Hotel Conversion with a Fire Engineering Approach
A 1976 industrial building in Kwun Tong has 12 storeys, a single 1.5 m wide staircase, and a floor plate of 1,500 m². A developer wants to convert it into a 300-room hotel. The existing escape route serves the whole building, and the farthest room on each floor is 38 m from the staircase. Under the prescriptive Code of Practice for Fire Safety in Buildings 2011, the proposed hotel occupancy would require two staircases and a shorter travel distance. The developer proposes a fire engineering approach (FEA): a smoke extraction system in the central corridor, a refuge floor at level 6, and enhanced fire service installations. The project is in a commercial zone; the lease permits hotel use subject to modification. The developer wants to start demolition before the FEA is accepted.
1. Is a fire engineering approach a lawful alternative to the prescriptive code? What must the AP demonstrate?
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Yes, the Building Authority may accept a fire engineering approach as an alternative to full prescriptive compliance, but it is not a waiver. The AP must demonstrate that the proposed design achieves at least the same level of life safety as the prescriptive Code of Practice for Fire Safety in Buildings 2011. The FEA should be prepared by a qualified fire engineer and should cover fire growth, smoke spread, evacuation, fire resistance, fire service access, and management. It needs an acceptance in principle from the Building Authority and the Fire Services Department before detailed design proceeds. The AP should ensure the FEA is building-specific and does not rely on unproven assumptions. If the FEA cannot show equivalence, the AP must require a second staircase, reduced occupancy, or another prescriptive solution. The AP should not let the client treat the FEA as a bargaining tool with the licensing authority.
2. What other approvals and licences are needed before the hotel can open, and how do they interact with the building approval?
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Before opening, the project needs planning permission or confirmation that hotel use is permitted under the outline zoning plan; lease modification or consent from the Lands Department if the lease restricts use; approval of building plans and consent to commence works under the Buildings Ordinance; an occupation permit or temporary occupation permit; fire service installations accepted by the Fire Services Department; and a hotel licence under the Hotel and Guesthouse Accommodation Ordinance (Cap 349) from the Home Affairs Department. The licence application will require proof of compliance with building and fire safety, and the licensing authority may impose conditions. These approvals interact: an FEA accepted for building approval does not automatically satisfy the hotel licensing authority, and an occupation permit cannot be issued until the building is fit for occupation. The AP should programme these approvals early and advise the client that opening without the licence is an offence.
3. The contractor wants to start demolition of non-structural partitions before plan approval. Advise the AP.
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The AP should not allow demolition to start without the required approval and consent. Demolition is building works and may require approval of demolition plans, a demolition method statement, and precautions for adjoining structures. Even if some internal partitions could fall under the minor works regime, the proposed FEA depends on the existing layout and fire strategy, and early demolition could prejudice the FEA and create unauthorized works. The AP should instruct the contractor to hold, record the instruction, and explain to the client that starting early may invalidate insurance and delay the FEA. The AP should also check whether the contractor has submitted the required notices and whether the building is vacant. If demolition proceeds, the AP should report to the Building Authority and consider whether to suspend services.