Written by Muna Hanim Abdul Samad
School of Housing, Building, and Planning, Universiti Sains Malaysia (USM), Penang, Malaysia.
Since the Great of Fire of London in 1666, fire regulations had progressed a long way underlying passive and active fire safety provisions to safeguard occupants from hazardous fire incidents and prevent massive properties losses. In Malaysia, fire safety is governed by the Uniform Building By-law (UBBL) 1984 under the Streets, Drainage and Building Act 1974. Its prescriptive nature has made the requirements out dated from the viewpoint of current performance-based design (PBD) approach in most developed countries including the UK. In the meantime, fire safety legislation for England and Wales was enacted under the Building Regulation, and the Approved Document B – Volume 1 for Dwellings and Volume 2 – Buildings other than Dwellings, of 2019 edition. According to the latest statistics in Malaysia as of 2019, there were 121 deaths from fire incidents whilst in England, the latest statistics shows that there were 243 fatalities related to fire incidents in 2019/20. This paper is a comparative study to review the regulations in both countries. It also investigates a few state-of the-art tall structures in Malaysia and how the UBBL implementation affect the design due to its prescriptive nature and the constrain in the implementation of the fire safety on such complex design.
Fire disasters pose very serious threats to humans, especially in the confined spaces of buildings, where the effects of fire: flames, heat, smoke and toxic gases can endanger occupants and cause death from asphyxiation as the highest risk. The Great fire of London in 1666 was infamous as a point in history to trigger enactments of most fire policies used worldwide today including legislation, fire insurance and professional fire-fighting services . Whilst in Malaysia, a great fire in Kuala Lumpur two centuries later in 1826, prompted the city to adopt some fire measures by storing fire drums at strategic locations, installing gongs and creating firebreaks between buildings . Subsequently, a fire in 1881, called for tougher actions, where the British resident Frank Swettenham issued an order to demolish timber premises and replaced by two-storeys brick structures with tiled roofs and shops within a block to be connected with a five-foot walkway . In the present day, fire protection in Malaysia is governed by the Malaysian Uniform Building By-Laws 1984, (the latest amendment as of 2012)  under the Streets, Drainage and Building Act 1974  with a prescriptive content in nature. Nonetheless, the Malaysian Fire and Rescue Department (MFRD) had issued a buletin in March 2020 , allowing for PBD as alternative means of compliance against the UBBL 1984 clauses on travel distance and compartmentation under the control of ‘authorities having jurisdiction’ i.e. the Director General of MFRD. The PBD approval should be in accordance to Available Safe Egress Time (ASET) which is from time of fire ignition to the point it reaches untenable conditions along the evacuation route, against the Required Safe Egree Time (RSET), the time taken for occupants to be alerted on the fire incident to the time they reach safety . The ASET time should exceed RSET time for safe evacuation process. The buletin suggests PBD using fire dynamic simulations (FDS) on computational fluid dynamics (CFD) . At the same time, for England and Wales, the latest fire safety legislation are under the Building Regulation 2010, and the Approved Document B – Volume 1 for Dwellings  and Volume 2 – Buildings other than Dwellings, of 2019 edition . The Approved Document is a guidance in fulfilling the Building Regulation and any alternative compliance from parties carrying out building works should be highlighted at an early stage. Malaysian fire statistics in 2018 shows that there were 6,626 cases of fire incidents involving structures, with 97 deaths and RM3.3billions of monetary losses . The main causes of fire are electrical failures accounting for 3,893 cases and 267 fires are caused by arson. The number of deaths is 1:325,051 to the ratio of the population. There are no statistics on fire involving high-rise buildings but only by typology and the highest involves domestic premises.
Figure 1. The Relationship Between ASET/RSET Time 
From the 2019/20 statistics, the Fire and Rescue Services (FRSs) in England attended 153,957 fire incidents and reported 243 fire-related fatalities in the same period . Though the figures for the last decade show a decrease of incidents involving fires but the pattern deviate in 2017, with 72 fatalities from the Grenfell Tower tragedy alone as shown in Table 1. Out of the fire incidents in the same year, it can be observed that 775 occurrences are fires involving high-rise flats purpose-built (10-storeys and above). The number of deaths to ratio of population is 1:244,609 population. The PBD approach to regulate buildings especially those that are very complex in design and functions relies on the fire safety engineering (FSE) methods to predict the fire scenario [12,13,14,15]. The approved document stated on FSE approach as alternative means to fire safety provisions and may deem the only practical way [8,9] to achieve a satisfactory standard of fire safety in some complex buildings and in buildings that contain multiple purpose uses. The aim of this review is to look into the case scenario on the effectiveness of the performance- based regulations and the problems in real implementation in comparison to prescriptive fire regulations.
Table 1. Fire Fatalities in England 2010-2019, Source 
2. Problem Statement
In this present day, fire remains one of the major hazards, albeit of the various safety measures and legislative requirements for building in the design stage as well as management regulations. Buildings are getting taller and more complex where prescriptive regulations and laws enacted from empirical judgements and often nor resulted from scientific research nor engineering verification in most countries are no longer apt to cater to those complexities [12,13,14,15]. In 1930, the Chrysler building in New York was design with 77-storeys and 252m high, and presently the tallest tower in the world is the Kingdom Tower, in Jeddah, tripled the height reaching 167-storeys and 634m in height . The tallest tower in UK is the Shard building, in London, rising up to 70- storeys at 310m height , while the tallest tower in Malaysia is to be completed in 2022, namely the Merdeka PNB 118 Tower reaching 118-storeys and 644m high . With the advancement of technology, the needs for sustainability and to reduce carbon footprint, many Asian and Middle Eastern countries had dominated the tall structures scene . Nevertheless, the tragedy of September 11, had raised concerns over tall structures on the structural integrity, fire threat, means of escape and rescue facilities for such buildings. However, there are arguments that FSE and PBD should be able to predict or designed to envisage the best fire scenario, evacuation and rescue [12,13,14,15]. On the other side of the coin, there is the cautionary viewpoint that performance-based regulatory practice may be hurdled by the regulators lack of competency in FSE, whereby a PBD solution will require them to play a bigger role to enforce adequately . The concept of PBD on the other hand is based on self-regulation, nonetheless there is still a skeptical stand on the readiness of FSE, in terms of training and to gauge the quantification of various performance scenario. Research on the chemical and physical dynamics of fire and smoke behaviours have not been fully translated and integrated into fire risk modelling for performance-based approach . There are also studies to highlight the complexity and unpredictability of human behaviours and the delays in ques by occupants in evacuation process in which the building evacuation engineering in the FDS should take into account [19, 20].
The research is a re-visit by the author on her PhD research of the comparative study on the safety of apartment buildings in Malaysia and England submitted in 1995. It is imperative that the research looked into the applications of regulatory requirements in both countries. This paper is a review on the current status quo and the overview of fire safety regulations and how they evolved to the current stage to cater for challenging design issues with complexity in designs and functions coupled with advancement in technology. The method employed is based on literature review, content analysis and case review on selected buildings in how the regulations requirements affected the design solutions.
4. Comparison of Fire Regulations
As mentioned above, fire protection regulations in Malaysia are stipulated under the Malaysian Uniform Building By-Laws 1984, (the latest amendment as of 2012) . The UBBL requirements on Fire are under Part VII -Fire Requirements and Part VIII – Fire Alarms, Fire Detection, Fire Extinguishment and Fire Fighting Access as well as under Schedule as shown in Figure 2 and Table 2. The fire safety regulatory requirements for England and Wales are governed by the Building Regulation 2010 and guided by the Approved Document B – Volume 1  and Volume 2  – for Dwellings and for Buildings other than Dwellings, of 2019 edition as shown in Table 3. The 2019 amendments of Approved Documents had included the shift of blocks of flats purpose group from Volume 2 to Volume 1 under Dwellings.
Figure 2. Part VII (Passive) Fire Requirements UBBL 1984.
Table 2. PART VIII (Active fire requirements) fire alarms, fire detection, fire extinguishment and fire-fighting access, UBBL 1984
Table 3 Approved Document Volume 1 and 2, Building Regulation 2010.
The comparison on the requirements for both countries, it is categorized under examples of core topics are described in Table 4, below:
Table 4. Comparison of some core requirements in UBBL 1984 and Approved Documents Volume 1 and 2
The regulation in both countries shows that the requirements are very well in place to safeguard buildings on fire safety but caution should be placed on the actual implementation on real situations especially for single staircase buildings relies heavily on the integrity of compartmentalization of the stairs lobby and if they are compromised due to flaws in construction, the result would be detrimental on the occupants if a fire was to occur. The UBBL specify single staircase building only applied to a building with topmost floor of 12m and only dwelling and offices above whilst shops or car park on ground floor. For Approved Document for Dwellings, a single staircase is permissible for dwellings with topmost floor of 11m. An example of the Approved document Volume 1 approach is to recommend that for ‘buildings containing flats, there are appropriate provisions to support a stay put evacuation strategy’  and this may work for new buildings designed according to new regulations but unfortunately for Grenfell Tower, a building designed in the 1970’s with only 1 escape staircase (which would not be approved in current times ). According to Grenfell Tower Inquiry: Phase 1 Report the stay put advice by the emergency services team to the residents was an error in judgement when the fire spread rapidly due to compartmentation failure . The report highlighted that evident shows the external walls of the building failed to comply with Requirement B4(1) of Schedule 1 to the Building Regulations 2010, in resisting fire spread adequately, more damaging is that they actively contributed to the rapid fire spread, resulting in 72 occupants losing their lives . It is highlighted elsewhere, that the aluminum cladding used in the building in 2016 renovations, of two layers of 3-millimeter-thick aluminum sheeting around a flammable polyethylene core, are banned in many countries, for use in buildings of this height . It is a sad reminder of the Summerland Fire Tragedy, 1973 , where the use of combustible materials in the lining and acrylic plastic materials walls, caused the rapid fire spread and claimed the lives of fifty people. As for the UBBL 1984, it is timely that the regulations be reviewed in totality to underline the overall concept of fire safety to achieve, from control on the source of fire, containment, compartmentation, structural integrity, internal walls integrity, means of escape, etc. instead of adding a list of clauses to fulfill. The UBBL does fulfill a minimum standard of safety but needs to be flexible for overall safety involving new innovation in design and complex buildings.
5. Case Review of High-Rise Buildings
This section of the paper reviewed two of the high-rise buildings in Malaysia, one of an iconic building not only in Malaysia but once upon a time was the tallest building in the world (1998 to 2004), the Petronas Twin Towers and the latest addition and would become the tallest structure in the country, the Merdeka PNB 118 as well as reviewing an iconic building in London, the Shard. It is to look at the fire safety systems and designed was applied to those buildings. From the review of the three cases of tall structures in both countries, they showed that the complexity of the safety system requires a PFB approach to resolve the multi-issues on fire safety but mainly learning from September 11 incident. Even for the Petronas Twin Towers, although the building was designed and constructed before the tragedy but the management team had device SOPs on evacuation procedures to cater for any eventuality. Another prominent finding from the review is that the Building Regulation 2010, and Approved document Volume 2, is inadequate for the design of the Shard with various purpose use combining office, hotels, public facilities as well as apartment building relies heavily on PBD and FSE in providing solution in the design of the building. A thermal modelling was adopted to ascertain the members to used for the steel framing from second to 40th floors of retail and commercial levels and whole modelling was used to determine overall performance of the building. From those modelling the designer was able to make better choices and reduce overall structural frames and cost on steels members and reducing to a thin layer of intumescent protection .
Table 5: Case Review of High-rise Buildings in Malaysia and England
From the study of both countries and review on various research conducted on fire safety development, the PBD is inevitable as a way forward. However, for Malaysia the field of FSE is at its infancy with only one course at Masters level, Master of Science, Fire Safety Engineering in the Universiti Sains Malaysia. The rest are short term training provided by various institutions. It is therefore, not feasible to adopt a FSE approach on a moderate project when there is no expertise on both the building designers and clients’ side as well as the authorities to approve submission based on PBD and FSE. Although the concept of PBD is self-regulatory with proves from FSE, based fire risk simulation and fire modellings to prove of compliance to provisions of fire safety, but on the receiving end, councils and authorities should be able to provide feedbacks on those proposals in totality to achieve safety. Due the shortcomings of lack in expertise that may not be possible. The common practice is that for mega projects, developers would usually commission international consultants which would use the PBD and FSE approach. A review on fire safety for supertall buildings, concluded that for such structures the International Building Codes (IBC) is a good way forward for ensuring a overall standard are achieved with more rigorous requirements based on IBC for building above 120 meters. Amongst issues highlighted in the review for improved fire safety in tall buildings are; higher fire structural resistance of frames and floors, improved integrity on staircases, improved sprinklers and wet riser systems, additional stairs for fire-fighting and the use of evacuation lifts . Nevertheless, the skepticism from some scholars  as mentioned above, factors on lack of FSE professionals, gaps in data and knowledge, lack of translation of research on physics and chemistry research into fire modelling, the lack of human behaviour in fire studies taken into account into the modelling, variability in the application of FSE and inadequate levels of training and lack of experience in key players implementing fire safety.
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Muna Hanim Abdul Samad is an Associate Professor in the Architecture Programme at the School of Housing, Building and Planning, Universiti Sains Malaysia. She obtained her PhD in the field of Fire Safety Design from the University of Manchester, Institute of Science and Technology (UMIST), United Kingdom in 1995. Prior to that she completed her Bachelor of Architecture (Hons) and Post-Graduate Diploma in Architecture at Manchester Polytechnic now known as Manchester Metropolitan University from 1985 to 1990. While she was the head of architecture programme, she advocated the architecture curriculum in USM towards sustainability previously with Eotecture branding. She engaged herself in various research and published many academic writings on environmental issues including on Indoor Environmental Quality. She is also a committee member of USM’s People with Disability Cluster and was involved in various Universal Design audit of buildings in USM and the State of Penang, Malaysia.
This research paper was presented at the 2021 CABE Malaysia Chapter online Conference.