Temporary building, permanent responsibilities
Temporary buildings are a familiar feature of construction sites. Modular cabins and relocatable units provide offices, meeting rooms, welfare facilities and other accommodation that must change as work progresses. Their temporary status, however, can create a false impression that the fire precautions within them are also temporary or less important.
A recent CROSS-UK report on fire safety governance and oversight for temporary and ancillary buildings draws attention to this risk. Some buildings used during construction work may be exempt from the Building Regulations, provided that the relevant statutory conditions are met. This can mean that they are installed without the building control scrutiny or fire safety information that would ordinarily accompany a permanent building.
That exemption does not make them unregulated spaces.
Temporary can mean several years
Site accommodation may remain in use for a substantial part of a major construction programme. It can be extended, stacked, relocated and repeatedly reconfigured. Doors, partitions and services may be altered, while changing site conditions can affect escape routes and fire and rescue service access.
Units may also be purchased second-hand and reassembled without complete information about their construction, previous alterations or fire performance. Gaps between modules, concealed voids, damaged linings and incomplete fire stopping can introduce routes for fire and smoke spread that are not immediately apparent.
The more extensive and complex the accommodation becomes, the less credible it is to treat it as a simple collection of temporary cabins.
Exemption does not remove responsibility
Although qualifying temporary buildings may be exempt from the Building Regulations, fire and health and safety duties continue to apply. The Regulatory Reform (Fire Safety) Order 2005 applies to non-domestic premises in England and Wales, while construction work is also subject to the wider requirements of health and safety legislation and the Construction (Design and Management) Regulations.
The important question is therefore not simply whether a building requires Building Regulations approval. It is whether its fire risks have been understood and managed competently.
A suitable assessment should consider the building’s construction, height, layout and occupancy, together with detection and warning, travel distances, exit capacity, emergency lighting and the potential for fire spread between modules. It should also consider surrounding construction activities, temporary power supplies, heating equipment, battery charging, combustible storage and changes to fire and rescue service access.
A strategy proportionate to the risk
Not every site cabin requires a complex fire strategy. A small, single-storey unit accommodating a few people may be adequately addressed through the site fire risk assessment and established management arrangements.
A large or multi-storey complex is different. Where significant numbers of people are accommodated, escape routes become more complicated or the construction cannot be readily verified, a documented fire strategy may be proportionate. This should define the fire safety objectives, assumptions about occupancy and construction, essential precautions and arrangements for reviewing the strategy as the site changes.
The same principle applies to inspection and maintenance. A unit that has been transported and reassembled should not automatically be assumed to retain its original fire performance. Its condition and the integrity of safety-critical elements need to be checked.
Calling a building temporary describes its intended period of use. It does not describe the potential consequences of a fire. Whatever the regulatory route, the responsibility to provide safe accommodation remains.
Pyrology Insight provides commentary on contemporary fire safety topics. It is intended to stimulate professional discussion and should not be relied upon as project-specific advice.