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Resilience to fire and
going beyond regulations
– an insurance industry
perspective
Gary Howe EngTech FIFireE demonstrates why greater collaboration is required from insurers in the building
design process to contribute to a resilient built environment
I
n March of 2018 a fire completely destroyed a
very large non-sprinkler protected warehouse
in the Midlands, UK. As no lives were lost and
everyone managed to escape from the building, is
this a success?
This warehouse building met UK Building
Regulations requirements yet was completely
destroyed by fire, highlighting the impact of not
providing effective sprinkler protection to such
a large structure which met statutory building
regulations. Had the building been protected with
a suitable sprinkler system, adequately designed for
the risk, the fire would have been suitably controlled
and/or suppressed within a very small area of the
building. Only the sprinkler heads in the immediate
vicinity of a fire would have operated. Research
carried out over 20 years shows that 80 per cent of
fires are controlled or extinguished by the operation
of fewer than six sprinkler heads.
Watching the news and seeing the drastic first-
hand pictures and aerial drone footage of the
warehouse being completely destroyed by fire,
raises the question, is it the time to ask questions
to understand the cause? And why did it spread
so rapidly? In the aftermath of a major fire there is
often a desire to understand what has happened,
were fire protection systems in place and what
lessons have been learned?
“Research carried out over 20 years shows that 80 per cent of
fires are controlled or extinguished by the operation of fewer
than six sprinkler heads”
22 International Fire Professional February 2019 Issue No 27 www.ife.org.uk
Sprinkler Protection
It is common practice for property insurers to be
told that a proposed new building meets current
building regulations and that there is no intention
to fit sprinklers as fire safety legislation does not
always require the fitting of fire suppression systems.
Sprinklers are commonly being value engineered
out; as insurers are routinely told they are not
needed. Where is the value in that?
Regularly insurers are presented with a fait
accompli and asked for their input and opinion of
new building projects at the 11th hour. Commonly,
insurers are approached at a late stage when the
developed design or technical design has been
completed. By then very little can be done and
it is virtually impossible to integrate insurer
recommendations or requirements; this is a common
and frustrating experience for the author
It is the author’s personal experience to find that
fire protection contractors who are involved with
the design of sprinkler projects are routinely told
not to speak to the insurance company for fear of
adding costs to the project. Commercial property
insurers should be consulted and exploited as a
useful, capable and intelligent resource to the fire
safety design and insurance team at the building
concept design stage in order to champion property
protection and business resilience objectives.
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The author has been told by a number of
fire engineering companies that they willingly
advocate the omission of sprinklers at project
conception stage to save their client and/or the
main contractor money in order to boost profit
margins. They often comment to the author
that if government had wanted them to install
sprinklers, they would have placed it within the
regulatory guidance. Fire engineers can often tell
clients they do not need sprinklers. What they
actually meant was “you do not need sprinklers to
comply with the minimum requirements defined
by regulatory guidance”.
The implications and impact of removal or
omission of sprinklers to large projects is not always
fully understood and has the potential to impact
on the insurer capability to underwrite the risk.
Sprinklers can be seen as burdensome and expensive
without understanding their truth worth and long-
term benefit.
Known examples of value engineering at design
stage include:
ll Reducing building height of a high-rise building
below the statutory 30m limit to 29.5m to omit
sprinkler protection.
ll Reducing the building footprint of a commercial
supermarket project below 2,000m2 to 1,995m2 to
alleviate the need to fit sprinkler protection.
ll Removal of sprinklers by use of a risk-based
assessment method in order to justify omission of
sprinkler protection.
ll Fitting of sprinkler protection only to basement
floors as part of the means of escape ‘life safety’
strategy.
Sprinkler protection is certainly not a panacea and a
one size fits all solution. For example, fire sprinklers
would not be recommended for an art store housing
valuable paintings and artefacts as this kind of
facility would be more suitably protected by a
gaseous fire suppression system. Fire sprinklers have
over a 100 years of proven in use history. However;
it is important that for the protection of buildings
there is a clear understanding of the objective and
risk and this will require the skill and knowledge of a
competent person to select the most suitable form of
fire safety measures required.
The author has found that it is common to find
sprinkler protection omitted in favour of other
suitable fire safety provisions such as automatic fire
alarms, compartmentation and the fact the local
fire and rescue service are located a few minutes
away. This may offer a false sense of security; whilst
automatic fire alarms are an essential part of any fire
engineering design, they are there predominately
for ‘life safety’ reasons and to facilitate means of
www.ife.org.uk International Fire Professional February 2019 Issue No 27 23
Technical Perspectives
escape. They are limited by virtue of the fact that
they can only tell you a fire has occurred and start
the building fire evacuation procedure; they cannot
suppress or control fire.
The presence of the fire and rescue service fire
station in close proximity to the site may on the face
of it be a positive feature, but there is no guarantee
that the fire and rescue service will commence
internal firefighting operations if there is no life
risk at stake (and why should they risk the lives
of firefighters?). The fire and rescue service may
only tackle the fire defensively from the outside
and prevent fire spread/radiant heat spread to
adjacent structures; this can still result in a total
loss of the facility. Lastly, whilst relying on internal
compartmentation to mitigate horizontal and
vertical fire spread, the author frequently finds
significant penetrations within fire compartment
walls. This occurs above celling voids and within
electrical risers, coupled with the fact that fire
doors can be routinely wedged open and or fire
shutters having obstructions in the way preventing
them from closing correctly. All of this impacts
significantly on the ability of the compartmentation
to restrict horizontal and vertical fire growth.
Building Regulations
It is at the concept design stage of new build
projects that the building occupier or owner can
be commonly found to have not fully appreciated
the nuances of the Building Regulations. As they
currently stand in the UK they are predominately
focused on life safety. Authorities having jurisdiction
(AHJ) such as Building Control, the fire authority
and consulting fire engineers employed on
their behalf have only to satisfy the minimum
requirements of the Building Regulations – with the
word ‘minimum’ sadly being key here.
The Building Regulations and associated guidance
in the UK are based on ensuring that a person
confronted by fire effects can turn away from it
and make a safe escape. I can understand some
of the confusion because the guidance does call
for fire resistance of construction and in some
circumstances also calls for automatic sprinklers.
However, they are not to protect the property but
to facilitate the safety of those in and around the
building. This would also extend to firefighters who
may need to enter a building to secure evacuation or
rescue of occupants.
Definition of a minimum standard for a ‘fire safe’
building in the UK is usually equivalent to the fire
safety provided by the application of Approved
Document B (ADB). It can be argued that this is a
lower than desirable standard in many respects from
an asset protection viewpoint.
Technical Perspectives
Life safety objectives are those mandated in the
UK Building Regulations and are often achieved
“Sprinkler protection can be an
by providing systems for early warning of fire,
extinguishing of a fire and proper egress for prompt
effective means of mitigating the
escape from the building. Property protection is not
a mandated objective, but is of concern to insurers
as they have a financial interest in minimising
losses. It can be achieved by installing fire control,
suppression or extinguishing systems, by providing
compartmentation features to confine or limit fire
spread within a building, and by constructing the
building with materials that incorporate non-
combustible construction that will resist a fire, not
add to the fire load and remain structurally sound
after a fire. Continuity of operations objectives
are not mandated, but of interest to insurers as
commercial property insurance policies cover not
only material damage (MD), but also business
interruption (BI).
The field of business interruption is where the
true value of providing sprinkler protection can
be demonstrated. When trying to cut costs and
keep spend to a minimum, a business owner may
conclude that sprinklers are an unnecessary expense.
However, by cutting corners a business owner could
fail to see the bigger picture and neglect to take the
impact of business interruption into account.
The impact of business interruption is often
vastly underestimated; following a major fire it
could be typically 18 to 24 months before a business
is fully back up and running again. Business
interruption impact and the related influence to
the supply chain continue to lead the list of major
concerns for businesses. With so many businesses
interconnected on a global scale, the impact of an
event in one part of the world can have negative
repercussions halfway around the globe. The
growing interdependency of many industries and
processes means businesses are now exposed to an
increasing number of disruptive scenarios.
Sprinkler protection can be an effective means
of mitigating the business interruption risk. With
a proven in use history, sprinkler systems and loss
history data indicate that typically six or fewer sprinkler
heads controlled the vast majority of all fires; business
interruption can be dramatically reduced from many
months or even years to as little as a few days.
Fire Safety Strategy and Design Process
At the early stages of the fire safety engineering
strategy and design process, insurers should be
actively involved, but the reality is very different.
Research by Wilkinson et al (2010) suggests that
not all insurers play an active role in the fire safety/
fire strategy process. A high level of competency
is required to play an effective role in the fire
24 International Fire Professional February 2019 Issue No 27 www.ife.org.uk
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business interruption risk”
engineering process, but where poor levels of
knowledge and understanding exists this precludes
any meaningful interaction and dialogue.
Whilst insurers are willing to engage with the
clients’ design team it is common for them not to be
invited to do so, or where invited it is often so late in
the process they are asked to merely ‘rubber-stamp’
design decisions. Unfortunately, this is a recurring
and frustrating experience as the opportunity to
make meaningful changes to the project has been
lost. The author frequently experiences invitations
to meetings where decisions have already been
made and therefore is unable to champion property
protection and business resilience objectives in order
to create a more resilient built environment.
The benefits of early insurer involvement are
not fully appreciated by clients; insurers bring a
wealth of risk engineering, industry experience and
knowledge of fire related losses in situation where
sprinklers were not installed. The author has had
many positive experiences of good practice where
the client, insurance broker, insurance manager and
fire consultant have proactively involved the insurer
throughout all stages of the design process which
has resulted in meaningful dialogue between all
stakeholders and has resulted in the fire engineering
strategy being improved for the better to encompass
both life safety and property protection/business
interruption insurer recommendations resulting in
a more resilient built environment.
Actively involving the insurer early within the
design process can be beneficial to all stakeholders
involved in the fire engineering process; there is
the unfair perception of insurers relying solely
on sprinklers as a form of fire safety. The benefits
of sprinklers have long been recognised by the
insurance industry. Discounts on premiums or
reduction in deductibles are normally given for
properties suitably protected by sprinklers. The
benefits of sprinklers are well recognised – with
over 100 years of proven in use history the case for
installing sprinklers in buildings is a strong one.
Even in 2019 the Hollywood fictitious film scenario
still plays on many client’s minds that once one
sprinkler in a building goes off, they all go off, with
the fear that the building will be flooded with
water. Which of course is untrue. Whilst there are
a minority of sprinkler systems designed as ‘deluge’
systems where all the sprinkler heads activate at
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once, these are for very specialist applications such Institution of Fire Engineers and Engineering
as external transformers, LPG tanks and tank farms. Council qualification. This has enabled Zurich field
The vast majority of sprinklers systems for building staff to have the knowledge, skills and competency
protection are designed in such a way that the to interact meaningfully with stakeholders on new
frangible bulb sprinkler head will only operate in the fire engineering projects.
immediate vicinity of a fire with the fire controlled Within innovative building designs and an ever
or suppressed by the operation of fewer than six changing and challenging built environment it is
sprinkler heads. probable that buildings will suffer greater material
The message from insurers is certainly not limited damage and business interruption if insurers are not
to ‘put in sprinklers’ – they are not a panacea. For involved in the design process. It would be naive to
example, fitting sprinklers will not solve the issue of assume that this will not have an impact on insuring
combustible cladding fitted to residential properties. such buildings.
The justification and reasoning for sprinklers
has to be on a ‘case-by-case’ basis based on the A Resilient Approach
risk, sums insured etc., with the challenging world Property insurers such as Zurich would offer
of modern methods of construction (MMC), use an alternative holistic view to just meeting
of combustible construction, innovative designed the minimum life safety objectives of Building
architectural buildings and large timber framed Regulations. An alternative approach to new projects
buildings, then the benefits of promoting sprinklers and site alterations/refurbishments would be to
is perfectly reasonable and entirely relevant to the adopt and undertake a systematic holistic approach
modern built environment. to risk that goes beyond life safety; the Zurich
The insurance industry welcomes dialogue with Hazard Analysis (ZHA) is the answer to this. ZHA
stakeholders, but the opportunities are few and far is a systematic and robust way of identifying and
between. It is common only to be asked after the fire managing key hazards to facilitate and develop
strategy has already been agreed. It is true that the tailor-made risk improvement measures to help
insurer does not always play a suitably active role in reduce those hazards.
the building design process, nor do they command
sufficient influence. This is due to a number of The aims of a Zurich Hazard Analysis are to:
reasons, including: a. Identify key hazards, assess hazards and
determine the risk
ll Commercial property insurers are often not b. Provide a tool which is compliant with legal
identified at the conceptual design stage and are and customer’s requirements in the area of risk
therefore not able to participate; identification
ll If a contract works insurer is appointed, their c. Reduce total cost of risk by optimising the loss
priorities are quite different where their focus is and improvement cost
concentrated on the construction process, rather d. Develop risk profiles, quantity financial severity
than the occupied building; and assess probability
ll Fire safety engineering designers are often e. Provide a systematic, top-down process
reluctant to invite insurers into the design process which harnesses the collective knowledge of an
for fear of the project incurring costly fire protection organisation’s expertise
features in addition to the mandated life safety f. Define the risk appetite, prioritise risk scenarios
requirements. and identify risk improvement actions.

Insurers have a big commitment to the risk
management of the properties they have a financial
interest in but can appear to lack the skills and
sometimes the willingness or authority to commit
the same effort when properties are being designed.
Even with the best intentions and regardless of
whether the insurer is involved in the design process
or not, the current approach is not effective and the
robustness of the fire engineering design becomes
questionable.
Zurich Insurance has invested heavily in the last
two years to up-skill their field staff with over 70 risk
engineering field staff now holding a professional
ll How do you deal with the risks that you may not even
know exists?
ll Can you efficiently prioritise and budget resources for
critical strategic and operational risk mitigation?
ll What is the true risk appetite of your organisation?
ZHA has been successfully applied for many years
over an extraordinary range of analysis scopes
ranging from common consumer products to
complex chemical processing facilities and even to
project management risks. It can equally be applied
as part of the stakeholder engagement process for
new build projects.

www.ife.org.uk International Fire Professional February 2019 Issue No 27 25

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The ‘Risk Profile’ for the ZHA starts as a two

dimensional matrix with the six Probability Levels
on the vertical axis (‘A = Frequent’ at the top) and
the four Severity Categories on the horizontal axis
(‘I = Catastrophic’ to the far right). This produces
a matrix which represents the lowest severity and
lowest probability in the lower, left-hand corner and
the highest severity and highest probability in the
upper, right-hand corner.
Figure 1: Risk profile
Case Study
The author attended a design meeting in late 2018
with a London local authority about a new project to
build a large high school academy. The build value
of the project was £50,000,000. Whilst sprinklers
have been originally thought about as part of the
original fire strategy; the sprinklers have been value
engineered out as there is no legal requirement
under UK law to fit them and they are not required
for life safety reasons under current UK legislation.
However, no consideration had been given to
property protection, business interruption, business
continuity, environmental and reputational risk at
the initial design stage.
Using the ZHA methodology Zurich Risk
Engineering undertook a ZHA to fully understand
the impact of removal of sprinklers, identify any
vulnerabilities and fully understand the probability
and severity of a number of possible fire scenarios.
The purpose of the ZHA is to not only just consider
fire safety but to also provide a 360 degree view of
risk and consider a multitude of risk factors and go
beyond the conventional approach of focusing only
on life safety as is often the case.
The objective of the ZHA was to develop various
risk scenarios, quantity financial severity and assess
probability. A number of possible fire scenarios (six
in total) were firstly considered:
ll What is the hazard?
ll What is the trigger? (How? Why? When?)
ll What is the effect? (How big? how bad?
How much?). Figure 2: Zurich 360 degree view on risk

The risk scenarios are then plotted on a matrix that

results in a ‘Risk Profile’, see below, which includes
a ‘Risk Tolerance Boundary’ line. This indicates the
building’s owner’s refusal to tolerate risks above
specified levels of probability and severity. The risk
tolerance boundary is indicated in blue. With the
visibility provided by the ‘Risk Profile’, clear risk
priorities have been addressed to development and
management of improvement actions.

The six scenarios chosen were:

1. Electrical arcing within cable conductors located
on a cable tray within a ceiling void.

26 International Fire Professional February 2019 Issue No 27 www.ife.org.uk

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“Zurich Hazard Analysis is a

systematic and robust way of
identifying and managing key
hazards to facilitate and develop tailor-
made risk improvement measures to
help reduce those hazards”

2. Arson fire as a result of deliberate fire setting adjoining structures. Offensive firefighting with
of unsecured wheelie bins located beneath a breathing apparatus (BA) wearers being committed
combustible canopy fixed directly to the building. to the building is not envisaged as there is no life risk
3. Overheating electrical computer PC monitor. at stake.
4. Fire within electrical deep fat fryer within kitchen The outcome of scenario ‘2’ is a significant and
as a result of a thermostat failure resulting in oil disastrous damage to the school resulting in an
reaching spontaneous ignition temperature. anticipated 100 per cent physical loss of the school
5. Unattended laser cutter fire as a result of a system and all of its contents due to the severity of the
malfunction. fire, coupled with the rapid internal and external
6. Spontaneous combustion of combustible fire spread and the inevitable delayed fire and
materials and food waste stored in open containers rescue response as a member of the public had
within the bin store to first summon by phone the emergency service.
This is an intolerable situation for the stakeholders
Severity categories: involved in the project. You only have to use a search
I. Catastrophic engine on the internet on school fires to see that this
II. Critical is not an uncommon situation for schools to suffer
III. Marginal a total fire loss.
IV. Negligible By inclusion of an automatic sprinkler system
designed to LPC rules incorporating BSEN12845,
the risk profile can be altered from a ‘unlikely’ (E)
Probability levels: probability’ but with a catastrophic (I) severity to
A. Frequent a ‘negligible’ severity (the probability element does
B. Moderate not change as there has been no improvement in for
C. Occasional example site security).
D. Remote The presence of the sprinkler would mean that a
E. Unlikely fire occurring beneath a canopy would be controlled
F. Impossible by the property protection sprinkler system; as
sprinklers would be expected to be fitted beneath
The current risk profile shows that all six scenarios canopies preventing fire spread internally into the
fall into the ‘red’ or intolerable section of the risk building and allowing time for the fire and rescue
profile. Taking specifically scenario no ‘2’ as an service to arrive at site, get to work, source water
example (a fire emanating out of deliberate fire supplies and extinguish the fire. The inclusion of the
setting/arson) in a non-sprinkler protected building sprinkler system gives a vastly different outcome;
this could be assessed as a ‘unlikely’ (E) probability’ not only does the risk profile change significantly
but with a catastrophic (I) severity. so does the quantity of overall material damage to
Based on the scenario of the fire occurring at a the building. This can also be expressed in financial
time when the building is unoccupied and there severity terms:
being no life risk, the fire and rescue service would
be expected to respond once called by a member of Current risk profile
the public. Upon arrival the fire and rescue would Loss estimate (£) before adopted Zurich risk
be reasonably expected to undertake defensive improvement advice – buildings £50,000,000 and a
firefighting to mitigate fire spread to adjacent and 24-month business interruption and rebuilding period.

www.ife.org.uk International Fire Professional February 2019 Issue No 27 27

Technical Perspectives
“It is wise to consult and involve the insurer at the earliest
possible stage of the design process”
Target risk profile
Loss estimate (£) reduction with adoption of Zurich
risk improvement advice (sprinkler system to LPC
rules/BSEN12845) £50,000,000 minus £500,000 =
£49,500,000 loss estimate reduction and business
interruption reduced from 24 months to one week
(rounded up to a 99 per cent reduction).
The ZHA highlights the fact that it is easy to seek
compliance without understanding the level of
outcome that compliance delivers and then readily
claim you did what the law demanded. However,
in the stark aftermath of a major fire this does not
always pass the test of good governance by that
business or property owner. Public reaction to
large fires demonstrates a huge interest in what the
building owner has done to protect their property and
can put the property owner under intense scrutiny.
The current Building Regulations are therefore not
necessarily based on providing resilience of the built
environment to fire. This leads to a gap in that building
owners and tenants often assume their properties are
more resilient than they are. It is easy to understand
that building owners following Building Regulations
would expect that the regulations adequately protect
their business from fire. It also helps underline
the continuing gaps highlighted by insurers that
businesses commonly tend to underestimate the value
of their property and overestimate their ability to
recover from a serious fire event.
This gap in understanding can prevent people
from asking important questions to their project
teams at the outset of a project to define their
business resilience objects from a new building or
extension. It can be common for insurers to be left
out of the decision making process with discussion
and decisions around resilience being lost amongst
the plethora of competing voices of regulators,
architects, contractors and suppliers, compounded
by discussions about cost without a discussion about
the wider impact and potential benefit.
Whilst UK Building Regulations define a
minimum level of performance, it is important
to remember if there is a desire to make the built
environment more resilient then it is important
to add to this minimum level of performance. It is
also important to ensure that those delivering
projects are clear on that performance level.
Insurers can offer specialist advice and guidance to
counterbalance this absence of a regulatory steer.
Assuming others will take care of it is not a solid
basis on which to proceed. If you want to avoid
28 International Fire Professional February 2019 Issue No 27 www.ife.org.uk
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disruption, a repeat of a past fire or limit damage
then that needs to clear and communicated at the
concept stage of any project.
Conclusions
Greater collaboration and input is required from
commercial property insurers at the building design
stage in order to champion property protection
and business resilience to build a resilient built
environment. It is impractical to expect insurers to
influence the design team on every project to the
extent desired.
It is therefore important that a business impact
analysis tool such as Zurich Hazard Analysis (ZHA)
is introduced to ensure that property protection and
business continuity objectives are at the forefront of
new building design, whether the insurer is involved
in the process or not.
This will support and help consulting fire
engineers and architectural design teams to
incorporate and imbed business protection
objectives in their fire safety strategy designs,
therefore enabling appropriate fire safety measures
to be incorporated into the building design to
enhance business resilience.
It is wise to consult and involve the insurer at the
earliest possible stage of the design process. Most
insurers have specialist risk, construction and fire
protection engineers who can be contacted for support
and advice over the acceptability of the proposed
building design for property insurance purposes.
References:
1. An investigation into resilient fire engineering building
design Dr Peter Wilkinson, Loughborough University.
About the Author:
Gary Howe EngTech FIFireE is a Senior Fire Protection Engineer with Zurich Risk
Engineering responsible for the assessment and analysis of active fire protection
systems, including witness and proving testing of sprinkler systems, water mist
systems, kitchen extinguishing systems, gaseous fire suppression and automatic
fire detection across a broad of industrial, manufacturing, educational and
commercial premises to support customers and insurance underwriters. He also
undertakes and supports professional development of Zurich field staff through
the Engineering Council and the Institution of Fire Engineers, supporting and
mentoring individuals to achieve Engineering Council/Institution of Fire Engineers
professional registration.
Gary Howe is a member of several national and international committees
representing Zurich, the wider insurance industry and as a UK representative on the
following groups: NFPA750 Standard on Water Mist Fire Protection Systems, British
Standards Institution panel for water mist – BS 8489-1 /BS8458, British Standards
Institution panel for fire engineering – BS9999, FIA/BAFSA water mist working
group panel member, UK delegate for CEN TC191 WG10 European Water Mist
Standards Group – prEN14972, BRE fire suppression liaison group.