As part of the DFC 10 year celebration posts (beginnings, projects, team), I wanted to reflect on the past, the present and celebrate the future of fire engineering. However, in the end, I concluded that whether we celebrate the future of fire engineering depends on the direction taken with respect to outcome vs prescriptive regulation and whether industry truly raises the bar of both the skill and, more importantly, the care applied to the design and construction of buildings.
Fire engineering is built upon fire science
Before starting, I want to introduce two concepts: fire science and fire engineering. It is not as delineated as an either or, but it is a useful construct to explain my thinking.
- Fire science is the pursuit of knowledge of all things fire related. It is about understanding the chemistry, physics and human response to all things fire. It is about eliminating unknowns and uncertainty.
- Fire engineering is about the application of the science as we know it and mitigating risk associated with the inevitable uncertainty in the science.
There has been some fantastic work in fire science and related fields from the early 1900s onwards (Thomas, Babrauskis, Law, Proulx, to name but a few). In many respects, the science is quite well established. That does not mean there is not plenty more to do.
Fire engineering started by these fire scientists applying their knowledge to specific challenges (Law, Thomas, Quintere). Around this time, the UK building fire safety regulations changed fundamentally from prescriptive rules to functional requirements. This removed redtape and fragmentation of legislation (Egan) and introduced freedom for designers and engineers to develop “engineered” solutions. The concept was sound; fire engineers should facilitate architectural flexibility and more optimised buildings.
Fire engineers became professional persuaders striving for approval
However, the implementation of the legislation (i.e. the way in which Approved Document B was applied by designers and building control authorities alike) resulted in a binary approach to fire safety:
- Code compliant designs where building designs complied with guidance in Approved Document B (ADB); and
- Fire engineered solutions where an aspect of building design did not comply with ADB and an alternative justification was provided.
At its extreme, yet perhaps most common manifestation, this binary approach resulted in architects being responsible for ADB compliance and so-called fire engineers being responsible for non-compliances with ADB, and ‘code compliant designs’ were considered safe without any further thought and ‘non-compliant designs’ required a disproportionate level of analysis and proof (Law). The fire engineer’s primary responsibility was ‘getting approval’ for the non-compliances.
Three key problems resulted:
- ADB was taken as being correct for all buildings (not just common building situations) and as such the need for skilful assessment of safety was removed,
- Responsibility for safety was abdicated to ADB meaning that no single party (neither the architect nor the fire engineer) felt bound to care about safety when designs appeared to comply with ADB; and
- The system prioritised gaining approval for alternative approaches more than prioritising competent fire engineering (building control authorities judged designs on compliance or equivalence to ADB as opposed to whether they actually comply with the regulations).
More often than not, the regulatory process involved designers trying to persuade the building control authorities that what they were doing was, in fact, okay. The focus was not on exercising reasonable skill and care to ensure adequate safety. Provided that the designer knew a bit more than the authorities, and they were prepared to be persuasive, they could get their designs approved.
In this culture, regulatory approval was more important than actual safety and the door for gaming of ADB was well and truly open. A new wave of so-called ‘fire engineers’ – those with enough fire science knowledge to be confident and persuasive but not enough to actually be competent – was allowed to exist. This phenomenon is explained wonderfully by Dunning Kruger and shown in the figure below – a little competence can be enough to lead to unfounded confidence (deliberate or otherwise) but not enough to realise what you don’t know.
Care left the industry and the results were disastrous
In the late 90s to late 10s a perfect storm was created: a regulatory system ripe for gaming, deft gamers (designers, engineers and product manufacturers), a regulatory approvals race to the bottom, and a housing boom that rewarded cost saving over quality and safety. The so called fire engineers had enough knowledge to game their way around Approved Document B. Some were not competent enough to know whether they were doing this safely; others simply did not care. ‘Fire engineering’ had been reduced to gaming compliance, not the application of science.
I know this was not always the case, and there will be examples where the skill and care required was applied, but equally a culture of skill and care was certainly not uncommon, and following Grenfell, it is clear that the present system is not working. Hackitt identified an industry that has been ethically moribund for at least 25 years, with a culture that can be described as:
a race to the bottom caused either through ignorance, indifference, or because the system does not facilitate good practice [Dame Judtih Hackitt, May 2018].
I also know that I was not immune. In my early career, aside from in my specialism of structural fire engineering, led by my mentors, I probably spent more time learning about ADB and how to get around it than about using fire science to ensure safety. As fire engineers, we were being taught that we “live and die by our approvals”.
Hackitt identified many failings within the system, two of which are gaming of prescription and a lack of professional competence (or lack of reasonable skill and care). These failings are often seen as two sides of the same coin:
- Prescription (or being told what to do and how to do it) reduces long term competence; and
- Lack of prescription requires industry to be trusted to do the right thing and act with reasonable skill and care.
More prescriptive regulation is not the answer
We have already seen that government will increase prescriptive regulation where it is felt the industry is not doing as it should. Examples include the ban on combustible materials in external walls of relevant buildings (Regulation 7), and the introduction of BS 9414 to effectively ban desk-top studies. Whilst both may seem effective, particularly in the short term, they also both remove the need for skill and care as opposed to requiring the application of skill and care.
The prescriptive approach is particularly attractive for people on the downward curve of the Dunning Kruger graph (i.e. those who are still confident enough to make noise but have just come to realise that there is more to know than they previously thought) – it allows abdication of responsibility, excuses lack of competence and negates the need to learn. It also might seem like prescription is the only answer because things are just too complicated (for you anyway).
This does not mean that prescription is not the right approach, but there are some very significant downsides:
- It absolves those actually delivering safety for being responsible for safety.
- It removes the need for fire engineering skill. In the long-term genuine skill will disappear and the industry will not be able to spot the next disaster until it happens (which it will).
- It constrains innovation and flexibility.
- It is open to gaming. In fact, it actually promotes and rewards the behaviours alleged of Kingspan – gaining competitive advantage by deliberately gaming the system.
- It requires knowledgeable regulators to ensure adequate safety within the prescription.
- It requires the never ending game of whac-a-mole process of more prescriptive legislation being introduced each time a new loophole is found.
The alternative is to stick with functional legislation, but to ensure that those responsible for delivering on the functional requirements act with both reasonable skill and care.
In the short term, this option is perhaps less attractive. It is the incumbent system and been shown to be ineffective. It is also clear that there are not that many people with genuine fire engineering skills. Successful implementation will require considerable upskilling of the industry (not just fire engineers) and a seismic cultural shift from one of ‘getting approval’ to one of genuine care.
Fire engineers need more skill and more care
As a professional fire engineer, I can only hope that we opt for this latter approach. I love the challenge of innovation and the sense of achievement when you achieve a building that is truly different or better than before. Prescriptive regulation will prevent this happening.
Ensuring reasonable skill and care has to be the right approach [Egan, Hackitt, etc.] and has been shown to work in other industries (aviation, nuclear, chemical, etc.).
Furthermore, I also believe that a short-term lack of skill can be compensated by care. It is also called being conservative. Of course there is an argument that if you don’t have sufficient skill, you don’t know whether you are being conservative, but let’s be realistic; there is little evidence that the current system being so devoid of skill that it is incapable of delivering adequate safety. Fire incident data tells us that except for notable exceptions, buildings are adequately safe, despite a prevalence of construction defects. Where there have been exceptions, the problem has been a lack of care, not a lack of skill. If one ‘cares’ to ask whether cladding high-rise residential buildings in polyethene is a safe thing to do, it should not require a great deal of ‘skill’ to know that the answer should be “no”. Similarly, there is growing evidence of buildings not being built properly (e.g. design intent not followed through to construction and poor workmanship), but this is not a result of a skills gap – it is the result of a care gap.
Ultimately, reasonable skill and care results in optimised safety, and provided sufficient care is applied adequate safety (albeit conservative, sub-optimal safety) would be achieved even if skill is not totally developed. In other words even if there is a short term lack of skill, the incumbent system works provided there is a culture of care.
As a side note, care does not simply mean a more rigorous application of prescriptive rules or a refusal to allow departure from ADB guidance; instead, it means thinking about outcomes, why things work, why things might not work and arriving at properly considered design solutions that are properly implemented.
You cannot prescribe care
Whilst thinking about reasonable skill and care, it is worth thinking again about the prescriptive route to fire safety. Whilst the approach negates the need for skill, it does not negate the need for care. Prescriptive rules can still be gamed. At its worst, the inevitable down-skilling of industry would mean that it would not be known when such a lack of care is becoming dangerous.
Regardless of whether society wants compliance or functional legislation, care is required to ensure safety.
Given that care is required regardless, surely the benefits of a functional approach and risks of a prescriptive route mean it is worth investing in fixing the incumbent system as opposed to stepping back into the perceived comfort of prescription.
Building a culture of care
Whatever the decision, a successful future requires an industry and fire engineering profession built on a culture of care.
How can that culture of care be built? I don’t have an answer to that. But everyone has a part to play.
Your daily decisions do not only affect a single project, but they influence colleagues, they influence design team members, and they contribute to the wider culture in the industry. By keeping those contributions positive, even when under pressure, everyone can build a culture of care.
Care has been central to DFC. In fact, it is why DFC was set up in the first place – a deep seated need by Jonny and Craig to care about quality, care about the buildings they work on, care about their clients, and care about their team. The team, in turn, cares (see our mugshots below). However, I will leave it to a future post to expand on the part that care plays in DFC, and whether or not DFC are adequately contributing to the wider culture of care.
In the meantime, I hope for regulatory frame work that continues to allow flexibility, innovation, improvement through genuine fire engineering and an industry that rewards, not reprimands, care.
– Neal Butterworth, hoping we can all care
- Posted by Matthew Eyre
- On 9th February 2021