Please find below our
answers to the questions within the consultation proposals. We have also
included a separate section at the end titled ‘other issues’.
Question 1: Do you agree with the proposed approach (set out
in paragraph 20) of implementing the intent of the Measure through a
combination of commencing section 1 of the Measure and making changes to the
Building Regulations?
No.
The overall
policy objective
There is,
manifestly, a need to reduce or eradicate the number of fire deaths in Wales
and FMB Cymru appreciates and supports the overall policy objective to reduce
fire deaths in Wales. However, the solution the policy objective proposes is to
achieve a reduction in fire deaths and address the issue through new build and
converted dwellings only. Our
understanding is that the main instances of fire deaths in Wales occur in older
properties that have not been maintained well. It appears that a majority of deaths
are caused by a particular failure to maintain battery powered smoke or fire
alarms. Given this appreciation of the problem it is not clear to us how the
proposed legislation will cause other than a minimum reduction in the dreadful
loss of life. It is not at all clear
that the legislation in its current from will achieve its aim.
Partners have introduced evidence, we understand, (informed by South
Wales Fire and Rescue) that in South Wales, a vast majority of all deaths
recorded from house fires between the years 2000 and 2009 were recorded in
homes without hard-wired smoke detectors installed. In this respect, given that
since 1992 the mandatory installation
of hard-wired smoke detectors in all new homes in Wales has been enforced
through building regulations, the evidence potentially demonstrates that the
vast majority of all deaths from fire within this period came from homes built
pre 1992.
Evidence given to the legislative Committee
[33] Val
Lloyd: The committee has received evidence questioning whether the
statistics provided in the explanatory memorandum, which relate to death and
injuries from fire in all dwellings in Wales, are
[34] ‘sufficiently focussed to accurately assess the
benefit of the proposed Measure’.
[35] Of the figures provided in paragraphs 3.8 and 3.9
of the explanatory memorandum, can you clarify how many of the fires occurred
in newly built homes and how many were in older housing stock? Secondly, can you also
provide details of the types of dwellings within which the fires occurred; for
example, house, flat or caravan?
[38] Ann Jones: I have been unable to get hard
figures but we are working on that. I will try to get some figures that break
down the number of deaths and injuries in new properties, as opposed to deaths
and injuries in older properties. I will try to do so during the course of your
scrutiny of this proposed Measure. I do not know whether you, as a committee,
could write to Communities and Local Government to ask whether the figures are
easily collected, because we do not want to put an awful lot of burden on
overworked staff within the fire service.
[39] Rosemary Butler: If you could find those
figures, Ann, and submit them in written evidence that would be helpful. We
will also make some inquiries…
Following this, at Ms Jones’ final evidence session on the 14th
October 2010 the following conversation took place on this issue.
[8] Rosemary Butler: When you last gave
evidence, you advised the committee that you would try to provide a breakdown of
the total number of deaths and fires in homes in Wales by the age and type of
property. Are you now able to provide this information?
[9] Ann Jones: Sadly, no, though it is not for
the want of trying. Apparently, the data are not collated in a fashion that
would make them available to the committee. I spoke to my local fire service in
north Wales and said that, if it could provide me with a list of property fires
over the last 10 years, I would attempt to go around and check how old the
buildings were. I could do that only in Rhyl and Prestatyn, I suppose, so the
exercise would easily outweigh the data.
As the above shows, the evidence
given to the Legislative Committee was not at all robust; we consider that the
Welsh Government should undertake further research, in order to ensure that any
new legislation enacted would actually achieve the overall objective. This
research should be particularly directed to measuring the relative value of
retro fitting hard wired smoke alarms to all properties.
The FMB is concerned that data used in the WG argument uses the data for all
fire deaths, to identify how many lives might be saved and injuries prevented
if sprinklers are installed in all new dwellings. The argument uses the total
fire deaths in all homes that have occurred in Wales and the Impact Assessment
is based exclusively on the Welsh Government’s estimates of the number of new
homes likely to be built in the future, the evidence plainly does not
differentiate between the occurrences of fire that occur in newly built homes
and those that occur in the existing stock. The issue is what can be done the
save the majority of lives lost which would appear to be in older
properties?
The Impact Assessment informs us, there will be around 35 lives saved if
sprinklers are installed in new buildings. However, given these figures are
based on the total fire deaths in all homes that have occurred in Wales. The
evidence clearly does not distinguish between deaths from fire in new homes and
those that in existing stock. This would appear to be a major flaw in the
calculations that leads to a distorted depiction of the potential for lives
saved by installing sprinklers in new homes.
.
We can
refer to the research given by our partners in the Welsh Construction Federation
Alliance around the number of deaths and injuries that have occurred as a
result of house fires in Wales. This research based directly on information
provided to partners by all the Fire and Rescue Services in Wales. The have
again used the presence of a hard wired smoke detector to establish whether or
not a home would be a recently constructed property or part of the older
existing stock. However, to be clear, hard wired smoke detectors were made
mandatory in 1992, which means the properties that benefit from these devices
could still be more than 20 years old. As such, when we say ‘recently
constructed home’, it is important to remember that such properties could still
be quite mature in comparison.
In
terms of the above, according to our data, nearly 80% of all fire deaths in
Mid, and West and South Wales between the years 2002 and 2012, occurred in
homes without a hard wired smoke detector. Furthermore, more than half of
injuries also occurred in homes without a hard wired smoke detector in South,
Mid and West Wales. Please see the tables below for more information.
Data relating to South Wales
|
YEAR
|
Deaths (hard wired smoke alarm)
|
Deaths (no hard wired smoke alarm)
|
Injuries (hard wired smoke alarm)
|
Injuries (no hard wired smoke alarm)
|
Fire related deaths in dwelling fires
South Wales
|
Fire related injuries in dwelling
fires South Wales
|
2002
|
0
|
10
|
23
|
95
|
10
|
118
|
2003
|
0
|
13
|
31
|
131
|
13
|
162
|
2004
|
4
|
4
|
29
|
87
|
8
|
116
|
2005
|
2
|
9
|
56
|
60
|
11
|
116
|
2006
|
0
|
3
|
22
|
45
|
3
|
67
|
2007
|
1
|
5
|
25
|
71
|
6
|
96
|
2008
|
2
|
7
|
42
|
32
|
9
|
74
|
2009
|
0
|
5
|
54
|
50
|
5
|
104
|
2010
|
0
|
2
|
65
|
68
|
2
|
133
|
2011
|
3
|
2
|
50
|
20
|
5
|
70
|
2012
|
5
|
1
|
47
|
45
|
6
|
92
|
TOTALS
|
17
|
61
|
444
|
704
|
78
|
1148
|
%
|
22%
|
78%
|
39%
|
61%
|
|
|
Data relating to Mid and West Wales
|
YEAR
|
Fire related deaths hard wired smoke
alarm
|
Fire related deaths non-hard wired
smoke alarm
|
Fire related injuries hard wired
smoke alarm
|
Fire related injuries non-hard wired
smoke alarm
|
Fire related deaths in dwelling fires
Mid/West Wales
|
Fire related injuries in dwelling
fires Mid/West Wales
|
2002
|
0
|
6
|
56
|
156
|
6
|
212
|
2003
|
2
|
6
|
81
|
135
|
8
|
216
|
2004
|
0
|
8
|
67
|
131
|
8
|
198
|
2005
|
1
|
5
|
50
|
108
|
6
|
158
|
2006
|
0
|
1
|
57
|
110
|
1
|
167
|
2007
|
0
|
5
|
75
|
69
|
5
|
144
|
2008
|
1
|
6
|
53
|
84
|
7
|
137
|
2009
|
4
|
5
|
86
|
47
|
9
|
133
|
2010
|
2
|
6
|
64
|
33
|
8
|
97
|
2011
|
4
|
2
|
104
|
22
|
6
|
126
|
2012
|
1
|
1
|
57
|
66
|
2
|
123
|
TOTALS
|
15
|
51
|
750
|
961
|
66
|
1711
|
%
|
23%
|
77%
|
44%
|
56%
|
|
|
In
this respect, if we assume that it is unlikely anyone would remove a hard wired
smoke detector from a dwelling, it is reasonable to assume that these deaths
occurred in homes built pre 1992. This therefore suggests that there are
significantly more deaths occurring in the older existing stock than in newly
built homes. This in turn suggests that installing fire sprinklers in newly
built homes only, might not reduce these instances of death and injury in future
years, given that the legislation will not cover the existing stock. Therefore,
we believe the figures quoted for lives saved and injuries prevented as a
result of the Preferred Option should be reconsidered, to ensure they are sound
and robust. We also believe this evidence somewhat contradicts the comments
made within the Impact Assessment (page 6), that the Committee
received evidence that the Measure would possibly eradicate fire deaths in Wales.
In this respect, we are yet to see any evidence from the Welsh Government to
corroborate this important statement and given our evidence above, we believe
this seems to be a very dangerous and rather ill-considered commitment statement
to offer Welsh Ministers.
In
terms of North Wales, similar data is only recorded from 2010 onwards, and does
not distinguish between hard wired and battery operated smoke alarms. However
the figures are very similar to those witnessed in other areas of Wales. The
table below sets the evidence out and demonstrates that over the period 2010 -
2012, roughly 73% of fire deaths and nearly half the total injuries occurred
in properties without a smoke alarm fitted. Furthermore, as you can see from
the table below, even though the percentage of fires that occurred in homes
without smoke detectors was relatively small, they still accounted for the vast
majority of deaths from fire that occurred over this period.
Data relating to North Wales
|
Year
|
% Proportion of residential fires where no smoke
alarm present
|
% Proportion of total deaths in fires with no
smoke alarm
|
% Proportion of total injuries in fires with no
smoke alarm
|
2010
|
16.33
|
88.89
|
34.62
|
2011
|
14.71
|
50.00
|
48.84
|
2012
|
15.96
|
80.00
|
61.54
|
TOTALS
|
15.6%
|
73%
|
49%
|
In light of the evidence above, we believe it is imperative the Welsh Government tackles the important issue of the instances of fire that occur in newly built homes versus those that occur in the older existing stock. Not only is this important to ensure the impact assessment and cost benefit analysis are based on robust evidence, but it is also critical in order to ensure the proposed legislation will achieve the aims and objectives it sets out.
Further to the above, we believe it is also important for the Welsh Government to understand the type of property that has presented the most risk from fire. In this respect, the purpose of this consultation is to determine the type of properties that should be covered by the sprinklers legislation. Therefore, when considering the number of deaths and injuries that have previously occurred in homes in Wales, in addition to considering the age of the property, it also is important to understand whether or not there is a certain type of property that is more prone to the risks from fire.
In light of the above, we believe it is crucial for the Welsh Government to revisit these aspects of the Measure and to undertake its own research into these matters, in order to ensure the impact assessment accurately reflects the potential effectiveness of the stated preferred option.
The FMB has done a brief desk top survey of the costs of retrofitting smoke alarms to existing stock. This shows that installing a surface mounted hard wired smoke detector [wiring not buried under surface] we can estimate a cost of around £250 a smoke detector. Individual house circumstances may cause fluctuations in this estimate. Providing the circuit breaker is not interfered with and the battery backup maintained, this may offer an opportunity to reduce fire deaths on a greater scale. Consideration to a heat sensitive alarm in the kitchen would be a similar cost, and these do not trigger from burnt toast. We understand that the two common causes of fire are from neglected chip pans, which would trigger heat, and cigarettes in bed, which should trigger a secondary detector. Given the average house is 2 storey; we estimate a cost of £500 a house? WE believe a study of this option and support for its implantation would have a far greater effect on loss of life in domestic fires than sprinklers in new
The FMB are of the opinion that not all the pertinent issues have been addressed adequately and the proposals need to be reconsidered to ensure these important matters are addressed.
In light of the above, despite the numerous potential flaws within the cost benefit analysis, the impact assessment, the creation of the Measure, the potential success of the measure and the viability analysis work, it would seem there is a substantial amount of evidence weighted against the adoption of the preferred option.
