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arowlands  
#1 Posted : 27 July 2023 14:14:21(UTC)
Rank: New forum user
arowlands

In a commercial premises, can combustible items be stored under stairs on a fire escape route, providing an alternative escape route is also available? Or should flammable objects never be stored under any escape stairs?

J Sullivan  
#2 Posted : 27 July 2023 14:34:50(UTC)
Rank: Forum user
J Sullivan

All stairwells particularly on route to a final exist should be free from combustibles , I would also add signage as clear information and instruction relating to this rule  

Your fire risk assessment / assessor should pick this on your annual assessment

Regards

John

thanks 2 users thanked J Sullivan for this useful post.
Roundtuit on 27/07/2023(UTC), Andrew_C on 27/07/2023(UTC)
firesafety101  
#3 Posted : 27 July 2023 21:14:26(UTC)
Rank: Super forum user
firesafety101

Hi Arrowlands, you mention Combustibles and Flammables, they are different but neither should be stored under a means of escape.

thanks 1 user thanked firesafety101 for this useful post.
arowlands on 28/07/2023(UTC)
antbruce001  
#4 Posted : 28 July 2023 06:40:37(UTC)
Rank: Forum user
antbruce001

If you want to store combustiblse under the stairs then you have to install a 30 minutes fire protected 'cupboard' or make it a little room fitted with a fire door (like Harry Potter's bedroom). As detailed above, you can't just use it for open storage.

I would have concerns if flammables were being stored even in a 'cupboard/room' within the stairwell.

Hope it helps,

Tony.

arowlands  
#5 Posted : 28 July 2023 08:54:15(UTC)
Rank: New forum user
arowlands

Thanks for the replies. In a building where storage space is limited, I wondered if the hazard could be 'risk assessed' out, on the basis that an alternative escape stair would be available. That would seem to tie in with the advice on reception areas in the HMRC Guide, which says: Reception or enquiry areas should only be located in protected stairways where the stairway is not the only one serving the upper floors, the reception area is small (less than 10m2 ) and is of low fire risk So if it's fine for a reception area, why not storage? 🤔

Kate  
#6 Posted : 28 July 2023 09:35:27(UTC)
Rank: Super forum user
Kate

You cannot 'risk assess a hazard out'.  You can eliminate the hazard (which is preferable), or you can mitigate the risk.  If you only mitigate the risk, the hazard is still there, in this case right under the stairs, and hasn't gone 'out'.  And then you have to ask yourself, why haven't I eliminated the hazard?  What's my justification?  "What about reception?" isn't a justification for storing combustibles under escape stairs.

Storage of combustibles - let alone flammables which would be much more dangerous - is an entirely different activity in terms of fire risk from operating a small reception area.  Also, with storage it is straightforward to either store less stuff, or store it somewhere better - whereas a reception area, by its nature, needs to be readily accessible to your visitors, and is much less practicable to eliminate or move.

thanks 1 user thanked Kate for this useful post.
peter gotch on 28/07/2023(UTC)
Messy  
#7 Posted : 28 July 2023 09:56:45(UTC)
Rank: Forum user
Messy

I do not accept the 'no combustibles at any cost' argument. The key is what are the combustibles , what are the ignition risks, how is the space separated and is there AFD? Some coats under an alternative staircase with no electrics and reasonably built cupboard is a whole world away from the storage of laundry and lpg cylinders in a cupboard of a single staircase building with a cat M fire alarm system I honestly think applying the concept re reception areas in staircases isn't a bad start but shouldn't be taken literally Its about lowering risk to an acceptable level and not eliminating it as the complete removal of risk is impossible
thanks 1 user thanked Messy for this useful post.
peter gotch on 28/07/2023(UTC)
firesafety101  
#8 Posted : 28 July 2023 10:27:24(UTC)
Rank: Super forum user
firesafety101

Commercial premises is a very broad description.  

If the premises has a Sleeping Risk above the ground floor then no way would any storage be allowed under the stairs.

antbruce001  
#9 Posted : 28 July 2023 10:55:35(UTC)
Rank: Forum user
antbruce001

The key to this question is 'What type of staircase is it?' If it is required to be a protected staircase (to achieve minimum travel distances, it's marked as a protected staircase in your fire strategy, or is an Approved B requirement) then it must be kept as fire sterile as possible. There is no getting around that. 

However, if it does not need to be a 'protected staircase' then you do have more flexibility as to how you use the space in the stairwell. It is still good practice to keep it fire sterile, but you can use it for 'reasonable' other purposes.

You really need to consult your competent fire risk assessor, who should be able to confirm whether or not the staircase is required to be a protected route and can then advise on whether or not limited storage in the stairwell is acceptable. 

Nobody here has sufficient information to give you a yes/no answer.

peter gotch  
#10 Posted : 28 July 2023 11:10:24(UTC)
Rank: Super forum user
peter gotch

Morning arowlands

This is all about achieving what is "reasonably practicable".

The guidance you quote says

the reception area is small (less than 10m2) and is of low fire risk 

Working out what is "reasonably practicable" means assessing the level of risk and then assessing the cost of whatever mitigations in terms of time, money and effort and deciding at what point those costs are "disproportionate"(1) or "grossly disproportionate"(2) to the reduction in risk that would be achieved by applying each mitigation.

(1) Marshall v Gotham 1954 rarely quoted but in a higher Court and later than (2)

(2) Edwards v National Coal Board 1949

If it comes to legal action the onus is on the duty holder to prove that they had done what was "reasonably practicable" on the balance of the evidence - the so called reverse burden of proof.

Most of the time nobody bothers to work out what is "disproportionate" or "grossly disproportionate" but simply applies rules of thumb or what it says in authoritative guidance.

One of the rules of thumb is "Don't store things that can burn under stairs that form part of a fire escape".

Hence if you were to try and risk assess to permit this storage as described, you have your work cut out, not least since you could relatively easily enclose the storage area to make it fire resistant.

However, the risk is dependent on the numbers and types of people who can be expected to have potential need to use the fire escape - so the risk increases with population, number of storeys, vulnerability of users, amongst other variables including the amount and nature of stored materials and the volume of the stairwell.

I worked for nearly 30 years in an 8 storey 1930s listed building where there is a reception area with one/two staff at the Ground Floor foyer with residential accommodation on the top floor. Not much in the way of stuff to burn and the stairwell is vast, so anything that might burn at reception would produce relatively little smoke compared to the volume of the foyer and stairwell. 

Contrast this with the situation where you might store some relatively easily combustible material under the stairs in a typical alternative fire escape route (EVEN in the 1930s building!) and you face the prospect of part or all of the stairwell rapidly becoming smoke logged.

So, I agree with Messy that trying to compare your scenario with a small reception area is not an appropriate comparitor.

arowlands  
#11 Posted : 28 July 2023 11:25:18(UTC)
Rank: New forum user
arowlands

Fantastic! Thanks everyone that gives me plenty of understanding. Playing devils advocate I thought so what if there's a fire in this stairwell (even with sleeping risk) as people can just use the other stairwell to get out. Therefore no risk to life.

But clearly it more nuanced that that!

ajw  
#12 Posted : 28 July 2023 15:39:04(UTC)
Rank: Forum user
ajw

#5 You cant really compare HMRC irec/reception location to Fire safety The stairwell i assume is the / main escape route and as such there will be fire warning signage in place directing occupents down the stairwell - in effect you run the risk of sending occupants directly into the heart of a fire should the flammables and or combustables ignite. Doesnt sound like a good idea to be honest

Kate  
#13 Posted : 28 July 2023 19:09:06(UTC)
Rank: Super forum user
Kate

If there is a significant fire in an occupied building, you can never say there is no risk to life.  People may indeed be able to evacuate using the alternative route (if that one is OK).  But suppose someone is incapacitated and unable to get out at all.  Then their life is at risk, and so are the lives of the firefighters who may enter the building to rescue them.

Messy  
#14 Posted : 28 July 2023 22:18:02(UTC)
Rank: Forum user
Messy

Originally Posted by: Kate Go to Quoted Post
<p>If there is a significant fire in an occupied building, you can never say there is no risk to life.&nbsp; People may indeed be able to evacuate using the alternative route (if that one is OK).&nbsp; But suppose someone is incapacitated and unable to get out at all.&nbsp; Then their life is at risk, and so are the lives of the firefighters who may enter the building to rescue them. </p>
Just a point of order Kate, operational fire crews engaged in firefighting in a premises are not 'relevant persons' so there is no need to consider them in a FRA where the FSO applies
thanks 3 users thanked Messy for this useful post.
Kate on 29/07/2023(UTC), peter gotch on 29/07/2023(UTC), Andrew_C on 31/07/2023(UTC)
firesafety101  
#15 Posted : 30 July 2023 17:24:22(UTC)
Rank: Super forum user
firesafety101

Fire safety law.co.uk. under the heading fire-fighters-as-relevant-persons has a better answer that I can give.  Please have a read and post your conclusion.

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