Next question:

What is the definition of 'student accommodation'?

I know we love to nit pick minuate of our regulations, but surely in this case, the regulation is fairly straight forwards - in intention at least - and intends for all student accommodation to have AFDDs? It doesn't really matter if it was built from the ground up or a conversion has happened, if the property has only students living in it, then AFDDs shall * (nowadays) be used. 

It doesn't leave a lot of wriggle room for engineering judgement.......

FYI - I am yet to be convinced of the effectiveness of AFDDs, or anything at all to do with AFDDs - I dislike the idea and implementation of something I cant test at install or fault find later on. I hate the things. Ignorance probably on my part......

tattyinengland said:

the regulation is fairly straight forwards - in intention at least - and intends for all student accommodation to have AFDDs?

Then why does it say something else?

That depends upon your definition of "student", which broadly, is anybody who studies. Specifically, at Christ Church, Oxford, it means a senior member of the College, i.e. a (teaching) fellow. In common parlance, however, I think that it means an undergraduate (of a university).

In the context of BS 7671, I take "purpose-built student accommodation" to mean halls of residence at a university.

Well now, you could have a barn which has been (purpose) built for the housing of livestock or storage of agricultural produce; but then again, you could have one which has been converted into domestic accommodation.

Here is a view which demonstrates what I mean. On the right we have what is clearly purpose-built student accommodation, but the occupants will be both undergraduates and teaching staff. On the far left is a rather fine building designed by Edwin Lutyens, which is also purpose built. Then there is a small post-war block which looks like a small block of council flats, which is again purpose-built. But what about the "student accommodation" in the foreground on the left? I suggest converted and not purpose built.

I would turn your argument on its head!

Classify C3, but then go on to explain the origin of the non-compliance. You may then say that the responsible authority may wish to have a fire risk assessment undertaken in order to inform their decision as to what action should be taken. We all know that C3 does not require further action.

Perhaps the old code 4 should be brought back. I note that the said BPG uses an observation "worthy of note" which to me implies that there is no suitable code available. It begs the question why deviate from the exemplar form set out in Appendix 6. 

Not that I would hold the codes used in the periodic verification forms used in ROI up as any kind of shining example, they do at least let me avoid making a recommendation for improvement just because a normative aspect is absent. (IS1010-1 2020 used in the ROI  sensibly makes only a recommendation that AFDDS should be used where the fire risk is other than standard).