approved and National Fire Chief Council guidance, I believe this is a matter that should be expanded on as part of the Government review of guidance to the public. However, the forms of locking devices used on the exit from a flat as a private dwelling is not something that falls to be regulated under the FSO. Therefore, LFB officers cannot enforce against it. This issue does arise from time to time in material and guidance produced in respect of ‘secure by design’. We will continue to press for guidance in that regard which does not adversely, or potentially adversely, inhibit escape from domestic premises in case of a fire emergency.

6. Insufficient emphasis is placed upon recommendations contained within British Standards regarding automatic connections to ARCs in fire alarms fitted in specialist accommodation. The ethos of the FSO is one of risk-based fire safety preventative and protective measures. Under Government guidance that does mean that it is not a prescriptive regime. Alternative means can be used to demonstrate compliance rather than adherence to a British Standard. As an enforcing authority we use British Standards as the benchmarks of good practice. However, we cannot necessarily enforce them unless a demonstrable risk arises from failing to comply with them. If that were to be the case, then we can and will continue to direct that the appropriate British Standard is followed. However, that cannot be done if alternative means to the recommendations of the British Standard (or other guidance) have been used and are found, on the day of inspection, to apparently be providing an equivalent level of safety. In the latter circumstances an enforceable level of risk would not have been identified and so a direction could not be given under article 30 of the RRFSO. The issue appears to be a lack of a direct enforcement mechanism for British Standards. That is a matter my officers have previously raised through the coronial system and with government. If a specific requirement is to be enforceable it will require legislative change. We will continue to advocate for this in appropriate cases as part of our ongoing work with government, other regulators and the sector itself. To summarise, along with the action already taken, LFB intends the following further actions:
1. Officers plan to attend the premises shortly after the end of the 56 day reply period to conduct a regulatory audit under the FSO.

2. A clarification of LFB policy expanding the requirement for vetting/review of fire safety regulatory audits by managers is to be issued to officers in the next few weeks.

3. Over the coming six months LFB will conduct a full review of the training and continuous professional development material used for all forms of vulnerable sleeping risk premises

including care homes, extra care schemes and sheltered housing and supported living schemes.

4. From this work in point 3, over the course of the next twelve months LFB will develop and roll out refreshed CPD covering the specific risks arising for these premises types.

5. LFB is committed to applying the new national scheme of third-party accreditation of the competency of fire safety inspecting officers whose work involves the audit or provision of advice to higher risk premises. We expect the first tranche of Inspectors to be subject to assessment over the coming 18 months.

6. Over the course of 2022 we will review our own guidance offering concerning portable electric fan heaters in premises such as these.

7. We operate a number of primary authority partnerships with housing providers and work with the G15 group of providers. LFB officers will highlight the issue of the use of high-risk electrical devices such as portable electric fan heaters to those providers we work with.

8. We will continue to press for guidance on fitting of digital keypads on doors in specialist housing that will not adversely, or potentially adversely, inhibit escape from domestic premises in case of a fire emergency. I hope that this satisfactorily explains the actions that have been taken and those which we will continue to take to address the concerns raised in your letter.

Dear Sir, Coroners and Justice Act 2009 Coroners (Investigations) Regulations 2013 Regulation 28: Report to Prevent future deaths (Ref: 108578) Re: Ashlie Claire Liana Timms, deceased As requested, I write in response to the above-mentioned report (Report) and particularly the concerns (Concerns) you have raised therein. By way of background, the National Fire Chiefs Council (NFCC) is the professional voice of the UK fire and rescue services (FRS) and is comprised of a council of UK chief fire officers. The NFCC is a membership organisation of FRS senior and strategic managers. Its main aims are to support FRS to meet the changing demands on resources and to maximise effectiveness by promoting consistency by highlighting best practice in the sector.1 For the sake of clarity, the NFCC is not an enforcing authority under the principal fire regulations relevant to the premises in issue; it does not have regulatory functions. The principal fire regulations applicable to the premises can be found in the Regulatory Reform (Fire Safety) Order 2005 (the Order).2 Article 25 of the Order provides—for the purposes of the Order—the meaning of an ‘enforcing authority’. One of the enforcing authorities within Article 25, is the fire and rescue authority, which is the corporate entity of the FRS pursuant to Section 1 of the Fire and Rescue Services Act 2004 (as amended),3 in which the premises are located.

1 Further information can be found here: National Fire Chiefs Council (NFCC) 2 See: The Regulatory Reform (Fire Safety) Order 2005 (legislation.gov.uk) 3 See: The Regulatory Reform (Fire Safety) Order 2005 (legislation.gov.uk)

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Enforcing authorities are required to enforce the provisions of the Order and any regulations made under Article 24 in relation to premises for which they are the applicable enforcing authority.4 In doing so, they must have regard [emphasis added] to guidance issued by the Secretary of State.5 Further reference to this statutory guidance is amplified hereunder. The NFCC, whilst not an enforcing authority under the Order, is able to contribute, encourage and steer, within reason, the strategic and operational functions, and activities of FRS, as they relate, among other things, to fire safety and protection, and the relevant statutory duties to enforce the Order. The following is provided to take account of each Concern. This regrettably requires, for the avoidance of doubt, repetition. The NFCC considers this favourable to assist with, among other things, future integrity of this response, should this document be later fragmented by design, or otherwise, and reproduced elsewhere. For ease of reference, the following uses the same numbering for Concerns as set out in the Report.
1. The operator of the premises failed to ensure that staff on duty were competent to carry out a fire evacuation. Despite reflection and remediation in policies, processes and training, multiple staff members who gave evidence to the inquest, remained unable to describe the proper action to take in the event of a fire alarm. The NFCC replaced the Chief Fire Officers Association (CFOA) which were a participant in the production of HM Government Fire Safety Risk Assessment in Residential Care Premises
20076. This document recognises, among other things, that relevant practical staff training, in evacuation procedures in the event of a fire, is vital in environments where residents of care homes have complex physical, sensory, and cognitive needs. In 2017 the NFCC, along with many stakeholders, co-operated to produce the Fire Safety in Specialised Housing Guide7. This document provides guidance on evacuation in supported living and other specialised housing. The NFCC represent FRS on various British Standards Institute (BSI) committees and other groups such as National Social Housing Fire Safety Group. Further, and perhaps more importantly in this case, the NFCC meet with the Care Quality Commission and other interested parties, regarding fire safety standards in higher risk accommodation. Action
1. The NFCC undertakes, at the earliest opportunity, to seek to ensure that this Concern is reported into these committees to encourage debate and petition for such positive outcomes necessary, and as far as is achievable under this action by the NFCC, to, it is hoped, assuage your apprehension to this Concern.

4 Article 26 Regulatory Reform (Fire Safety) Order 2005 5 Article 26(2) Regulatory Reform (Fire Safety) Order 2005 6 See: Fire safety risk assessment: residential care premises - GOV.UK (www.gov.uk) 7 See: NFCC_Specialised_Housing_Guidance_-_Copy.pdf (nationalfirechiefs.org.uk)

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2. The NFCC will send a copy of your Report annexed to a copy of this response, to all FRS in England to bring your Concerns to their respective attention, and to inform the FRS of the NFCC’s proposed actions. This should provide an excellent opportunity to direct information regarding the Concerns and the NFCC’s response, into the corporate mind and strategic management forums of the FRS.
2. Fire alarms in three units operated by Sequence Care Group remain non-compliant with the 2013 British Standard Guidance, which recommends that they should have a link to an Alarm Receiving Centre (“ARC”) which automatically contacts the emergency services when an alarm is activated. The NFCC represent FRS on BSI committees including the overarching committees for fire detection and alarm systems (FSH12) and fire precautions in buildings (FSH14). Action
1. The NFCC undertakes, at the soonest opportunity, to seek to ensure that this Concern is reported into these committees to encourage debate and petition for such positive outcomes necessary, and as far as is achievable under this action by the NFCC, to, it is hoped, assuage your apprehension to this Concern.
3. The London Fire Brigade conducted fire safety audits at the premises which assessed the unit as displaying the highest standard of fire safety compliance. These findings were found to be entirely incongruent with procedures, equipment and staff training in place before and at the time of the fire. The London Fire Brigade have reviewed and changed processes since 2018 but they remain incomplete. The former CFOA provided the audit framework that FRS adapt to their own local working practices. This is reviewed regularly and is now due for a full review and improvement following the recent introduction of new fire related legislation which will affect the FRS audit process.8 The NFCC is heavily involved with the, relatively new, Fire Standards Board (FSB). The FSB was founded to oversee the identification, organisation, development, and maintenance of professional standards for fire and rescue services in England. The FSB is responsible for approving standards and the approach to their development. It sets the priorities for standards development work. And commissions work based on proposals from third parties, monitors progress with ongoing work and approves completed work. Further, it seeks to ensure that any standards presented for approval have been developed in line with the agreed development process, undergone appropriate consultation with subject matter experts and relevant stakeholders and undergone an independent quality assurance process. The FSB meets at least four times per year; all papers are published on its website.9

8 See: Fire Safety Act 2021 (legislation.gov.uk) and Building Safety Act 2022 (legislation.gov.uk) 9 See: Fire Standards Board

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Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS)10 independently assesses and reports on the effectiveness and efficiency of FRS. The HMICFRS draws upon its inherent expertise to interpret the evidence derived from the assessments of FRS to make recommendations for improvement. Action
1. The NFCC will redouble its efforts in progressing such work mentioned above and that it is responsible for. This extends to influencing the content of new or amended fire protection and safety standards. The NFCC is also currently leading the review of the competency framework for Fire Safety Regulators (which includes FRS inspecting and enforcement officers) and enforcement toolkit for high rise buildings and have in the past year launched a third-party professional accreditation scheme for Fire Safety Regulators and a national learning platform to underwrite the continual professional development of such officers.
2. The fire sector, in the wake of the Grenfell fire tragedy, is receiving the closest of scrutiny, review and reform—much of which is being driven by HM Government—and the NFCC is subject to the dynamic and varying demands and challenges flowing from these activities. The NFCC respectfully submits, therefore, that there is some difficulty in offering a timetable to complete this action, other than to say that it is receiving dedicated and continual attention by the NFCC, with an expectation of delivery within the upcoming months.
3. The NFCC will continue to support the FSB with its undertakings.
4. The NFCC will continue to support the HMICFRS with its undertakings.
4. No clear and practical guidance exists on how specialist housing operators should manage the use of high-risk electrical devices such as portable electric fan heaters. Pursuant to Article 50 of the Order,11 the Secretary of State must ensure that guidance (Guidance) is issued to assist those responsible for fire protection and fire safety within premises to which the Order applies. A full review and improvement of the Guidance is in progress and is being superintended by the Home Office. Notwithstanding this, it is the view of the NFCC that the Guidance, regarding care homes and the NFCC Specialised Housing Guide, whilst not being statutory in nature, does satisfactorily address this Concern.12 Action
1. The NFCC is in the process of carrying out a significant programme of work, much of which is closely aligned and in collaboration with, the Home Office and the Department for Levelling Up, Housing and Communities. It is also working closely with the Care Quality Commission13 to formalise the use of ‘Person Centred Fire Risk Assessments’ (PCFRA) by care provider companies as part of care planning processes. Similarly,

10 See: HMICFRS - Home (justiceinspectorates.gov.uk) 11 See: The Regulatory Reform (Fire Safety) Order 2005 (legislation.gov.uk) 12 See: NFCC_Specialised_Housing_Guidance_-_Copy.pdf (nationalfirechiefs.org.uk) 13 See: Care Quality Commission (cqc.org.uk)

15 June 2022

local authorities, housing providers and their fire risk assessors are being encouraged to apply PCFRA to new residents upon the granting of leases or periodic tenancies. The NFCC believe these innovative interventions will increase the likelihood of such risks being identified and addressed in future.
2. This work includes the Guidance review and improvement, and the NFCC will continue to work with the Home Office to make sure that the matter of Concern is suitably addressed in any Guidance revision. It should be noted that any revision is subject to drafting and consultation, with an expectation of being issued in early 2023.
5. No clear guidance exists regarding the fitting of digital key-pad locks on doors in specialist housing. Pursuant to Article 50 of the Order,14 the Secretary of State must ensure that guidance (Guidance) is issued to assist those responsible for fire protection and fire safety within premises to which the Order applies. A full review and revision of the Guidance is in progress and is being superintended by the Home Office. Notwithstanding this, it is the view of the NFCC that its own guidance, contained in the NFCC Specialised Housing Guide, whilst not being statutory in nature, does satisfactorily address this Concern. Action
1. The NFCC is in the process of carrying out a significant programme of work, much of which is closely aligned and in collaboration with the Home Office and the Department for Levelling Up, Housing and Communities.
2. This work includes the Guidance review and improvement, and the NFCC will continue to work with the Home Office to make sure, as far as is reasonably practicable, that the matter of Concern is suitably addressed in any Guidance revision. It should be noted that any revision is subject to drafting and consultation, with an expectation of being issued in early 2023.
6. Insufficient emphasis is placed upon recommendations contained within British Standards regarding automatic connections to ARCs in fire alarms fitted in specialist accommodation. The NFCC represent FRS on BSI committees including the overarching committees for fire detection and alarm systems (FSH12) and fire precautions in buildings (FSH14). Action
1. The NFCC undertakes, at the soonest opportunity, to seek to ensure that this Concern is reported into these committees to encourage debate and petition for such positive outcomes necessary, and as far as is achievable under this action by the NFCC, to assuage your apprehension to this Concern.

14 See: The Regulatory Reform (Fire Safety) Order 2005 (legislation.gov.uk)

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Conclusion In closing I wish to provide you with my assurance that the NFCC will attend to, and expedite the actions set out above, with due diligence, care, and close attention. I trust that you find all in order with this response and that you consider the NFCC proposed actions contained herein—as far as they can be addressed by the NFCC—suitable in addressing the Concerns. And, further, that you are satisfied that the relevant duty for the NFCC to respond to your Report has been properly discharged. If this is not the case or, if you require anything further from the NFCC, please do not hesitate to contact my colleague Roy Carter within the NFCC Protection Policy and Reform Unit .

F r o m:

T o: C or o n er s C c:

S u bj e c t: R ef 1 0 8 5 7 8 F A O Mr G Ir vi n e P RI V A T E A N D C O N FI D E N TI A L D a t e: 1 5 J u n e 2 0 2 2 1 2: 0 2: 1 7 A t t a c h m e n t s:

D e ar Sirs, Pl e as e f or w ar d t h e b el o w t o Mr G Ir vi n e, A cti n g S e ni or C or o n er D e ar Sir F urt h er t o o ur e m ail of 5 M a y, I a m writi n g t o u p d at e y o u o n B SI’s r es p o ns e t o y o ur R e g 2 8 r e p ort. M e m b ers of B SI’s c o m mitt e e F S H/ 1 2 - Fir e d et e cti o n a n d al ar m s yst e ms h a v e dis c uss e d y o ur R e g 2 8 r e p ort. T h e c o m mitt e e e x p erts b eli e v e t h e c o m mitt e es w hi c h s h o ul d e x a mi n e t h e iss u es m or e cl os el y ar e:
a. T e c h ni c al c o m mitt e e F S H/ 1 4 - Fir e pr e c a uti o ns i n b uil di n gs. T h e s c o p e of t h e c o m mitt e e is “t h e d e v el o p m e nt of N ati o n al st a n d ar ds f or fir e s af et y pr e c a uti o ns i n r esi d e nti al a n d c o m m er ci al b uil di n gs, fir e ris k ass ess m e nt a n d fir e ris k m a n a g e m e nt s yst e ms. ” A m o n g ot h er st a n d ar ds, F S H/ 1 4 is r es p o nsi bl e f or B S 9 9 9 1 Fir e s af et y i n t h e d esi g n, m a n a g e m e nt a n d us e of r esi d e nti al b uil di n gs - C o d e of pr a cti c e. T h at st a n d ar d is c urr e ntl y b ei n g r e vis e d, a n d is d u e t o g o f or p u bli c c o ns ult ati o n o n 2 1 J ul y 2 0 2 2.
b. S u b c o m mitt e e F S H/ 1 2/ 1. T h e s c o p e of t h e c o m mitt e e is: “I nst all ati o n a n d S er vi ci n g - t h e d e v el o p m e nt a n d m ai nt e n a n c e of Britis h St a n d ar ds a n d t h e U K i n p ut i nt o C E N/ T C 7 2, I S O/ T C 2 1/ S C 3 a n d t h eir W or ki n g Gr o u ps i n t h e ar e a of pl a n ni n g, d esi g n, i nst all ati o n a n d s er vi ci n g of s yst e ms ”. A m o n g ot h er st a n d ar ds, F S H/ 1 2/ 1 is r es p o nsi bl e f or B S 5 8 3 9- 1: 2 0 1 7 Fir e d et e cti o n a n d fir e al ar m s yst e ms f or b uil di n gs - C o d e of pr a cti c e f or d esi g n, i nst all ati o n, c o m missi o ni n g a n d m ai nt e n a n c e of s yst e ms i n n o n- d o m esti c pr e mis es, a n d B S 5 8 3 9- 6: 2 0 1 9 + A 1: 2 0 2 0 Fir e d et e cti o n a n d fir e al ar m s yst e ms f or b uil di n gs - C o d e of pr a cti c e f or t h e d esi g n, i nst all ati o n, c o m missi o ni n g a n d m ai nt e n a n c e of fir e d et e cti o n a n d fir e al ar m s yst e ms i n d o m esti c pr e mis es. F S H/ 1 2/ 1 m et o n 1 0 J u n e, a n d h a v e i d e ntifi e d t h e f oll o wi n g as p e cts of B S 5 3 8 9- 1 t o b e c o nsi d er e d as p art of a f ut ur e r e vi e w, a n d als o t o b e c o nsi d er e d i n r es p e ct of B S 9 9 9 1 b y F S H/ 1 4:
1. W h et h er B S 5 8 3 9- 1 s h o ul d i n cl u d e u n d er us er r es p o nsi biliti es a n i nf or m ati v e n ot e t h at t h e us er m a y wis h t o r e q u est a c o m pl et e r e vi e w of t h e “ a d dr ess es ” of fir e d et e ct ors at r e g ul ar i nt er v als, f or e x a m pl e, 5 y e ars.
2. W hil e B S 5 8 3 9- 1 alr e a d y d et ails a n e e d f or us ers of t h e st a n d ar d t o c h e c k z o n es a n d c o nfir m z o n e pl a ns, it is pr o p os e d t h at c o m m e nt ar y b e a d d e d t o 4 6. 2 a n d/ or 2 3. 1 m a ki n g t h e ris k t o lif e fr o m a l a c k of a z o n e pl a n v er y cl e ar. T h e t e xt c o ul d als o list t h e l a c k of a z o n e pl a n as a m aj or n o n- c o nf or mit y O R t h e l a c k of a z o n e pl a n i m m e di at el y r e n d eri n g t h e s yst e m n o n- c o m pli a nt. T his m a y i n cl u d e t h e a bs e n c e of a n A R C.
3. R e g ar di n g A R C c o n n e cti o ns, t h e c o m mitt e e n ot e d, m a n y Fir e & R es c u e S er vi c e ( F R S) ar e o p er ati n g a nil-r es p o ns e p oli c y t o A F As ( A U T O M A TI C FI R E A L A R Ms). T h e st a n d ar d m a y i n cl u d e a r e c o m m e n d ati o n t h e us er t o d et er mi n e w h at t h e p oli c y is f or t h e l o c al F R S a n d c o nfir m w h et h er t h e pr e mis es ar e i n cl u d e d or e x e m pt.
4. C urr e ntl y t h e st a n d ar d all o ws v ari ati o ns t o b e m a d e a n d t h e s yst e m still b ei n g c o nsi d er e d c o m pli a nt. T h e c o m mitt e e h as pr o p os e d t h e cr e ati o n of a list of c ert ai n v ari ati o ns t h at c a n n ot b e all o w e d, a n d t h at s yst e m still b e c o nsi d er e d c o m pli a nt. T h e n e e d t o j ustif y t h e

v ari ati o n(s) m a y als o b e i n cl u d e d i n t h e cl a us e.
5. W h et h er a n i nf or m ati v e n ot e b e i n cl u d e d t h at st at es a n al ar m c a n n ot b e r es et u ntil t h e c a us e of t h e al ar m is r es ol v e d. H o w e v er, it w as n ot e d a n y n e w w or di n g w o ul d b e a d d e d t o cl a us es p ert ai ni n g t o us er o p er ati o n r at h er t h a n a n y n e w r e c o m m e n d ati o ns f or m a n uf a ct ur ers.
6. T h e c o m mitt e e is c o nsi d eri n g i n cl u di n g a r e c o m m e n d ati o n t h at t h e e v e nt l o g s h o ul d b e l ar g er. H o w e v er, t h e y n ot e d t h at o n e iss u e is t h at “ e v e nt ” is v er y br o a d. As p art 1 is a C o P, t h er e ar e li mits t o w h at c a n b e r e c o m m e n d e d a n d a E N 5 4 pr o d u ct st a n d ar d m a y b e b ett er pl a c e d. T h er e ar e als o t e c h ni c al li mit ati o ns. It h as b e e n pr o p os e d t h at t e xt b e a d d e d t o c o m m e nt ar y t h at p oi nts o ut t h at m a xi m u m n u m b er of r e c or d a bl e e v e nts is 9 9 9 b ut m or e m a y b e n e e d e d, a n d t h o u g ht s h o ul d b e gi v e n t o pr o vi di n g m or e c a p a cit y f or a d dr ess a bl e s yst e ms. It w as als o a gr e e d t h at B S 5 8 3 9-6: 2 0 1 9 + A 1: 2 0 2 0 n e e ds t o b e r e vi e w e d a g ai nst t h e a b o v e list as t h es e c h a n g es m a y n e e d t o b e m a d e t h er e. It w as s u g g est e d t h at B SI m a y n e e d t o writ e t o or i nf or m all Fir e a n d R es c u e S er vi c es a n d p ossi bl y t h e C ar e Q u alit y C o m missi o n ( C Q C) t o i nf or m t h e m of t h e c h a n g es t o t h e st a n d ar d t o e n c o ur a g e att e n d a n c e t o A F As d uri n g t h e d a yti m e. It w as f urt h er s u g g est e d t h at t h e f a mil y of t h e d e c e as e d b e i nf or m e d as t o t h e pr o p os e d c o urs e of a cti o n b y t h e r el e v a nt a ut h orit y/ or g a niz ati o n. R e g ar di n g t h e m att er of k e y l o c ks, it w as a gr e e d s u b c o m mitt e e F S H/ 1 2/ 4 m a y c o nsi d er it as p art of a f ort h c o mi n g a m e n d m e nt t o B S 7 2 7 3- 4. It m a y als o b e c o v er e d as p art of t h e o n g oi n g r e visi o n of B S 9 9 9 1 vi a t h e i n cl usi o n of a n i nf or m ati v e n ot e t o t h e eff e ct t h at “if el e ctr o ni c l o c ki n g is pr o vi d e d o n fl at e ntr a n c e d o ors of i n di vi d u al u nits of a c c o m m o d ati o n it s h o ul d n ot b e n e c ess ar y or n e e d e d t o i nst all a c o d e t o e xist t h e fl at. M e a ns of el e ctri c l o c ki n g s h o ul d b e si m pl e a n d e as y t o us e ( e g a si m pl e l e v er h a n dl e). It is als o i m p ort a nt t h at r esi d e nts u n d erst a n d h o w t o us e t h e el e ctr o ni c l o c k. ” Fi n all y, it w as als o s u g g est e d t h at B S 9 9 9 1 c o ul d s a y t h at “ c o nsi d er ati o n s h o ul d b e gi v e n f or A R C c o n n e cti o n i n c ert ai n s u p p ort e d h o usi n g ” a n d f urt h er g ui d a n c e c a n b e f o u n d i n B S 5 8 3 9 -1. E a c h of t h os e p oi nts will b e c o nsi d er e d b y t h e r es p o nsi bl e c o m mitt e e(s) a n d w e will writ e a g ai n t o u p d at e pr o gr ess i n d u e c o urs e. Y o urs si n c er el y,

B A/ L L B ( H o n s) H e a d of St a n d ar d s G o v er n a n c e B SI, 3 8 9 C hi s wi c k Hi g h R o a d, L o n d o n, W 4 4 A L, U K

W e s u p p ort t h e U N S u st ai n a bl e D e v el o p m e nt G o al s, s o pl e a s e c o n si d er t h e e n vir o n m e nt b ef or e pri nti n g t hi s e m ail T h e Briti s h St a n d ar d s I n stit uti o n i s a m e m b er of B SI Gr o u p a n d i s i n c or p or at e d i n E n gl a n d u n d er R o y al C h art er. It s pri n ci p al a d dr e s s i s 3 8 9 C hi s wi c k Hi g h R o a d, L o n d o n, W 4 4 A L, U nit e d Ki n g d o m