To comply with these requirements, most Trusts enter into a service and maintenance contract with a specialist provider. However, the level of support provided by firms under these contracts can differ. Before entering into these agreements, it is important to confirm that the organisation has the skills, knowledge, and training to not only carry out standard inspection works, but also complete maintenance and repair works themselves rather than outsourcing this to a separate third party.
To help estates teams to understand the requirements for smoke control maintenance, and who is qualified to carry out work on these systems, the Smoke Control Association (SCA) has published Guidance on Maintenance of Smoke Control Equipment. This guide provides an overview of the legal obligations for estates managers — along with advice on how to identify smoke control assets and suggested maintenance and inspection schedules. This document also defines a new role, Competent Maintainer, to ensure all servicing works are carried out correctly and by properly qualified individuals. It is important that managers understand this role and ensure any individual or company appointed to service their smoke control systems meet its definition.
Understanding the risks
Healthcare estates incorporate a wide range of equipment, materials and commodities which can act as potential sources or fuel for fires. Data from the most recent Estates Return Information Collection from NHS England showed that there was a total of 1,102 fires at NHS facilities in the period 1st April 2023 — 31st March 2024, leading to 21 injuries and one death.1
Alongside the potential for accidental fire, further data from the Ministry of Housing Communities and Local Government states that 29 per cent of the primary fires within NHS facilities during this period were started deliberately.2 Whilst steps can be taken to limit opportunities for these acts of arson, the reality is that the extent of NHS facilities and limited security resources means preventative measures can only go so far.
Alongside the potential risk to life and safety in the event of a fire, these events can also lead to considerable long-term disruption and costs, particularly where specialist equipment may be damaged. It is important that estates teams fully factor these potential costs into the cost-benefit analysis when tendering for firms to inspect and maintain smoke and fire safety systems.
In the event of a fire, smoke often presents the most serious risk to life and safety, with data from the Government consistently showing that the most common cause of death for fire-related fatalities is occupants being ‘overcome by gas or smoke’.3 This is in part because smoke and hot gasses are often able to spread through a building much faster than flames, but also because smoke from modern materials can be highly toxic and can quickly render a fit and able person unconscious, let alone a person with a serious health condition. For this reason, it is essential that this risk is addressed through effective smoke control management.
In NHS facilities, the immediate and total evacuation of buildings is often not practical as patients may have restricted mobility, be under medication, or be dependent on electrical or mechanical equipment which cannot be easily disconnected and moved. As a result, evacuation strategies will typically focus on horizontal evacuation from the immediate area of the fire to an adjoining sub-compartment or compartment.
Standard solutions
Smoke control systems play a vital role in supporting these strategies. Solutions such as smoke control dampers and smoke curtains can help to ensure that proper compartmentation is maintained, preventing smoke and flame from escaping the compartment where the fire originates for a specified period. Meanwhile, Automatic Opening Vents (AOV) and Smoke and Heat Exhaust Ventilation (SHEV) systems can help to evacuate any smoke which enters evacuation routes, preventing these from becoming smoke logged. This supports both safe evacuation and access for fire emergency services to allow the fire to be addressed.
In recognition of the crucial roles these systems play in supporting life safety, there are now considerable legal responsibilities placed on estates managers to ensure that these systems are regularly inspected and maintained by suitably qualified individuals. This proactive approach is critical to ensure these systems perform as expected in the event of a fire.
The wide range of new legislation, standards and voluntary codes that have been introduced in recent years relating to these systems can be confusing for teams to navigate. The new SCA Guidance on Maintenance of Smoke Control Equipment is designed to provide clarity, offering a simple reference guide for estates managers which supplements the specific guidance within Health Technical Memorandum 05, helping estates teams to understand the risks and requirements, and ensure smoke control systems are being properly inspected and maintained.
New guidance
The SCA Guidance provides an initial overview of the key legislation which applies to the maintenance of smoke control systems, including the Regulatory Reform (Fire Safety) Order 2025 (RRO) and the Fire Safety Act 2021, and provides clarity on the roles and responsibilities for both the Building Representative and the organisations appointed to maintain these systems.
The document goes on to provide an outline of the different core components of smoke control systems, and details what steps facilities managers should take during handover of a building to ensure they have all the necessary information about the smoke control system (including its design, maintenance logs, and specification and performance criteria).
It finally provides details on the inspection schedules which should be maintained to meet the minimum recommendations under relevant standards. These schedules clearly detail when different types of smoke control system should be inspected, serviced and maintained, and who should carry out this work, highlighting relevant standards where needed.
At the core of the document is the creation of a new role — Competent Maintainer — which has been developed to ensure all maintenance works are completed by individuals that have the required knowledge and experience. The SCA guidance views this role as being separate from that of the ‘Competent Person’ defined in the RRO, and it is important that estates managers are aware of how these differ.
The SCA guidance defines the Competent Person as an individual who has sufficient training, experience and knowledge of smoke control systems in general, and understands how the system is laid-out within the building, in order to be able to adequately undertake inspections of the systems as required. Critically, a Competent Person may therefore not have the skills to actually carry out any maintenance work that is required.
In contrast, the SCA guidance defines a Competent Maintainer as a ‘maintenance organisation having appropriate training, skills, knowledge, experience and behaviours suitable for undertaking maintenance of smoke control systems’. To ensure they meet these requirements, it recommends that the organisation is certified under the IFCC SDI 19 scheme for maintenance activities.
Key industry regulations
IFCC SDI 19 has been specifically developed for installers of smoke control systems, requiring them to demonstrate they are suitably experienced in the design, installation, commissioning and maintenance of these systems across a range of building sizes and types, and have suitable knowledge of the key industry regulations and standards.
The standard was developed by SCA in direct response to Dame Judith Hackitt’s call to industry to improve competence as part of the findings of the Building a Safer Future: Independent Review of Building Regulations and Fire Safety — Final Report. SDI 19 is independent, accredited by UKAS and managed by IFCC Certification. Certification under the scheme is a requirement for membership of the SCA.
The IFC SDI 19 scheme requires certified companies to continually demonstrate that their processes and trained staff adhere to industry best practice, including relevant standards such as BS 9991, BS 9999 and BS 7346 – 4,5,7 and 8, through a process of regular audits.
As part of the application to be accredited under IFC SDI 19, firms need to confirm that they meet all the technical requirements contained in the scheme document, including specific installation and maintenance requirements.
IFC Certification then carry out an initial audit of different aspects of the company’s on and off site operations to confirm compliance. This includes:
- Office — demonstrating that they operate a management system which allows all work for contracted clients to be tracked and recorded over time. This should include specific information about the products that are fitted and their ongoing maintenance and inspection logs.
- Site installations — auditing a selection of completed and ongoing installations to demonstrate that staff have the necessary training and understanding of systems they are installing, and that works are being completed in line with the contract drawings and installation instructions.
- Maintenance — evidencing that service and maintenance activities are only undertaken by suitably qualified individuals, that they are maintaining a database of all the contracts they operate and the systems installed within the buildings, and that there are clear processes in place for the inspection, maintenance and reporting of any issues to the client/end user.
Achieving certification under this scheme is only the start of the process. Once a company is certified, it is required to log every contract it takes on to IFC Certifications’ database, along with all staff who are recognised as competent by IFC Certification through training and assessment.
The company will then be subject to a process of annual office audits along with interim site audits of a range of jobs based on a variety of factors including:
- Size and complexity of the installation.
- Type of system.
- Contractor activity level.
Any non-compliance issues will lead to additional audits and can result in accreditation being suspended and ultimately withdrawn.
This certification and audit process provides clear assurance to estates teams that firms which meet the definition of Competent Maintainer have the knowledge and skills to undertake effective long-term maintenance and repairs on smoke control systems as necessary.
It is important to be aware that some companies which offer smoke control service packages are not accredited under the SDI 19 scheme and therefore do not meet the definition of a Competent Maintainer. This can mean their staff only have the knowledge and experience to carry out the regular inspection works. If any issues are discovered, requiring repair or maintenance, this work may then have to be contracted out to a separate third party.
For estates managers, this can mean that works on critical building safety systems — for which you have ultimate responsibility — are being carried out by a third party you have no existing relationship with. This places additional responsibility on you to ensure that they are suitably qualified and that works have been completed and documented correctly. It can also significantly raise the cost of the maintenance work as third parties will charge on a job-by-job basis, and your actual service contract provider may charge an additional mark-up fee on top of this.
Service engineers
By appointing smoke control service engineers who meet the definition of a Competent Maintainer, estates teams can have confidence that the works will be overseen by firms which have staff that are properly trained to carry out both service and maintenance works, ensuring these life critical systems are functioning correctly.
Smoke control systems play a vital role in ensuring the safety of occupants in the event of a fire, and help to limit damage to building assets and contents.
The new SCA guide helps to supplement the sector specific guidance given in Health Technical Memorandum 05, providing clarity both on how these systems should be proactively inspected and maintained, and — through the defined role of Competent Maintainer — who estates managers should look to appoint to ensure these works are completed to the necessary standards.
References
1 NHS Digital. Estates Returns Information Collection (ERIC) 2023-24. Available from: https://digital.nhs.uk/data-and-information/publications/statistical/estates-returns-information-collection/summary-page-and-dataset-for-eric-2023-24.
2 UK Government. Fire Statistics Data Tables. Available from: https://www.gov.uk/government/statistical-data-sets/fire-statistics-data-tables.
3 UK Government. Fire Statistics Great Britain. Available from: https://www.gov.uk/government/collections/fire-statistics-great-britain.