Request ID: FOI-0396-2122 Date published: 22 June 2021
You asked
To whom it may concern,
I am writing following reports of a fire on Friday April 9th 2021 in the A102 Blackwall Tunnel. In a video published online, drivers can be seen to pass a car on fire in contravention of the fire safety advice audible through the tunnel sound system as well as on the overhead ‘Red X’ Lane control signs, and proceed directly past the car fire and into the smoke beyond. Clearly, this is not standard for a tunnel fire, however instead goes against assumptions made about people’s behaviour when encountering a tunnel fire. In light of this, I would appreciate it if you could provide the following information, related to the A102 Blackwall Tunnel:
- Details of the Fire risk assessments carried out in the tunnels including when these were carried out
- Details of when any Fire Mitigation equipment was installed in the tunnels
- Any report containing information into assumptions made about the behaviour and/or expected reaction of drivers using the tunnel when encountering a fire
- Details of the standard procedure when dealing with a fire
-Any contingency planning to mitigate the risk posed by people failing to follow the standard procedure (such as the situation outlined previously)
-Details about any investigations carried out by TfL or any third party on its behalf in relation to the events described above
-Any recommendations and improvements being considered following the above incident
- Whether TfL assesses that the risk of harm to motorists using the tunnels has increased in light of the developments of the incident above, and whether the currently installed fire mitigation is sufficient in light of the above.
In addition, I would if possible I would like to know the following:
-Whether this incident has meant that TfL are now reviewing safety measures in any other road tunnels on its network
-A brief outline of the fire mitigation systems in other similar road tunnels (such as the Rotherine or Limehouse tunnels), and whether there are similarities in the fire mitigation techniques used in these other tunnels, such that the incident in the Blackwall may have a likely impact on the assumed effectiveness of the mitigation in these other tunnels
-Whether TfL is consulting with any other public body (such as the LFB, or DfT) as a result of the incident above.
I would very much appreciate it if you could provide such information and await your response.
We answered
TfL Ref: EIR-0396-2122 Thank you for your request of 26th May 2021 asking for information about fire mitigation measures in relation to the Blackwall Tunnel. Your request has been considered in accordance with the requirements of the Environmental Information Regulations and our information access policy. You wrote: “I am writing following reports of a fire on Friday April 9th 2021 in the A102 Blackwall Tunnel. In a video published online, drivers can be seen to pass a car on fire in contravention of the fire safety advice audible through the tunnel sound system as well as on the overhead ‘Red X’ Lane control signs, and proceed directly past the car fire and into the smoke beyond. Clearly, this is not standard for a tunnel fire, however instead goes against assumptions made about people’s behaviour when encountering a tunnel fire. In light of this, I would appreciate it if you could provide the following information, related to the A102 Blackwall Tunnel: - Details of the Fire risk assessments carried out in the tunnels including when these were carried out - Details of when any Fire Mitigation equipment was installed in the tunnels - Any report containing information into assumptions made about the behaviour and/or expected reaction of drivers using the tunnel when encountering a fire - Details of the standard procedure when dealing with a fire -Any contingency planning to mitigate the risk posed by people failing to follow the standard procedure (such as the situation outlined previously) -Details about any investigations carried out by TfL or any third party on its behalf in relation to the events described above -Any recommendations and improvements being considered following the above incident - Whether TfL assesses that the risk of harm to motorists using the tunnels has increased in light of the developments of the incident above, and whether the currently installed fire mitigation is sufficient in light of the above. In addition, I would if possible I would like to know the following: -Whether this incident has meant that TfL are now reviewing safety measures in any other road tunnels on its network -A brief outline of the fire mitigation systems in other similar road tunnels (such as the Rotherine or Limehouse tunnels), and whether there are similarities in the fire mitigation techniques used in these other tunnels, such that the incident in the Blackwall may have a likely impact on the assumed effectiveness of the mitigation in these other tunnels -Whether TfL is consulting with any other public body (such as the LFB, or DfT) as a result of the incident above.” TfL works alongside the Metropolitan Police Service and London Fire Brigade to ensure the response to emergencies, such as this vehicle fire, keep all road users safe. TfL continuously reviews the processes in place to ensure our roads and infrastructure are safe for all, and carries out lessons learned exercises after any significant incident. In regard to your specific questions, these are addressed in turn below: Question 1: Details of the Fire risk assessments carried out in the tunnels including when these were carried out. It is not entirely clear what “details” are requested. However, note that the fire risk assessments themselves are subject to an EIR exception on the grounds of National Security and Public Safety (under Regulation 12(5)(a)). This applies on the same basis as detailed in the following Decision Notice from the Information Commissioner’s Office (ICO) in relation to a similar request about the ventilation system in the Rotherhithe Tunnel: https://ico.org.uk/media/action-weve-taken/decision-notices/2019/2615771/fer0820729-1.pdf The basis for the exception applying here is the same. Regulation 12(5)(a) provides that a public authority may refuse to disclose information to the extent that its disclosure would adversely affect national security or public safety. Whilst we make no suggestion that you would use this information for anything other than your own personal interests, note that release of information under the EIR is considered to be release to the world at large rather than to the individual applicant, as once it is outside of TfL’s possession it can be circulated more widely without control. As you will no doubt be aware, TfL infrastructure has been the subject of attacks in the past and the release of information which may be of value to those looking to plan and carry out such attacks must be treated with caution. Fire risk assessments fall into this category, as they contain detailed information about the infrastructure and potential areas of vulnerability, and we believe that the release of such material would put the public at risk. Note that in the Decision Notice referenced above the ICO stated that: “The Commissioner is also mindful that terrorists can be highly motivated and may go to great lengths to gather intelligence. This means there may be grounds for withholding what seems harmless information on the basis that it may assist terrorists when pieced together with other information they may obtain.” Further, the Commissioner stated that: “In the Commissioner’s view disclosure would give encouragement to those with ill intent or help them plan an attack. The Commissioner also recognises that disclosure would be likely to increase the confidence of any attacker even if that confidence is ultimately misguided or irrational.” While these comments relate to a separate case, we believe the principles nonetheless hold true here given the obvious similarities in the information in hand. The application of this exception is subject to consideration of the ‘Public Interest Test’, whereby TfL must consider whether the greater public interest lies in applying the exception and withholding the information or, instead, in releasing it. In this case we believe that the greater public interest lies in the exception applying. We recognise that there is a genuine public interest in the safety of public infrastructure and the fact that you have asked for the information is in itself an argument in favour of release. However, the safety of the tunnel is assured by the requirement to comply with relevant standards - such as Highways England’s risks based design standards (BD78/99: Design of Road Tunnels) - and the fact that all TfL tunnels have a specific incident response plan, including liaison with the emergency services. Further, there is a significant public interest in not disclosing information that may be used by those who pose a threat to the wellbeing of individuals and the nation. Disclosure of information that would pose a threat to national security and public safety can never be considered to be in the public interest, and in this case we believe that this outweighs any interest in release of the information. That said, we can answer the specific question about dates: the last Northbound Fire Risk Assessment (FRA) was completed on 19th May 2020. The Southbound FRA was delayed due to COVID restrictions but the estimated completion date is by the end of July 2021. TfL have also recently commissioned an independent review of end to end fire safety and risk from an external company due for completion in August 2021. A similar review was carried out for Rotherhithe Tunnel in late 2019. Question 2: Details of when any Fire Mitigation equipment was installed in the tunnels. The tunnel includes a range of fire mitigation measures and equipment. However, details of exactly what these measures are, and when they were installed, is being withheld under Regulation 12(5)(a) on the same basis as explained above. Question 3: Any report containing information into assumptions made about the behaviour and/or expected reaction of drivers using the tunnel when encountering a fire. TfL does not hold any specific reports on user behaviours in relation to the Blackwall Tunnel, but we are aware of industry-wide documents touching on this subject, and we have engaged with Highways England and other organisations nationally and internationally on the subject of human behaviour during tunnel fire incidents. Question 4: Details of the standard procedure when dealing with a fire. It is unclear exactly what ‘details’ are requested. TfL has specific incident response plans for all of our tunnels which are activated by staff in the Network Management Control Centre when an incident occurs. Once a fire is identified the incident will be logged and staff will implement the response plan. These plans include measures such as: closure of the tunnel, illuminating Wayfinders (signs for people walking within the tunnel); activating the Public Address system to warn drivers; the use of signage to alert drivers; and updating the TfL website to notify people that the tunnel is closed. This is not an exhaustive list, and more specific details of the exact procedures implemented are being withheld under Regulation 12(5)(a) on the same basis as explained above. Question 5: Any contingency planning to mitigate the risk posed by people failing to follow the standard procedure (such as the situation outlined previously) The incident response plans referenced above outline the procedure for the safe evacuation of the tunnel, including what happens if tunnel users do not follow procedure. More specific details are excepted from disclosure under Regulation 12(5)(a), for the same reasons cited above. Question 6: Details about any investigations carried out by TfL or any third party on its behalf in relation to the events described above And; Question 7: Any recommendations and improvements being considered following the above incident It is unclear exactly what “details” are requested. A lessons learnt report was undertaken (which is the case for all significant incidents) by TfL and included input from all relevant stakeholders. This is currently in draft format. The specifics of the report are excepted from disclosure under Regulation 12(5)(a), for the same reasons cited above. Question 8: Whether TfL assesses that the risk of harm to motorists using the tunnels has increased in light of the developments of the incident above, and whether the currently installed fire mitigation is sufficient in light of the above. We do not believe that the risk to motorists using the tunnel has increased. The initial finding of the lessons learned process is that all systems and processes worked as expected and the tunnel was successfully evacuated within the expected timescales. Question 9: Whether this incident has meant that TfL are now reviewing safety measures in any other road tunnels on its network TfL constantly looks for improvement in processes and safety measures. Following the fire a lessons learned process has been undertaken and recommendations will be fully investigated and implemented if required. Question 10: A brief outline of the fire mitigation systems in other similar road tunnels (such as the Rotherine or Limehouse tunnels), and whether there are similarities in the fire mitigation techniques used in these other tunnels, such that the incident in the Blackwall may have a likely impact on the assumed effectiveness of the mitigation in these other tunnels Our road tunnels vary in size and usage and therefore risks can be different – this in turn means our fire mitigation is also varied and meets the specific risks presented at each tunnel in line with current standards. Many of the systems and procedures are similar across our tunnel assets, meaning any lessons to be learnt in one area are transferable to others quite readily. However, details of the exact fire mitigation measures in place at other tunnels is being withheld under Regulation 12(5)(a), for the same reasons cited above. Question 11: Whether TfL is consulting with any other public body (such as the LFB, or DfT) as a result of the incident above. Yes. As part of our lessons learnt procedure we consult with stakeholders – in this particular case this was focused on consultation with our emergency service colleagues. Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed. Yours sincerely, David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
