The regs: School buildings
Geoff Wilkinson looks at the application of the Building Regulations to school buildings
School premises have had to comply with many pieces of legislation, including the Schools Premises Regulations 1999, Health and Safety at Work Act 1974, Management of Health and Safety at Work Regulations 1999, Workplace (Health, Safety and Welfare) Regulations 1992, Control of Asbestos Regulations, Building Regulations, and Regulatory Reform (Fire Services) Order 2005.
Reducing the regulation and bureaucracy around school premises was recommended in the independent ‘Review of Education Capital’ carried out by Sebastian James. One recommendation was to revise its school premises regulations and guidance to remove unnecessary burdens and ensure that a single, clear set of regulations apply to all schools. Another was that they should seek to further reduce the bureaucracy and prescription surrounding BREEAM assessments.
In November 2011, the department launched a consultation on making identical requirements for the maintained and independent sectors and to reduce the number of regulations. From that, the new school premises regulations for maintained schools came into force on 31 October 2012 and the Independent School Standards from January 2013. The guidance advises schools and local authorities on how to meet the regulations. It also provides signposts to other, more general, building and premises-related legislation and guidance of relevance to schools but, in my opinion, falls far short of a single, clear set of regulations.
While schools are expected to comply with the Building Regulations, the Approved Documents are not always the appropriate guide and instead a series of Building Bulletins remain which provide alternative (and sometimes conflicting) guidance on technical standards. The most commonly used are:
• BB.83 Schools’ Environmental Assessment Method
• BB.87 Guidelines for Environmental Design
• BB.90 Lighting Design
• BB.91 Access for disabled people in schools (Superseded by BB.102)
• BB.93 Acoustic Design of Schools
• BB.95 Schools for the future
• BB.100 Fire Safety Design
• BB.101 Ventilation
• BB.102 Designing for disabled children and children with special educational needs.
The problem for designers is that building control bodies have widely varying views on the application of the guidance, and whether the current or original versions of the guidance should be applied. As an example, BB.93 was updated in September 2012, though the Building Regulations (and more specifically Part E) wasn’t. So the updated document ‘Acoustic performance standards for the priority schools building programme’ should be used for schemes under the PSBP, but not other schools. Any variations from the existing BB.93 should be taken as Alternative Performance Standards approved by the Education Funding Agency for this programme. Confused yet? You will be!
Another area of frequent confusion is emergency lighting. We often hear schools saying they don’t require emergency lighting, and certainly until 2001, when the general exemption for schools was withdrawn, that was probably true. By contrast, BB.100 refers back to BS 5266:Part 7 and requires ‘non-maintained’ emergency lighting to: (1) clearly indicate and illuminate escape routes and exit signs; (2) ensure that changes of level and direction are indicated and (3) ensure that fire alarm call points and firefighting equipment can be easily located.
A third possible interpretation under the guidance in Approved Document B comes as schools are classed as assembly buildings. Hence emergency lighting should be provided to all escape routes and accommodation areas, toilet accommodation with a floor area over 8m², electricity and generator rooms and switch room/battery rooms.
Given such wide-ranging variations, architects are wise to engage with their chosen building control body early in the process to ensure appropriate guidance can be agreed before detail design is undertaken.
Geoff Wilkinson is managing director of Wilkinson Construction Consultants