A Hotel in a 1972 Factory

Statutory route.

• A change of use from industrial to hotel is a building works and change of use project. Plans must be prepared and submitted by an AP and approved by the Building Authority before work starts. The Building (Planning) Regulations and the Code of Practice for Fire Safety in Buildings apply.
• The hotel use also triggers the Hotel and Guesthouse Accommodation Ordinance (Cap. 349) licensing regime, which requires building and fire safety compliance to the satisfaction of the licensing authority, together with Fire Services Department requirements. An occupation permit is not a hotel licence; both are needed.
• Existing buildings are not exempt. The AP must demonstrate compliance, or propose an alternative acceptable to the Building Authority, typically through a fire engineering approach agreed in principle in advance.

Principal fire safety issues.

1. Means of escape. A hotel is non-residential with a sleeping risk. A 780 square metre floor plate served by one 1.1 m staircase gives a single direction of escape for much of the floor. Two independent escape routes are the norm; a single staircase must be justified against the Code's travel distance, exit width, occupancy and single-staircase provisions, or replaced.
2. Protected staircase and lobby. Guest rooms approaching the stair need a protected lobby, and the stair enclosure needs the required fire resistance with self-closing doors and no unprotected openings.
3. Sprinkler system. The existing industrial installation is unlikely to meet the current standard. Design, coverage and water supply need upgrading and Fire Services Department acceptance.
4. Smoke control. The restaurant and gym need smoke extraction and appropriate compartmentation; the hotel lobby needs smoke control.
5. Firefighting access and provisions. Fireman's lift and firefighting shaft requirements, appliance access, and the 3 m back lane and 6 m separation to the neighbouring building all need checking against the Code's unprotected opening and separation provisions.
6. Structural fire resistance. The conversion changes imposed loads and compartment sizes.
7. Licensing conditions will add requirements beyond building approval.

The consultant's opinion addresses only one of these.

The claim is a conclusion without an argument. 'It is sprinklered, therefore one staircase' does not follow, and the burden is on whoever relies on it to produce the reasoning.

Why sprinklers alone are not enough.

• The Code permits a single staircase or direct exit only within defined limits, typically small floor plates, low occupant numbers, short travel distances and a limited single direction of escape. A 780 square metre floor containing a restaurant and a gym is not obviously within those limits, and the numbers must be checked against the relevant tables.
• A performance-based justification for a single staircase in a sleeping-risk building must address: the probability of a fire occurring in or near the only stair; smoke control and pressurisation of that stair; the reliability and maintenance of the sprinkler system, since a single-stair building has no redundancy when the system is impaired or isolated; the evacuation strategy for sleeping guests who are unfamiliar with the building; and fire service access and intervention.
• The fire engineering approach must be agreed with the Building Authority and the Fire Services Department. An indicative opinion from a consultant who is not the AP is not an approval and creates no reliance for anyone.
• The separation to the neighbouring building and the unprotected openings facing the 3 m lane may themselves require upgrading, which affects the single-staircase case.

What I would ask for. The calculation: assumed occupancy, exit width and discharge capacity, travel distances, the single-direction limits relied on, the smoke control design and the acceptance criteria. If the answer is simply 'sprinklers', the case is not made. The next step is either a code-compliant second staircase or a properly commissioned fire engineering study to be discussed with the Building Authority before submission.

Programme reality. A fire engineering route is not faster than a straightforward compliant design. It requires agreement, and often departmental review. That matters directly to the Christmas target the client is working to.

Options.

1. Second staircase, external or internal, with a protected lobby. It costs two to three rooms per floor and part of the restaurant or gym, with added cost and time. It is the route most likely to secure approval without argument.
2. Pressurised single staircase plus fire engineering. Retain the stair, upgrade the enclosure and pressurisation, add a protected lobby, upgrade the sprinkler system and obtain Building Authority and Fire Services Department acceptance of the single-staircase case. It preserves the room count but carries approval risk and its own cost.
3. Reduce risk to fit the Code. Reduce occupancy, restrict the restaurant or function areas and reconfigure guest rooms so that travel distances and single-direction limits are met.
4. Change the use to one with a lower sleeping risk that the existing stair can support.

Programme advice. Plan approval, Fire Services Department acceptance and Cap. 349 licensing will not be compressed into the weeks before Christmas on any of these routes. Advise the client in writing of a realistic opening date and the cost of a rushed opening, so the decision is made with the facts in front of them.

If the client insists on opening regardless.

• You cannot submit an occupation permit application or certify completion for works you know do not comply. That is false certification and a disciplinary matter.
• Opening a hotel without an occupation permit or a Cap. 349 licence is unlawful. The operator carries that risk, but an architect who facilitates it shares the professional consequences.
• Put your advice in writing, setting out the specific risks: refusal or revocation of licence, invalidation of insurance, closure, and personal liability of the operator.
• If instructed to proceed on an unlawful basis, decline, and consider whether you can continue to act. Document the decision.

The AP's duty. The AP's statutory duty runs to the Building Authority, not only to the client. That is why a client's commercial timetable cannot be treated as a design constraint.