Staying Safe: Disability, Fire and the Law Colin Todd, Managing Director C. S. Todd & Associates Ltd CS TA C. S. TODD & ASSOCIATES LTD
Fire Risk in Hotels Fires in UK hotels 2002 - 2008 1200 1000 800 600 400 2002 CS TA 2003 2004 2005 2006 2007 C. S. TODD & ASSOCIATES LTD 2008
Fire Risk in Hotels Fires in UK hotel bedrooms 2002 - 2008 250 200 150 100 50 0 2002 CS TA 2003 2004 2005 2006 2007 C. S. TODD & ASSOCIATES LTD 2008
Fire Risk in Hotels UK hotel bedroom fires that spread beyond room 2002 - 2008 20 18 16 14 12 10 8 6 4 2 0 2002 CS TA 2003 2004 2005 2006 2007 C. S. TODD & ASSOCIATES LTD 2008
Interfacing Legislative Regimes Fire Safety Legislation Building Regulations Equality Act CS TA C. S. TODD & ASSOCIATES LTD
Building Regulations § Building Regulations 2010 supported by AD B Scotland § Building (Scotland) Regulations 2004 (as amended) supported by the Tech Handbooks Northern Ireland § CS TA England Wales Building Regulations (Northern Ireland) 2000 supported by TB E C. S. TODD & ASSOCIATES LTD
Interfacing Legislative Regimes Fire Safety Legislation Building Regulations Equality Act CS TA C. S. TODD & ASSOCIATES LTD
Fire Safety Legislation England 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 § CS TA C. S. TODD & ASSOCIATES LTD
Interfacing Legislative Regimes Fire Safety Legislation Building Regulations Equality Act CS TA C. S. TODD & ASSOCIATES LTD
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 law CS TA C. S. TODD & ASSOCIATES LTD
Disability Defined by later speaker In a hotel, need to consider: Mobility impairment Deaf and hard of hearing people Blind and partially sighted people People with cognitive impairment CS TA C. S. TODD & ASSOCIATES LTD
Requirements for Access and Amenity Part M of Building Regulations 2010 Reasonable 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 Scotland Safe, unassisted and convenient means of access throughout the building plus accessible bedrooms CS TA C. S. TODD & ASSOCIATES LTD
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) CS TA C. S. TODD & ASSOCIATES LTD
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 CS TA C. S. TODD & ASSOCIATES LTD
Potential Conflicts CS TA 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! C. S. TODD & ASSOCIATES LTD
Misconceptions and Misunderstandings CS TA 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 C. S. TODD & ASSOCIATES LTD
Two Main Issues CS TA Evacuation of disabled people from upper floors Warning of deaf and hard of hearing people C. S. TODD & ASSOCIATES LTD
Evacuation Problems CS TA 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 C. S. TODD & ASSOCIATES LTD
Warning Problems Visibility of visual alarm devices (VADs) No code for location and siting of VADs Are vibrating devices necessary? CS TA C. S. TODD & ASSOCIATES LTD
Philosophy EQUIVALENCE: The basis of all solutions Leads inexorably to correct answers Think it! Commit to it! CS TA C. S. TODD & ASSOCIATES LTD
Menu of Solutions (Management) Management commitment Identification of special needs Sufficient staff with proper training Instructions to guests CS TA C. S. TODD & ASSOCIATES LTD
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 CS TA C. S. TODD & ASSOCIATES LTD
Final Thought “The only disability in life is a bad attitude” Scott Hamilton CS TA C. S. TODD & ASSOCIATES LTD
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