Beyond Accessibility to Equal Egressibility
Access to buildings in England is addressed within the Building Regulations through Approved Document M and within the fire safety industry, we are equally concerned with egress. In the event of a fire, having access to a space does not necessarily mean you are going to be able to escape from it, not on your own anyway.
Consider this instance of mobility impairment:
You’ve broken your leg and are using a wheelchair to help you move around. You might:
- Use the platform lift to get into a restaurant
- Ask the station staff to get the ramp for your train
- Take the lift to your 10th floor office.
Now consider a fire in any of these situations:
- The platform lift is not risk-assessed for use in a fire
- There are no ramps or staff trained in using them on the train
- The lifts are not evacuation lifts; there’s a sign saying “In case of fire, do not use the lift”.
In each event you are reliant on others to help you escape, often having already watched everybody else leave of their own accord. You might be directed to a refuge, or you might be left where you were while you wait for help.
How do you feel?
In many instances, a carry-down procedure using an evacuation chair is implemented and you get out of the building. Great! But your wheelchair is still inside… How do you get home without it? How do you get to work the next day?
It seems that while independent access is expected, independent egress is often overlooked.
Requirement B1 of the Building Regulations states that “A building shall be designed and constructed so that there are appropriate provisions for the early warning of fire, and appropriate means of escape … to a place of safety outside the building capable of being safely and effectively used at all material times.”. Approved Document B (ADB) (2019) states that the Secretary of State’s view is that this is met if “All people can escape to a place of safety without external assistance.”.
I think most in the built environment are aware of the wording in ADB, but the words ‘without external assistance’ are sometimes glossed over. There are then clauses within guidance which would reduce the reliance on external assistance, but I rarely see these implemented in my experience of buildings. Here are a few examples:
- BS 9999 (2017) distinguishes that “the preferred method of evacuation for disabled people is by horizontal evacuation to the outside of the building or another fire compartment or by evacuation lift”.
- BS 9999 also states that lifts not explicitly designed for evacuation may be used if certain criteria are met.
- BS 9999 states that where carry up/carry down procedures are to be used, the staircase design should reflect that strategy.
- BS 9991 (2015) recommends the fitting of handrails, step-edge marking, orientation information, tactile information and audio signals within residential buildings.
- BS 5839-6 (2019) recommends that a facility for automatic transmission of fire signals to the fire and rescue services should be provided where occupants have a mobility or sensory impairment that may impact their evacuation, or have a speech or hearing impairment which would preclude telephone communication with the fire and rescue services.
Some of the guidance seems to contradict the above: the focus on refuges within ADB; guidance for carry down procedures; and the expectation that evacuation lifts will be driven by a trained operative rather than the user, all demonstrate that evacuation is expected to rely on external assistance.
Other aspects of guidance are difficult to interpret. The BS 5839-6 recommendation, for example, isn’t clear with regards to whether these facilities should be provided as an anticipatory measure in every flat, or whether they should be retrospectively fitted for residents who disclose a need.
The National Fire Chiefs Council (NFCC) published their response to the recent consultation on the implementation of the Building Safety Act 2022, stressing that the current residential design guidance allows the design of a building which does not meet the requirements for safety in occupation. They gave the example of a tall single staircase building without evacuation facilities for those disabled by the design. They call for a review of ADB, but also make the point that the industry may need to go beyond the minimum requirements of ADB in order to demonstrate safety.
My interpretation of BS 9999 is that lifts should be the default evacuation method for those unable to use stairs in non-residential multi-storey buildings. Implementing evacuation lifts, especially in existing buildings, can be perceived as challenging as there are many criteria to meet for a designated evacuation lift. This includes: space for refuges; trained staff; associated power supplies; controls and communication systems. BS 9999 does explicitly state, however, that non-evacuation lifts may be used, providing appropriate criteria are met and that firefighting lifts may be used. Therefore, there is scope for the use of lifts for evacuation in many instances.
Planning requirements in London specify that in any building where a lift is provided at least one lift should be an evacuation lift. The draft guidance to accompany the London Plan discusses that “all building users should be able to evacuate from a building with dignity and by as independent means as possible” but still considers that user-driven lift evacuation is an “alternative” method to be considered only when a lift driver is not present, rather than the default. Evacuation, therefore, still relies on external assistance in many cases.
Using lifts for evacuation has many potential benefits including:
- They are safer for those with mobility, cognitive and sensory impairments, enabling them to avoid stairs and crowded areas;
- Mobility aids can be taken with the person evacuating;
- Where user-driven, they enable independent and dignified evacuation;
- They reduce the need for trained staff and management to facilitate evacuation;
- They’re helpful to children and family groups;
- They can speed up evacuation from tall buildings;
- They prevent the need for transfer to evacuation chairs, which is not safe for many.
We need to move away from the idea that refuge spaces are a panacea. They rely heavily on management having a clear understanding of their responsibilities and the implementation of emergency evacuation plans. There are several problems with this: for many, assistance requirements are temporary or undisclosed; management procedures are often not robust enough and staff are not well trained to assist; moving to an evacuation chair can present risks to a disabled person and staff are often not on site within residential buildings. As part of my Fire Risk Engineering degree, I conducted research, asking the residents of flats what was the most important to them when evacuating a building. Out of the 6 participants who had a Personal Emergency Evacuation Plan (PEEP), all reported that their landlord or managing agent had been reluctant or had refused to provide one. Participants in this study ranked independent evacuation as the most important factor for them.
The London Plan is a step forward, but further consideration of self-driven evacuation is needed. In high-occupancy buildings, evacuation may need to be managed, but where small numbers of people are using lifts to evacuate, is it safe or ethical to require staff to stay in the building to drive the lift and to expect people to wait for assistance in evacuating?
We must also think more carefully about multi-storey residential buildings, which typically do not have refuges. Current provisions seem to rely on the idea that once in the communal corridor, a disabled person is safe from the fire. This ignores the need for onward evacuation when firefighting commences and how this might occur without using the lift or relying on ‘rescue’. Rescue occurs when there is a danger to life and does not equate to assisted evacuation. Why should it be that disabled people are expected to accept a lower standard of safety than their neighbours? In many instances, the lift in their building will not enter emergency mode and would be safe to use.
As much as the industry is concerned with the impracticality of providing refuges or evacuation lifts, Smedburgh et al . argue that the environment is modifiable while a person’s impairments may not be. Their work developed an instrument to identify, quantify and address egressibility within public buildings in Sweden. The result of this work, the Egress Enabler tool may prove useful in assessing buildings for egressibility.
It is time to stop overlooking the egressibility of buildings and to begin finding solutions. It is time to consider what we already know about evacuation (the government recently commissioned a summary of the research into high-rise residential evacuation), what is already written within guidance and to start asking building users what they need. This article focuses on the use of lifts for evacuation as a measure which can be easily implemented, but the industry needs to be aware that vertical evacuation and mobility impairments are not the only barrier to egressibility. The industry needs to develop and implement other solutions too.
- Posted by Design Fire Consultant
- On 27th January 2023
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