Fire Safety Policy

1. Legislation

The primary legislation for fire safety is the Regulatory Reform (Fire Safety) Order 2005, the Building Safety Act 2022 and the Fire Safety Act 2021. Other related legislation includes the Fire Safety (England) Regulations 2022 and Section 156 of the Building Safety Act.

The Fire Safety Order 2005 covers general fire precautions and other fire safety duties, which are needed to protect persons in cases of fire, in and around premises. The Order requires fire precautions to be put into place where necessary, and to the extent that is reasonable and practicable. Responsibility for complying with the Order rests with the 'Responsible Person'.  

The Building Safety Act 2022 came into force on 1st April 2023 and introduces new duties for the management of fire and building safety in high-rise residential buildings. As of 1st October 2023, the new regime of the Building Safety Act 2022 came into law, bringing about changes to the requirements for higher-risk buildings, and introducing the Building Safety Regulator as the building control authority for higher-risk buildings. The new legislation will help people be and feel safer in their homes, and will change the way buildings are designed, constructed, and managed.

It overhauls existing regulations, creating lasting change and making clear how residential buildings should be constructed, maintained, and made safe.

The Act creates three new bodies to provide effective oversight of the new regime: the Building Safety Regulator, the National Regulator of Construction Products, and the New Homes Ombudsman.

Together, these changes mean owners will manage their buildings better, and the home-building industry has the clear, proportionate framework it needs to deliver more, and better, high-quality homes.

The Fire Safety Act 2021 clarifies that where a building contains 2 or more sets of domestic premises, the FSO applies to:

• the building’s structure and external walls (including windows, balconies, cladding, insulation and fixings) and any common parts
• all doors between domestic premises and common parts such as flat entrance doors (or any other relevant door)

The Fire Safety Act came into force on 16th May 2022. The Act clarifies the Fire Safety Order to make it clear that Responsible Persons must consider these parts when conducting fire risk assessments. If you contract out this work, you must make sure that those engaged to complete the fire risk assessment include those elements detailed above, as you are responsible for complying with the FSO and liable for any necessary remediation.

Section 156 of the Building Safety Act 2022

This new legislation has the effect of amending the Fire Safety Order to:

• require that all Responsible Persons must record their completed fire risk assessment, in full (where previously only specific information was required to be recorded)
• require that all Responsible Persons must record the identity of any individual (their name), and/or, if applicable, their organisation (name) engaged by them to undertake/review any or all of the fire risk assessment and share this with residents of multi-residential unit premises where appropriate.
• require that all Responsible Persons must record their fire safety arrangements (demonstrate how fire safety is managed in your premises)
• require that all Responsible Persons must record (and, as necessary, update) their contact information, including a UK-based address, and share this, along with the identified fire safety risks, preventative and protective measures, and any competent persons nominated to assist with firefighting and detection measures, with other Responsible Persons and residents of multi-domestic unit premises where applicable
• require that all Responsible Persons must take reasonably practicable steps to ascertain the existence of other Responsible Persons who share, or have duties in respect of, the same premises, and of Accountable Persons (which are a new legal entity made under the Building Safety Act in the case of higher-risk residential buildings) in relation to the premises – they must then identify themselves to said persons and cooperate with Accountable Persons so that the Accountable Persons can carry out duties imposed by the Building Safety Act 2022;
• require that departing Responsible Persons must share all ‘relevant fire safety information’ with incoming Responsible Persons
• require Responsible Persons of a building containing two or more sets of domestic premises to provide residents with relevant fire safety information in a format that is easily understood by the residents
• increase the level of fines for some offences
• strengthen the status of statutory guidance issued under Article 50 of the Fire Safety Order

There is also a legislative requirement that, where the Responsible Person appoints a person to make or review the fire risk assessment, they must be competent. If you do appoint a fire risk assessor, you must ensure they are competent to do so, in terms of having sufficient training and experience or knowledge and other qualities. It remains the case that the Responsible Person has a duty to make sure that a suitable and sufficient fire risk assessment is completed.

There is other legislation relating to fire safety, including the Dangerous Substances and Explosive Atmospheres Regulations.  The requirements of these regulations are subject to further Imperials Chemical Safety policies.

2. Roles and responsibilities

Imperial College of Science, Technology, & Medicine is designated as the 'Responsible Person'. The University Management Board, chaired by the President, is accountable and, although it delegates day to day duties to the Faculty Principals, the Chief Operating Officer, Chief Property Officer, Director of Property & Major Projects, and the Fire Safety Team, it remains responsible for ensuring that:

• General fire precautions are taken to ensure the safety of staff, students, contractors, visitors, and members of the public.
• Suitable and sufficient risk assessments are carried out and regularly reviewed.
• Arrangements are put into place for the effective planning, organisation, control, monitoring, and review of the preventative and protective measures.
• Ensuring compliance with all other fire safety legislation.

2.1 General Responsibilities

Fire safety is everyone's responsibility, and this is documented in Article 5 of the Fire Safety Order 2005.  All staff, students, contractors, and visitors are required to follow general fire precautions in the extent that is under their control. All relevant individuals are required to follow established procedures and cooperate with appointed Imperial staff in order to achieve the highest standards of fire safety.  This includes minimising the amounts of combustible materials present in buildings, ensuring the safe use, storage and disposal of flammable substances, and avoiding misuse of fire safety equipment, as well as complying with the Imperial Smoking Policy.

2.2 Specific responsibilities

The President

The President, as the chair of the University Management Board, is the designated spokesperson for the “Responsible Person" for Imperial. They delegate duties to the Faculty Principals, the Chief Operating Officer, Chief Property Officer, Director of Property & Major Projects, and the Fire Safety Team, but remains responsible for ensuring that:

• General fire precautions are taken to ensure the safety of staff, students, contractors, visitors, and members of the public.
• Suitable and sufficient risk assessments are carried out and regularly reviewed.
• A positive fire safety culture is promoted across Imperial and that arrangements are in place for the effective planning, organisation, control, monitoring, and review of the preventative and protective measures.
• Adequate resources are allocated to the management of fire safety.

Faculty Principals

The Faculty Principals and the Principal of the Business School have delegated duties from the Responsible Person and are responsible for ensuring that a positive fire safety culture is promoted in their area of responsibility, and that fire safety is managed appropriately within their faculty.

Chief Operating Officer

The Chief Operating Officer is an Accountable Person as defined in the Building Safety Act 2022 and has delegated duties from the Responsible Person. They are responsible for ensuring that:

• All Imperial premises comply with statutory requirements.
• All new construction projects and refurbishments incorporate appropriate fire precautions and statutory requirements.
• A positive fire safety culture is promoted in their area of responsibility.
• Fire safety is managed appropriately within the Support Services.

Chief Property Officer

The Chief Property Officer is an Accountable Person as defined in the Building Safety Act 2022 and has delegated duties from the Chief Operations Officer. They are responsible for ensuring that:

• All Imperial premises comply with statutory requirements.
• A positive fire safety culture is promoted in their area of responsibility.
• Fire safety is managed appropriately within the Property Division.
• Staff and contractors within their division receive sufficient and appropriate fire awareness instruction and training.

Director of Campus Operations

 The Director of Campus Operations has delegated duties from the Chief Property Officer and is responsible for the day-to-day management of all buildings and campuses. They are responsible for ensuring that:

• All Imperial premises comply with statutory requirements.
• A positive fire safety culture is promoted in their area of responsibility.
• Fire safety is managed appropriately within the buildings and campuses.
• Ensuring that staff and contractors within their division receive sufficient and appropriate fire awareness instruction and training.
• Cooperates and coordinates with the Fire Safety Team.
• Cooperates and coordinates with the Director of Residential and Community Services.
• Cooperates and coordinates with the Heads of Departments and Divisions.

Director of Residential and Community Services

 The Director of Residential and Community Services has delegated duties from the Chief Property Officer for the responsible for day-to-day management of residential building and the Community Safety and Support Team across all campuses. They are responsible for ensuring that:

• All Imperial premises comply with statutory requirements.
• A positive fire safety culture is promoted in their area of responsibility.
• Fire safety is managed appropriately within the residential buildings and campus sites.
• Staff, students, and contractors within their Division receive sufficient and appropriate fire awareness instruction and training.
• They cooperate and coordinate with the Fire Safety Team.
• They cooperate and coordinate with the Director of Campus Operations.
• They cooperate and coordinate with the Heads of Departments and Divisions.

Heads of Department and Division

Heads of Department and Division have delegated duties from their Faculty Principals and are responsible for:

• Promoting a positive fire safety culture in their area of responsibility.
• In consultation with the Fire Safety Team, appointing a competent person as a Fire Warden Coordinator to advise them on fire safety matters arising within their Department/ Division and implement the relevant emergency plans.
• Additional Fire Wardens Coordinators may be required for Departments/Divisions that extend over multiple buildings and campuses.
• Ensuring that all flammable materials are correctly stored, used and disposed of, and that in all cases the quantities involved are the minimum reasonably practicable. All potential fire hazards within their Department/ Division must be clearly identified and notified to the Fire Safety Team.
• Acting on the recommendations of the Fire Safety Team set out in the Fire Risk Assessments for the buildings in which their Department/ Division is located.
• Liaising with the Fire Safety Team before introducing new activities and/ or processes which may increase the fire risk.
• Ensuring that staff and students within their Department/ Division receive sufficient and appropriate fire awareness instruction and training.

Faculty Safety Advisers/Departmental Safety Officers

Faculty Safety Advisers and Departmental Safety Officers have assigned duties for the general fire precautions within areas that are under their control and responsible for:

• Promoting a positive fire safety culture in their area of responsibility.
• Being aware of how to identify fire hazards and report any risks.
• Undertaking fire safety inspections, including firefighting equipment and Means of Escape, to ensure they are in good condition and to report any failures.
• Acting on the recommendations of the Fire Safety Team set out in the Fire Risk Assessments for the buildings in which their Department/ Division is located.
• Liaising with the Fire Safety Team before introducing new activities and/or processes which may increase the fire risk.
• Assisting the Fire Safety Team with Annual Evacuation drills.
• Ensuring that staff and students within their Department/ Division receive sufficient and appropriate fire awareness instruction and training.

Managing Director of Imperial College Union (ICU)

The President of the ICU has the same responsibilities for fire safety as a Head of Department/Division. In addition, the President is responsible for ensuring that the Union meets its legal obligations for fire safety in respect of its catering and bar outlets, its clubs and societies, and other entertainment and sporting activities.

Staff, Students and Visitors

All staff, students, and visitors are required to follow established procedures and cooperate with appointed Imperial staff in order to achieve the highest standards of fire safety. This includes minimising the amounts of combustible materials present in buildings, ensuring the safe use, storage, and disposal of flammable substances, and avoiding misuse of fire safety equipment, as well as complying with the Smoke Free Policy.

Contractors

Contractors must comply with the Imperial Fire Safety Policy and obey all fire safety instructions given to them by the Fire Safety Team and/or the Health and Safety Advisor (Construction). Contractors must also ensure that all personnel for whom they are responsible are adequately trained and instructed in fire safety procedures and know the local arrangements for the areas where they are working. Contractors are required to cooperate fully with Imperial procedures, including the need to apply for Hot Work Permits when carrying out work that could present a fire risk or potentially result in activation of the fire alarm system. All work on Fire Alarm Systems is also subject to Permit-to-Work procedures and must be agreed, in advance, with the Fire Safety Team and the Building/Campus Manager responsible for the area covered by the alarm system.

2.3 Specialist Fire Safety responsibilities

Director of Property & Major Projects

The Director of Property & Major Projects is an Accountable Person as defined in the Building Safety Act 2022 and has delegated duties from the Chief Property Officer and, in addition to his or her duties as a Head of Division, he or she is responsible for:

• Developing and implementing the Imperial Fire Strategy.
• Ensuring that Imperial premises comply with statutory requirements.
• Acting on the recommendations of the Fire Safety Team as far as they relate to the fire alarm systems, fire precautions (means of escape, etc.) and fire signage.
• Appointing Fire Safety Coordinators (in effect assigning duties to Building Managers) to provide support in the implementation of the Imperial Fire Safety Policy.

And for ensuring that:

• Imperial meets its legal obligations for fire safety in respect of all premises it leases to third parties.
• Tenancy agreements place Imperial's tenants under a legally enforceable obligation to comply with Imperial's fire safety policy and procedures.
• All building projects comply with statutory requirements and, in particular, that new or upgraded fire alarm systems, fire precautions and fire signage comply with the Imperial Fire Strategy.

Fire Safety Team

The Fire Safety Team, which is part of the Safety Department is responsible for:

• Promoting a positive fire safety culture across Imperial.
• Advising Imperial on its statutory obligations regarding fire safety and the effect of new or amended legislation.
• Developing the Fire Safety Strategy and the policies and procedures necessary to ensure Imperial's compliance with legislation and the effective control of its fire hazards, including conducting building fire risk assessments.
• Developing appropriate guidance and codes of practice to support these policies and procedures.
• Advising senior managers of their responsibilities for fire safety.
• Writing and reviewing all fire risk assessments for Imperial buildings annually, or when significant changes are made.
• Reviewing, advising on, and approving all minor and major construction and refurbishment projects.
• Liaising with fire auditors and local authorities for fire safety matters.
• Providing specialist advice, information, and support to all parts of the university, including the dissemination of good practice, on the management of fire safety.
• Inspecting, monitoring, and auditing the implementation of fire safety policies, procedures, and codes of practice across Imperial, including the testing and maintenance of firefighting equipment and fire alarm systems, and the issuing of Hot Work permits.
• Developing, setting, and reviewing performance standards and targets, as necessary.
• Advising on training needs and providing in-house training and instruction, including arranging regular fire drills.
• Managing the interface between Imperial and the local fire authorities.
• Liaising on fire safety matters with associated NHS Trusts, contractors working on Imperial premises and external organisations with a presence on Imperial campuses.

The Fire Safety Team has the authority, delegated from the President, to close buildings, or parts of the buildings, and to call a halt to processes or activities if it believes there is a serious risk of injury from fire to the occupants of the building or people undertaking the activity or process.

Fire Warden Coordinators

 Fire Warden Coordinators are appointed by the Head of Department and Division and are responsible for.

 Identifying/ reviewing the minimum number of Fire Wardens required for each of the building floors they oversee, in conjunction with Faculty/Departmental/ Divisional Safety personnel and Fire Safety Officers, as required.

• Recruiting departmental staff as Fire Wardens.
• Booking departmental staff onto the Fire Warden e-learning course.
• Allocating Fire Wardens to each of the areas/zones of the floor to be swept and keeping the list to Fire Wardens up to date.
• Liaising and coordinating with Fire Warden Coordinators from other Departments/Divisions/Faculties that may be sharing the floor space, to ensure that information is shared and there is a single list of Fire Wardens for the shared space.
• Coordinating and arranging Fire Warden meetings, in collaboration with the Fire Safety Office, and holding debrief meetings following fire emergency evacuations, ensuring lessons learned are shared.

 Fire Wardens

 Fire Wardens are managed by the Fire Warden Coordinators and must:

• Support any evacuation, including annual evacuation drills and any additional tasks during the annual evacuation drills as directed by the Fire Safety Team.
• Raise the alarm and alert Community Safety and Support team if a fire breaks out. Call for assistance for first aid incidents and alert Community Safety and Support Team.
• Cover final exit doors and direct people to assembly point until everyone is out of the building or it is unsafe to remain. Assist in ensuring roads are clear of people without putting yourself at risk. Evacuate and direct all people from the building to the assembly point. Liaise with the Community Safety and Support Team.
• Assist with crowd control as directed by the Community Safety and Support Team.