Getting to grips with the revised Part K

Health Technical Memoranda (HTM) give comprehensive advice and guidance on the design, installation, and operation, of specialised building and engineering technology used in the delivery of healthcare. They include use for when developing governance and assurance systems which take account of risk, and the safety of patients, staff, and visitors.

They are issued by NHS England, and focus on healthcare-specific elements of standards, policies, and up-to-date established best practice.1 They are applicable to both new and existing sites, and are for use at various stages during the whole building lifecycle. In the hierarchy of guidance documents, they are akin to guidance issued under Article 50 of the Regulatory Reform (Fire Safety) Order 2005.2 As such, compliance with the guidance may be relied upon as tending to establish legal compliance with fire safety duties. Fire safety is covered by the HTM 05 series, also known as Firecode, which includes the subjects shown in Table 1.

The definition of a complex healthcare premises in Part K is a ‘hospital or other healthcare premises which place a dependence on staff for evacuation’. This, however, only touches the surface of what one can find in a complex healthcare premises, with features which are not common, or less common, to other buildings, as follows:

Meeting the needs of patients

• Very high dependency patients, for whom the act of evacuation can only be in exceptional circumstances, and may not be immediately possible, for instance in operating theatres.
• Dependent patients who rely on staff to evacuate them.
• Patients with conditions such as dementia who need close supervision during a fire emergency.
• Patients with other behavioural conditions which may cause them to be disruptive during evacuation, or who have malicious fire-raising traits.
• Children undergoing treatment or care who may have relatives with them or nearby.
• Business continuity is vital to ongoing patient care, and may in itself be a life safety-critical element.

Evacuation protocols

• A high level of training and competence for staff is required.
• Evacuation not routinely commenced on the fire alarm sounding in many patient treatment or care areas. This is due to the risks which may be posed by an evacuation. Evacuation is only commenced when necessary.
• Progressive horizontal evacuation is the usual methodology for evacuation — i.e. away from the fire to initially a place of relative safety on the same floor.
• Specialised evacuation equipment and arrangements to ensure continuity of care away from the fire compartment (including availability of medical equipment, medication, and patients’ records).
• An environment in which a sounding fire alarm can be extremely disruptive and distressing.
• A greater emphasis on the importance of fire wardens, both in preventing a fire, and in fire safety, should one occur.

Medical gases and building set-ups

• Piped medical gases, including oxygen and nitrous oxide (50% oxygen), can aid in the rapid development of fire.
• Extensive use of cylinders, including those containing oxygen, can aid the rapid development of a fire, while cylinders exposed to heat can explode with devastating effect (e.g. the Great Ormond Street Fire in 2008).
• Extensive use of compartmentation and sub-compartmentation to restrict the growth of a fire.
• Interaction of life-critical complex engineering systems.
• The separation of any higher-risk areas in a ward or department into a 30-minute fire protected hazard room.

Other hazards

• Arson is one of the greatest hazards.

The above list is only a small sample, but it is vital that the risks are properly assessed and managed to minimise damage and disruption. For example, a historic fire incident involving the medical gas pipeline system at a hospital caused extensive fire damage, while a similar more recent fire at a hospital caused relatively minor fire damage (see Figures 1 and 2). The main difference was that the medical gas pipeline system was isolated at an early stage in the latter — a product of an effective training needs analysis and management system.

If you are considering completing FRAs in complex healthcare premises, an in-depth knowledge of Part K, and some knowledge of the rest of Firecode, are essential. Some of the methodology in Part K may be useful in other buildings, for instance when remediating existing fire seals in fire-rated walls where the manufacturer of the seal is not known (HTM 05-03 Part K, Appendix A).

Part K is a newly revised document, and provides a pragmatic means to achieve regulatory compliance. Familiarity with the document would be helpful for the Continuing Professional Development of professional persons completing FRAs.

Notable elements in the revised Part K

Risk Assessments

Primary: A primary fire risk assessment (FRA) is now required for the whole building, including common areas, and will include building management arrangements such as the fire strategy, fire alarm system, external wall system, and compartmentation.

Secondary: A secondary FRA is required to locally assessed or managed areas such as wards or departments. The methodology outlined in PAS 793 is generally adopted, although the risk matrix is 5 x 5, to fit with NHS reporting systems.

External wall systems

Guidance on external wall risk assessment is included, and follows the methodology in PAS 9980.⁴

Alignment to PAS 79

The most severe level of potential consequences resulting from a fire has been amended to ‘catastrophic’, to align with PAS 79. While the revised HTM states that it is not necessary to provide indicative timescales for completion of the recommendations within the FRA, it is essential and vitally important that a level of priority and importance to these recommendations is afforded within the relevant management system. Action must be taken immediately if there is catastrophic risk, or if risks can be reduced by simple immediate action.

‘As low as reasonably practicable’ (‘ALARP’)

Emphasis on the legal requirement to reduce the risk to ‘as low as reasonably practicable’, i.e. the point at which the benefits of risk reduction become grossly disproportionate to the cost. This will vary, as the risk varies, and includes not only financial cost, but equally cost in terms of reductions in the ability to provide treatment or care for patients.

Proportionality

An area in which all persons can easily and quickly evacuate will have a different risk profile to one in which the act of moving very highly dependent patients may endanger their lives. In the case of the latter, the benefits are likely to be far higher than in the former, and thus the point at which the costs become ‘disproportionate to the risk’. It is this which the FSO differentiates at the start of many of the Articles by including e.g. “17.-(1): ‘Where necessary in order to safeguard the safety of relevant persons”. This means that there may be variations in, for example:

a) The acceptable standard of fire doors.

b) Maintenance regimes — both in frequency and applicable standards.

c) The provision of fire extinguishing media.

d) The level of training.

e) The frequency and type of evacuation exercise.

f) Any such variation should be supported by, and detailed in, a fire safety protocol (HTM 05-01 Appendix E) or training needs analysis (HTM 05-03 Part A).

Competence

There are many reading this article who will be fire risk assessors. As is clear from the aforementioned bullet points, complex healthcare premises are very different from a typical factory, office, or shop, and more complex than even a high-risk residential building.

FRAs may be undertaken by both (or either) internally employed staff or externally appointed contractors. Whatever the appointment status of the fire risk assessor, a robust process of due diligence should be employed to ensure that the appointed fire risk assessor holds an adequate level of competence, to the satisfaction of the responsible person. Only suitable persons who have relevant comprehensive training or experience in FRAs should assess healthcare premises. The level of the training and experience should be commensurate with the complexity of the premises to be assessed. Where relevant, the Fire Safety manager and appointed Authorising Engineer (Fire) should be consulted.

The Fire Sector Federation has produced an Approved Code of Practice: a national framework for fire risk assessor competency5 to establish industry standards for assessing the competency of individuals who conduct FRAs. The guidance includes matters of behaviour and details of the knowledge, skills, and experience expected for a competent fire risk assessor. The Code sets out the requirements for fire risk assessors for:

• appropriate third-party certification and/or accreditation and membership of professional bodies.
• core competencies.
• functional requirements for specific sectors.
• methods of assessing competence of persons.
• competency assessment recording and reassessments.
• maintenance of competence training and Continuing Professional Development.

Details of competence — such as records of training, knowledge, and experience — must be checked, including the risk assessment and method statements. In addition, it is important that the Authorising Engineer (Fire) validates the efficacy of at least a sample of fire risk assessments completed, including areas where there are very high dependency patients.

Remediation of existing passive fire protection (fire compartmentation), and fire door maintenance

More comprehensive guidance on assessing and maintaining fire doors has been included. It outlines different options for existing fire doors that may not meet current standards, such as accepting ‘notional’ fire-rated doors if professionally assessed as likely to perform adequately, and upgrading them with new seals/strips as opposed to full replacement. Competent assessors must evaluate fire compartmentation, including fire doors, against their intended purpose in the fire strategy, considering factors such as fire load, patient dependency, and evacuation times.

There is a new chapter on maintenance, recommending that the frequency of it should be risk-based and evidence-backed. The overriding risk to healthcare from contamination, and the risk of infection, mean that there should be a proportionate maintenance programme that is unlikely to pose a risk to patient safety. This may result in varying the frequency of checks from generally accepted standards and recommendations, with a greater emphasis on utilising local staff. See also HTM 05-03 Part B for fire alarm maintenance.

Appendices now include guidance on assessing the remediation of existing passive fire protection, and a hazard room assessment matrix. In the case of existing fire compartmentation seals which require remediation, the process outlined in Figure 4 should be adopted.

Other sources of information

Part K is, in part, a wayfinder to information provided by other organisations. This includes guidance documents from the National Association of Healthcare Fire Officers, IHEEM, the National Fire Chiefs Council, and the British Standards Institute. It supplements, and advances for complex healthcare facilities, the information in the Home Office Guide to Fire Risk Assessment in Healthcare Premises.6 It also provides information for mental health facilities.

The revised Part K provides extensive guidance and a methodology to achieve a ‘fire safe’ environment in complex hospital environments, where the risk is to be reduced to ‘as low as reasonably practicable’. However, the process relies on the professional completing the assessment to be competent — not only in completing fire risk assessments, but also in the specific and unique environment of complex healthcare.

References

1 Health Technical Memorandum 05-03: Operational provisions Part K: Guidance on fire risk assessments in complex healthcare premises. NHS England, 2024. (Wales, Scotland and Northern Ireland have their own respective WHTMs, SHTMs etc).

2 The Regulatory Reform (Fire Safety) Order 2005.

3 PAS 79-1: 2020. Fire risk assessment — Premises other than housing. Code of practice. bsi. 31 December 2020.

4 PAS 9980: 2022 Fire Risk Appraisal of External Walls and Cladding of Flats. bsi. January 2022.

5 Approved Code of Practice: a national framework for fire risk assessor competency. Fire Safety Federation, 2020. https://tinyurl.com/mwrzed7m

6 Guidance: Fire safety risk assessment: healthcare premises. Home Office, 25 September 2006.