Will BREXIT require a re-think for products in relation to CE Marking and EN standards? Will there be change? Or is the best policy, perhaps, to keep calm and carry on? What does No Deal mean?

Few in the current fevered political environment have in mind what happens in a post-Brexit UK to the suite of glass and glazing standards originating under the CPR. The glass and glazing standards have been very well established for around 20 years, after what was a long gestation period of diligent standardisation work in which the UK industry took such a prominent leading role. Will Brexit bring problems? Or can we just follow on, still dancing to the EN tune?                                                                                

One sure aspect of BREXIT is that very little is actually nailed down. Nothing is certain relating to possible consequences and outcomes. Politicians have wandered into a political morass and are now going about in increasingly smaller circles trying to find a way out to firmer ground. We won’t know in many areas what the implications are until events start to unfold after the UK leaves.

Even when leaving is finally settled, we still cannot be entirely confident what will emerge as a result. Uncertainty rules, OK?  There is a hope that the implications will not mean a re-working of all the product standards that now provide such a firm basis for glass and glazing products in the UK.

It is useful to recall the origin for those glass and glazing standards – the background history is important

The standards come from the Single Market, determined by processes under the Construction Products regulation (the CPR) subject to the original EU Treaties, originating way back from the Single European Act, in Margaret Thatcher’s day, to establish the single market by 1992. The Act came into force in 1987, under the Delors Commission.  Before the stimulation provided by the European single market process there were no BS glass and glazing product standards in the UK.

A fundamental requirement by treaty is the free movement of goods without technical barriers to trade within the EU. That requires what is described as a common technical language, captured by harmonised European Norms (hEN’s) that allow the definition of product types and classification according to key properties and characteristics.   

First came the Construction Products Directive in 1988, finally leading to a new regulation of the European Parliament 305/2011 known as the CPR (The Construction Products Regulation). The CPR made CE marking obligatory for qualifying products available for sale and placed on the EU market (i.e. those which are covered by an appropriate product harmonised standard, hEN).  

On that count there is perhaps not cause to worry unduly. It seems BSI will remain part of the European standards club – at least as far as we can see, at the moment, until things settle down further.

BSI has announced that they have been accepted to continue as a full member of CEN in transition to BREXIT until the end of 2020. How membership continues beyond the interim period is not yet clear: CEN membership rules require the national bodies to come from countries that are either EU or EFTA members. The UK looks likely to be in neither camp.

As a member of the standards club, the UK represented by BSI will be able to continue using the BS EN standards that have already been developed. The consequences of not being able to continue with those standards is horrific to contemplate. They have all been developed over many years, involving a very high level of work in various European and UK standards forums, for many industry people. It would take years to go over that work again, to replace the BS EN’s with original new BS’s. It is fundamentally important to keep the British Standards for products, testing and performance classification that are available from adopted EN standards.  

When standards have to be updated, or new standards developed, the future ability to be as fully engaged in the standardisation process is less clear and somewhat hazy.  

Hopefully the deadlock intransigence to agree will not spill over into standardisation, where there has been harmony. But the UK may find itself not as welcome in European Forums as it has been in the past.  Voting rights might not be the same. And it would be an unwelcome outcome if UK industry should not be as influential as it has been in the past.

Conformity with the EN standards is shown by the CE Mark, the only mark acceptable for compliance with the CPR Single Market process.  If the UK is no longer part of the EU Single Community Market – by definition, beyond the CPR – then it’s obvious that the CE Mark can no longer hold sway in the UK. Government has suggested an answer. There are optimistic noises and the mood at least in this respect, can be said to be somewhat upbeat.

If the UK crashes out on a No Deal basis then the Government has said that goods already on the market that meet EU CE mark requirements can still legitimately be placed on the UK market in the same way. Current arrangements are expected to have force through a new UK mark, the CA Mark (i.e. Conformity Assessed). The stated policy intention is that new UK rules will mirror the EU rulebook. That at least is the anticipated position when the starter gun goes off.

But this is to be time-limited. Products tested by a UK-notified body under CPR procedures will no longer be able to be placed on the EU market without re-testing and re-marking by a EU-recognised conformity assessment body. A UK-based organisation cannot be a new EU notified body. UK bodies notified under the CPR will be granted new UK Government approved body status, Government has said. And those organisations will be able to assess products for the UK market against UK essential requirements (which are naturally expected most likely to mirror EU essential requirements).  

All this scenario comes under the heading “We hope; and expect.” But there are many BIG influential issues to be resolved yet.  The best policy in the absence of anything more definite does seem to be to keep calm and carry on.  But don’t be surprised if there should be unforeseen consequences and disruptive unwelcome outcomes.

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Residents in private blocks of flats have finally receive Government support, with a £200 million fund at last provided by the Government to stimulate work on towers at risk because of fire safety.

The Communities Secretary has finally made a clear statement that the scandal of unsafe fire risk cladding is a matter of Public Safety. In a major statement to Parliament on 9 May 2019 James Brokenshire announced a Government fund of £200 million to help remove and replace dangerous Grenfell-type cladding and insulation on the many residential towers under private ownership that are still considered at risk, almost 2 years’ after the Grenfell Tower fire.

There are many in the fire safety sector and in the residential and social housing sector who have been frustrated by the extended time it has taken for proper recognition of the serious situation faced by residents in tall residential towers who are challenged daily by thoughts on the fire risks that exist in external cladding materials of the Grenfell-type identified as a serious fire safety threat.  

Building owners and freeholders responsible for the buildings have failed in many cases to take action. James Brokenshire praised those that had.  But he focused clear criticism on those who had tried to shift financial responsibility unfairly on to innocent residents, who found themselves faced by unaffordable high remediation bills offloaded on to them through no fault of their own. The Minister said that too many owners had failed to take responsibility.  Now the Government has been forced to act, by providing a starter fund (from existing budgets) to remove the block on improvement work going forward.

The message from the Minister is clear.  The Government is “looking at measures to get building owners and developers to do the right thing.”  But the Minister has said that the fund should not be taken to absolve the wider construction industry from taking responsibility for high-risk materials being put on the outside of buildings which have been shown to be highly combustible, infringing building regulatory guidance to limit the chances of external fire spread ( Regulation B4 for England and Wales).  

This isn’t intended to be a free handout without strings.

Receiving money is conditional upon the building owner or responsible person in their stead agreeing a contract to start remediation work within a set period (not defined, however). Owners have three months to apply for funds.  And Government have said that they will look carefully at further steps where owners still fail to take action.

A condition of funding is that the building owner takes “reasonable steps to recover costs from those responsible for the presence of unsafe cladding” in the first place (from the Ministry’s press release). Clearly, this matter will not be allowed to rest. And as the Parliamentary session showed, there are several MP’s from all sides on the case to monitor progress and hold government to account.

Government records that work has yet to start on 166 private high-rise buildings (above 18m tall) to remove and replace at risk cladding and insulation materials.  That compares with 23 still in the public sector. Work on only 10 private residential blocks has been carried out in the last two years since Grenfell. The Government is already funding substantial work in the public local authority sector, by providing a further £400 million previously announced.

That’s £600 million in total, a significant commitment to underline the importance of fire safety.  At last there is a well-defined Government purpose, with evident intent.

433 buildings were originally identified as having unsafe cladding of the Grenfell type. There are questions over other cladding types as well, also under suspicion and to be evaluated in a new government test programme.  That illustrates the shocking scale of the issue, reflecting how low consideration for fire safety had been allowed to slip down the priority list in construction and design.

What are the overall signals for fire safety arising from the Government’s statements?

Personal responsibility cannot be evaded and simply passed on down the chain from one operator to another.  Fire safety means using products and installations that are robust and reliable in fire. The message is: Don’t take unreasonable risks.  Be sure about product capability to survive and last in fire, demonstrated from test evidence. Taking responsibility is fundamentally important.  That personal responsibility applies to anyone designing, specifying, approving and providing products with a claimed performance in fire. It cannot be simply sub-contracted on down the line to others. Fire safety is a matter of public safety, and several in practice have a responsibility to ensure that products, designs and constructions are actually in practice fit for the intended purpose.  

Building owners, developers and their representatives cannot evade their fundamental obligations.  As Justine Greening MP said in the Parliamentary Questions, as recorded by Hansard, “while those owners are quite happy to take the gains that come from owning a building, they must also take the responsibilities that it brings.”  

In summing up the Minister would note for everyone that fire safety ultimately in compliance with regulations is a requirement to be fulfilled under the Law. That should be sufficient reminder.

Ceramic Glass Limited has been involved in fire safety since 1982 as a dedicated supplier of integrity fire-resistant ceramic glass FireLite.  As a transparent ceramic FireLite has ideal properties to perform as a robust resilient barrier against fire. It has a softening point above typical flashover maximum temperatures in building fires and is specifically designed to be immune to thermal stress (as a result of an effective zero thermal expansion coefficient that avoids significant thermal stress generation).

FireLite is therefore ideal for use as fire-resistant barrier glazing.  Used in external glazing, the effective integrity performance can be effective in preventing fire break-out and break back in for tall buildings should fire spread up the outside of the façade. FireLite has the core property of being able to survive in fire resistance tests for longer than 4 hours, even resisting without change the impact of a cold-water hose stream at the end of 4 hours exposure to demonstrate effective resilience against thermal shock and stress.

One of the core principles at the heart of firefighting policy for dealing with fire in high-rise residential and more complex buildings has come under the spotlight because of concerns over what is best for the safety of residents. What is described as stay-put has been a core principle for many years but now it is being questioned. With that, comes questions over other fire safety measures.

It is common sense and instinctive to many that when aware of fire, simply get out. The psychological reaction to stress and threat is commonly described as either fight or flight. In fire, which can develop and move quickly, the immediate response is flight, get to a place of safety and stay out. 

That’s an understandable reaction. Yet common advice from the Fire Service for those in high-rise blocks and similar high occupancy complex buildings where there is no immediate fire safety supervision, is for occupants to stay where they are if they are aware of fire but not immediately affected by flames, smoke or heat. It’s counter intuitive. But that is the long-standing advice.

The Stay-Put Policy

If there is fire inside your flat then alert everybody in the flat, leave (immediately) and close all doors. Follow a pre-determined escape plan. If there is a lot of smoke in the flat and escape ways, then crawl along the floor where air should be clearer and temperature less hot. Always use the stairs, not a lift. Call 999 when in a safe place. If there is fire elsewhere in the building then you are usually safer to stay in your flat, unless the heat and smoke is affecting you. If you “stay put” then you should still immediately call 999 for advice, and to ensure that fire and rescue and other emergency crews have been notified. Advice can and does change depending on circumstances.
 Advice from The National Fire Chiefs’ Council (NFCC).

From the point of view of the fire and rescue services, there are some practical considerations. 

The underlying, implicit assumption is that the fire safety measures in the building – predominantly the compartmentation structure of the building perhaps combined with suppression systems – will keep the fire small and manageable and in the place where it breaks out. It is also assumed that the detection and alarm systems will work to give the earliest possible alert for fast response. 

Although internal compartmentation barriers may be in place horizontally and vertically, what can be forgotten however, is that the external wall with windows is not usually a compartment wall. Fire can break out. Yet robust fire-resistant integrity glazing can be used to prevent glass failure and limit the chances of flame spread outside, up and along the façade. Ceramic glass can easily resist thermal stress; and has been tested to endurance times of more than 4 hours, even with hose stream impact.

The fire service needs to get to the fire as quickly as possible to deal with it as easily as possible. They don’t want panic in the building with everybody trying to leave, all at the same time.

“Stay put” also means staying aware and keeping in touch with the emergency telephone contacts. It may mean perhaps making emergency decisions to leave when conditions become uncomfortable, especially when firefighters are able to assist. Fire of course is dynamic and circumstances can change on the ground very quickly. Conditions for safe escape may very quickly change as well.

On 11 February 2019 London’s Fire and Rescue Service Commissioner Dany Cotton appeared on Radio 4’s News at One programme to make (yet another) plea for better use of sprinkler fire suppression systems in high-risk residential blocks. The Commissioner spoke earnestly and honestly: sprinklers save lives, but she finds that fire service advice is simply being brushed aside, ignored. 

The evident frustration of the Commissioner’s call for real action on installing sprinklers in both new build and refurbished buildings can easily be understood. Emergency response to fire is to use water. And surely, on a common-sense basis alone, suppression including sprinklers has a role in the fire safety and protection strategies for buildings, especially where higher risks cause concerns?

Sadly, lack of attention on the benefits of sprinklers reflects a wider lack of focus on the risks of fire. Disasters such as Grenfell 2016 and Lakanal 2009, together with other lower profile fire events, suggest that sprinklers are not the only fire safety measure that needs to be given far more attention.
Fire protection – in all its respects – requires more emphasis. The key is integrated fire safety. That’s a variety of different measures, working together, firstly, to avoiding fire breaking out and, secondly, if fire does arise to prevent fire and smoke spread. Both people and property need to be safeguarded against the extremes of fire growth. A combination of steps is necessary, including the following:
Building management aligned with risk assessment to ensure that proper fire precautions are in place, including elimination of obvious sources of ignition, housekeeping to remove easily combustible material and attention to keep escape routes open for use in an emergency.

Attention to active measures – especially detection, alarm and suppression – to allow those in the building to react and move to a place of safety before conditions become untenable.

Appropriate access facilities for firefighters, both outside the building and especially inside.

Effective compartmentation (i.e. defined areas surrounded by fire-resistant boundaries) to limit the chances of fire spread and movement, especially paying attention to ensure that barriers built into the original structure are maintained and not compromised by any building work.

Protected escape ways and enclosures providing access to exit points and escape stairways – to physically keep out fire and smoke, all along the way through to a place of safety.

There are no magic solutions. Fire is unpredictable and its effects uncertain. No single measure on its own can be entirely relied upon, in all potential circumstances; and a combination of different measures is required to cope assuredly with whatever conditions may arise. That may require consideration of enhanced fire resistance, for example, for a longer time period that might otherwise be expected in view of the risks arising from the extremes of intensive fire growth and spread.
And if suppression is to play a role then it makes sense to ensure that other fire safety systems – such as smoke control, venting and fire resistance physical barriers, including fire protection glazing – are compatible with water, as an important part of the overall integrated plan.

Despite the increased attention given to fire over the last two years, sensitivity to fire safety is still not apparently at the high level it really needs to be given the unpredictability and uncertainties of fire. London Fire Brigade have reported that the elderly are potentially at risk in significant numbers of care homes that they have inspected.  The brigade has found that too many failed to measure up in formal audits, when awareness of the dangers from fire would be expected to be acute. 

It can never be appropriate to relax the focus on fire safety. The Regulatory Reform Fire Safety Order 2005 brought fire safety into line with established health and safety procedures.  Places other than individual private homes (dwellings such as houses and apartments) require a fire risk assessment of the fire safety measures and the means of escape.  Fire is a particular potential threat in care homes where residents are extremely vulnerable and unable to escape to a place of safety without help. 

Yet London Fire Brigade have reported several staggering outcomes from their surveys:

• 45% of the care homes evaluated in the formal audit were found to have fire risk assessments that were unsuitable or insufficient;

• 101 out of 177 of inspected premises had to be issued with a formal warning;   

• in 29% of the inspected homes problems were found with fire doors; and

• one in seven have been said to have poor emergency planning or a potential shortfall in staff to fully carry out the emergency plan.

Such reports are truly shocking given the prominence of the Grenfell Tower fire inquiry, the Hackitt Report, attention from Government in their implementation plan and numerous guidance notes from the MHCLG’s Expert Panel. All have been in the headlines.  Fire safety could not have been more under a public spotlight. We’ve seen the biggest, most sustained campaign on fire safety awareness in the national press for several years.  Not before time many are saying.

The brigade carried out its audit review because of concerns over a series of fires in care homes.  In February 2018 a resident in his 80’s died, and another left in a critical condition. In 2017 two died in a Cheshunt care home after a fire spread through the roof to quickly engulf the building. 

There can be no room for uncertainty and doubt concerning fire safety.  Nothing must be left to chance.  Fire safety measures and precautions for escape need to be regularly checked and double checked to be confident that they are fit for their intended purpose should fire break out.  Fire safety should always be a combination of different measures working together, with back-up where risks justify an increased level of confidence. 

The lessons of major fires point to the critical need to protect escape ways from fire penetration and to keep them free of black choking smoke.   Preventing fire movement and transfer is key to any fire protection strategy. And in complex and tall buildings or other buildings where escape can be perhaps difficult, complicated and drawn out with major risks to residents then the resilient endurance of the fire-resistant barriers is potentially crucial.  In fire, extended time for assisted rescue and assistance to get out is an important consideration.    

Vision panels are esential in fire doors, along corridors, in lobbies and in walls or partitions surrounding areas which require special protection combined with transparency for observation and perhaps security.  Fire-resistant glazing therefore has a major part to play in maintaining adequate levels of safety and protection against fire.

Fire completely devastated the automated Andover warehouse of on-line supermarket Ocado on 6 February 2019, despite attendance by 200 firefighters and 20 fire engines. The cause of the fire is not so far disclosed. The warehouse is reported to have contained sprinklers, which raises important points about the use of sprinklers in large open spaces full of combustible items. Sprinklers should not be in isolation, but advisedly used in compartmented zones, part of a holistic fire protection strategy.

The fire in Ocado’s flagship robotic warehouse killed nobody.  But it serves to remind us that fire can cause major disruption and costs in the destruction of property and building contents. The blaze lasted at its height for 48 hours, destroying a £45 million state-of-the-art modern handling facility, temporarily wiping £1 billion off the retailer’s stock market value. 100 local residents had to be relocated because of the risk of a pressured tank exploding and concerns over fall-out from the smoke plume, down-wind for 1.6 km. Stock worth £6 million is reported lost, along with the hundreds of robots used throughout the facility for the assembling of orders (at around 30,000 orders per week).

Dr Jim Glocklin, Technical Director of the Fire Protection Association (on behalf of the insurance industry), reported in the specialist on-line news portal IFSEC Global, observes that the intended function of sprinklers is to stop the growth and development of a fire – to hold fire at a manageable size so that it can be more easily extinguished by the fire and rescue service when they arrive.

Dr Glocklin emphasized the importance of holistic fire safety design.  He draws attention to the need for sprinklers to be designed within a compartmented structure, i.e. with the building divided into control zones intended to restrict the ability of fire to spread very far, very fast, by the use of robust barriers that are fire resistant, to prevent the physical movement and transfer of fire.

It’s implicit that the use of a sprinkler system should be designed carefully with the characteristics of the protected space in mind, especially including considerations on what the maximum compartment size should be.  It would also be sensible, as part of the holistic approach, to give thought to the ability of the compartmentation boundaries to remain in one piece under fire conditions where there is the chance of water impingement, not just from sprinklers but also from firefighter hose streams.  

That applies particularly to glazed partitions and glass vision panels or internal glazed ribbons assemblies, which can be so important in large internal compartmented spaces to provide natural lighting and allow through vision from one side of a compartment to another.  Standard glass products have no significant resistance against fire: traditional glass is notoriously vulnerable to thermal shock and stress.  Ceramic glass, however, is exceptional in its immunity to thermal stresses.