LBWF’s Goddarts sheltered housing block in Walthamstow: fire safety assessors find serious issues for five years running, but, astonishingly, they remain unaddressed, leaving vulnerable residents in danger

Goddarts House, Walthamstow, is a purpose built two-storey block, owned and administered by LBWF, containing 27 flats providing sheltered living accommodation.

Its residents include the elderly, and those who have hearing, sight, or mental health impairment. 

Some are wheelchair users.

In 2019-21, Goddarts came to the attention of this blog because one of its residents, Roy Sutton, discovered that though LBWF insisted the front entrance doors to the 27 flats provided 60 minutes protection from fire, in reality they only provided barely half that.

In the end, this saga of the ‘fake fire doors’ led to a court case and an internal fraud investigation (see links, below).

Subsequently, Mr. Sutton has continued to urge that Goddarts be made fully fire safe, and in the course of his investigations, and using the Freedom of Information Act, he recently asked LBWF for the annual Fire Risk Assessments (FRAs) of the block from 2020 to 2024, and was sent five documents, one for each of the five years.

This post begins by examining these documents, and then turns to some related evidence.

But, first, a short digression to explain how FRAs work.

A building like Goddarts, which contains vulnerable residents, must be assessed for its fire safety every year, and LBWF contracts a private company to carry out this duty and report back.

Each FRA is fairly detailed, and looks in turn at a number of variables, from (to give some examples) ‘electrical ignition sources’ and ‘smoking policies’, through ‘means of escape’, to ‘means of giving warning in case of fire’.

However, that said, FRAs do vary in scope, with Type One, the most common and cheapest, focusing on communal spaces rather than individual dwellings, and avoiding any intrusive sampling; and Type Four, at the other end of the spectrum, involving a far more comprehensive approach, encompassing every corner of every room, and if necessary, exploring behind walls and into roof voids.

Finally, there’s a scoring system, with assessors rating each individual fire risk on a three-point scale (High, Medium, and Low priority), and then producing an overall ‘Fire Risk Rating’ for the block.

Turning to the Goddarts FRAs specifically, some of the most salient findings are the following:

(a) All the 2020-24 Goddarts FRAs sent to Mr. Sutton were Type One, and carried out by a company called S3 Environmental Ltd..

(b) Each of the FRAs assessed the overall risk rating for the building to be ‘Moderate’, meaning, in S3 Environmental’s opinion, that ‘It is essential that efforts are made to reduce the risk. Risk reduction measures should be implemented within a defined time period’.

(c) In every FRA, the assessors were unable to name the ‘persons managing fire safety’ at Goddarts. 

(d) As to individual risks, those classified as High or Medium numbered 10 in 2020, 17 in 2021, 19 in 2022, 15 in 2023, and 15 in 2024.

(e) Finally, tracing individual risks rated High and Medium across the years reveals that, surprisingly, some were noted in every one of the FRAs, meaning they remained unaddressed. 

Of this latter group, five stand out for their seriousness, with S3 Environmental describing them thus:

(a)  Travel distances between the flats and safe common areas found to be too great

‘No person should need to travel more than 7.5m from a flat entrance door along a corridor or lobby to reach a fire door to a protected stairway, protected lobby to the stairway or a cross corridor fire door. However, the travel distances noted within the block were found to be in excess of this’.

‘Recommended that corridors and lobbies throughout the common area are restricted to have a maximum travel distance of 7.5m from the flat entrance doors; this can be achieved by the installation of cross-corridor doors and screens’.

(b) Smoke detector issues

‘Although a smoke detection was noted within the [sampled] flat, the cause and effects of the system is unknown. The sample flat was also found to have 2…systems, a stand-alone in flat detection system and a system extended from the common area detection system linked to an alarm receiving centre’.

‘The cause and effect should be confirmed and then the AFD should be configured so that the communal areas received Grade A LD1 coverage…with no communal detection being extended to flats. The flats should have a Grade D1 LD1 detection interlinked with the warden call system that either notifies the scheme manager when they are on site or diverts to the alarm receiving centre’.

(c) Block entrance door issues

‘Block entrance door is electronically controlled’.

‘Recommend management confirm that the secure door entry system fails safe in the event of a power failure or fire alarm’.

(d) Windows on staircase and escape route found to be sealed

‘A number of the windows to the staircase and escape route were found to have sealed double-glazed units with no means of opening’.

‘Recommend that the windows are made to be openable within the staircases and escape route’.

(e) Fire action notices are inconsistent

‘The block contains 2…fire action notices that are inconsistent with their advice’.

‘Recommend that a bespoke fire action notice advising of the “Simultaneous Evacuation” evacuation policy within the common parts and a “Stay Put” policy within the flats be provided in the common areas’.

The fact that nothing was done about these risks across the five-year period, despite them being clearly and repeatedly flagged, is shocking, but there is worse.

One document which LBWF inexplicably did not release to Mr. Sutton is S3 Environmental’s Type Four FRA of Goddarts dated January 2020, but this certainly makes for interesting reading.

As noted above, Type Four FRAs are intrusive, that is they encompass looking beyond walls and ceilings into what lies behind.

One key concern here is the extent of compartmentalisation, because, for example, if roof spaces are not securely isolated, both from each other and from the rooms below, fire may spread dangerously fast.

So what did S3 Environmental find at Goddarts in January 2020?

In all it identified 18 fire risks related to the various roof spaces above the block’s common areas (the lounge, passages, and so on), five rated as High priority.

Most of the latter concerned ‘fire breaks’ being either substandard, that is not installed correctly, or penetrated by service ducting and trunking which was not ‘fire stopped’, in other words not made fully airtight.

Thus, in January 2020, it was absolutely clear that Goddarts’ roof spaces needed sorting out, and urgently, with S3 Environmental recommending that ‘high priority’ risks be rectified within three months.

The relevant question, then, is how S3 Environmental assessors dealt with this alarming discovery in the five succeeding Type One FRAs. 

The form that they used included the question ‘Is compartmentation maintained in the roof space?’, and these are the answers recorded, in date order:

FRA 10 September 2020

‘A number of issues noted to the previous Type 4 survey that has been carried out. These action [sic] should be completed as per the Type 4 assessment’.

FRA 11 August 2021

‘NK. No access to the loft void at the time of survey. Recommend management check compartmentation within the roof space over the common area’.

FRA 28 April 2022

‘NK. No access to the loft void at the time of survey. Recommend management check compartmentation within the roof space over the common area’.

FRA 13 April 2023

‘NK. No access to the loft void at the time of survey. Recommend management check compartmentation within the roof space over the common area’.

FRA 06 February 2024

‘NK. No access to the loft void at the time of survey. Recommend management check compartmentation within the roof space over the common area’.

It doesn’t say much for communication between S3 Environmental and LBWF – to put it mildly – that four years after the Type Four FRA, whether the required remediation work had occurred was still unknown.

Adding to the confusion, it is notable that in its 2022, 2023, and 2024 Type One FRAs, S3 Environmental recommended that there should be a new Type Four FRA.

Why was that thought necessary so soon after the previous one?

In conclusion, the revelations in the preceding paragraphs are disturbing. S3 Environmental discovered serious fire risks at Goddarts, but appears to have been content with simply recording them in successive FRAs, rather than pressing for them to be addressed.

It is unclear why LBWF failed to take the actions that S3 Environmental recommended, and even uncertain whether staff in the Town Hall actually bothered to read the Goddarts FRAs in the first place.

All things considered, can LBWF be said to have exercised its duty of care? Shouldn’t it have been far more energetic in protecting a group of people who unarguably, and through no fault of their own, are particularly ill-placed to deal with a fire?

Finally, what of Mr. Sutton?  He has tirelessly raised concerns over Goddarts, but, as reported by the Waltham Forest Echo, on occasion has received only unacceptable treatment in return.

On the basis of the evidence presented here, though, he stands vindicated.