Staying Safe: Disability, Fire and the Law Colin Todd, Managing Director C. S. Todd & Associates Ltd C.S. TODD & ASSOCIATES LTD C S T A

Staying Safe: Disability, Fire and the Law

Colin Todd, Managing Director

C. S. Todd & Associates Ltd

C.S. TODD & ASSOCIATES LTD

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Fire Risk in Hotels

Fires in UK hotels 2002 - 2008


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Fire Risk in Hotels

Fires in UK hotel bedrooms 2002 - 2008


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Fire Risk in Hotels

UK hotel bedroom fires that spread beyond room 2002 - 2008


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Interfacing Legislative Regimes


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Building Regulations

Fire Safety

Legislation

Equality

Act

Building Regulations England and Wales Building Regulations 2010 supported by

AD B Scotland Building (Scotland) Regulations 2004 (as

amended) supported by the Tech Handbooks

Northern Ireland Building Regulations (Northern Ireland)

2000 supported by TB E


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Fire Safety

Legislation

Equality

Act

Fire Safety Legislation


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England and Wales Regulatory Reform (Fire Safety) Order 2005 Scotland Fire (Scotland) Act 2005 Fire Safety (Scotland) Regulations 2006 Northern Ireland Fire and Rescue Services (Northern Ireland)

Order 2006 Fire Safety Regulations (Northern Ireland)

2010



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Fire Safety

Legislation

Equality

Act

Equality Act 2010


Applies in Great Britain Does not override other legislation Reasonable adjustments for substantial

disadvantage due to disability Direct discrimination cannot be justified Indirect discrimination justified subject to

proportionate means of achieving legitimate aim

Breach affords right of action in civil lawCSTA

Disability

Defined by later speaker In a hotel, need to consider:

Mobility impairmentDeaf and hard of hearing peopleBlind and partially sighted peoplePeople with cognitive impairment


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Requirements for Access and Amenity

Part M of Building Regulations 2010Reasonable provision for people to gain access and to use the building and its facilities

Same requirement for disabled people in Part R of the Building Regulations (Northern Ireland) 2000

Functional Standard 4.2 in ScotlandSafe, unassisted and convenient means of access

throughout the building plus accessible bedrooms


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Key Points of Interpretation of Building Regulations

Access for mobility impaired and blind and partially sighted people

Proportion of hotel bedrooms accessible for wheelchair users

Visual fire alarm devices in bedrooms and toilets (less specific in Scotland)


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Fire Safety Legislation Where necessary, in the event of danger, it

must be possible for persons to evacuate the premises as quickly and as safely as possible

Where necessary, the premises must be, to the extent that it is appropriate, equipped with appropriate fire detectors and alarms

An offence is committed only if a breach puts relevant persons at risk of death or serious injury in case of fire


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Potential Conflicts Access versus egress Amenity versus safety Staff evacuation versus staff assistance for

disabled people Affordable accommodation versus adequate

assistance for evacuation Space utilization versus provision of refuges Provision of refuges versus unobstructed escape

routes Alarm audibility versus refuge communication Fire doors!


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Misconceptions and Misunderstandings

The fire and rescue service evacuate disabled people

Evacuation lifts should be used by disabled people without staff supervision or control

One staircase or evacuation lift is always sufficient

Disabled evacuation is about hardware and physical measures

Use of stock solutions, not tailor-made to building


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Two Main Issues

Evacuation of disabled people from upper floors

Warning of deaf and hard of hearing people


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Evacuation Problems Provision of refuges (TWS) How many refuges Communication with disabled people in

refuges Availability of staff Single manning at night Unstaffed buildings External paths Logistics and training in use of equipment Separation of family groups


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Warning Problems

Visibility of visual alarm devices (VADs)

No code for location and siting of VADs

Are vibrating devices necessary?


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Philosophy

EQUIVALENCE:

The basis of all solutions Leads inexorably to correct answers Think it! Commit to it!


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Menu of Solutions (Management)

Management commitment Identification of special needs Sufficient staff with proper training Instructions to guests


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Menu of Solutions (Physical Measures)

Siting of disabled rooms Early warning (smoke detectors in

disabled bedrooms) Protection of corridors Refuges (? bedrooms) Communication within refuges (BS

5839-9) Evacuation lifts


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Final Thought


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Documents

Staying Safe: Disability, Fire and the Law Colin Todd, Managing Director C. S. Todd & Associates Ltd C.S. TODD & ASSOCIATES LTD C S T A