A Critical Appraisal of the UK’s Regulatory Regime for Combustible Façades

Abstract

The Grenfell Tower fire has brought the regulatory system that permitted combustible materials on high-rise buildings in England into question. At the heart of that system is the BS 8414 test, and the BR 135 criteria used to demonstrate compliance with the Building Regulations. The test is empirical and the criteria arbitrary: there is no scientific link between test performance and how a building will perform in the event of a fire; nor any detailed analysis of why fires spread through façade systems which have passed the test. Following the Grenfell tragedy, the UK government commissioned a series of tests on Grenfell Tower-type facades, using BS 8414. This paper critically analyses BS 8414, the BR 135 criteria and the government tests. It shows that important aspects of the standard are poorly defined: the heat flux imposed on the façade is not measured and the fire load can vary by at least a factor of 2; the ambient ventilation has a significant impact on the thermal attack but is not adequately controlled; judicious location of the cavity barriers can confer compliance or failure on a façade system. As the vehicle for allowing combustible products on tall buildings, the test does not specify the extent of cavity barrier deployment, while ignoring features present in real buildings, such as windows, vents or other openings, despite a test rig height of more than 8 m. There is no restriction on debris, or molten or burning droplets falling from the façade during the test. The BR 135 criteria only specify that the test must run for the full 60 min duration without flames reaching the top, and the temperature rise at thermocouples 5 m above the fire chamber must only remain below 600°C for the first 15 min. It is unclear how the fire safety of the occupants behind the façade system can be ensured, when the criteria specify such a high temperature for such a short period, so early in the test. There is no direct connection between the façade system in the test and the actual façade system the results deem compliant. Worse, “desktop studies”, using large-scale test data, have been allowed to confer compliance on systems which have never been subject to the test. The UK government tests used heavy-duty welded aluminium “window pods”, preventing flames from entering the cavity within the façade. They also used a disproportionately large number of vertical and horizontal cavity barriers of a higher specification than required by statutory guidance. These aids to meeting the criteria are not proscribed by BS 8414-1 but are not commonly found in actual rainscreen system designs.