PAS 9980 (a draft British Standards Institution Code of Practice) is currently used by MHCLG to support risk-based assessments of external walls. Once the Fire Safety Act 2020 becomes effective, these assessments will be mandatory as part of a Fire Risk Assessment for all flat blocks. PAS 9980 seems to replace IEP Consolidated Advice Note. However, some believe it could also replace the need for an EWS1 Assessment. In the beginning, it should be noted that PAS9980 is designed to assess the residential safety of a particular block. It doesn’t consider whether the block is compliant with current regulations or whether it can be considered a suitable property for securing an insurance policy or mortgage. Initial thoughts are that PAS9980 could spell doom for property owners and residents. This could result in a lock-up of flats for many years and potentially lead to an avalanche of legal actions.
PAS 9980 is a positive example of how hard it is to create robust assessments for fire behaviour in external walls. Its overwhelming length at more than 180 pages, subjectivity (and confessed technical incompletion) highlight the futility of using risk-based design for external walls for the mainstream (largely repetitive). There were some intelligent and experienced contributors to the document. Additionally, the history of the modifications to official approved external wall response-to-fire guidance is helpful but somewhat erroneous. Some technical passages are beautifully written in contrast to the harsh wording of sections written by or influenced attorneys. The best thing about PAS 99880 is that you can print it out.
The problem with the document is not its technical content and size. They are primarily sound. The main problem stems from the assumption that those responsible for it believe the EWS1/Advice Notes problems were due to insufficient information. The belief that if all of the data about the fire performance of exterior walls is gathered and presented to assessors, they can form reliable, robust, and proportionate conclusions seems to be the key to the solution. As a result, we have compiled a list of non-exhaustive flaws in the PAS 9980. FR Consulting is here to help you.
- It’s complex, lengthy, confusing, inconsistent, and sometimes misleading
- Is unable to identify the problem
- Substantially relies upon publicly available knowledge of product performance, which is inherently biassed.
- Key dangers are missing information such as the timber frame
- This list is not complete and can’t stand alone in light of the intended classifications
- Unfair and unreasonable for assessors
- Restrictive for property managers, residents
- This will result in inconsistent outputs that are clumsy and inaccurate
- Shuns accountability
Failure to State the Problem
Let’s look at the problem. In many opinions, PAS9980 doesn’t clearly state its purpose. This makes it virtually impossible to complete a complex task. It is essential to review the context of PAS 9980 to understand its purpose. Let’s start with the functional requirement to comply with Building Regulations. This is generally taken to be the standard for safety.
Functional requirements like these are a call to common sense. They’re vague and can be interpreted in many ways. They can hide behind it for all of its shortcomings in guidance. There are two main aspects to B4.1 you need to be aware of:
- Examine the potential fire performance of an exterior wall
- Assessment ‘a. b. Assess.’ by the ‘evaluation requirements’
In this case, the evaluation criterion for fire resistance is that external walls ‘shall sufficiently resist the spread.’ Referring to the first part of the assessment or taking the help of Facade Consultants. The criteria of “adequately,” which is not defined in PAS 9280 or the Regulations, is known for being incredibly unhelpful. However, we will return to clues scattered around the document.