"Better regulation scheme" consultation- fire safety

[kurnal]

Heres some more that bothers me.

The current duty to “have regard to” inspection plans should be amended so that local authorities are obliged to follow inspection plans drawn up by a Primary Authority

The current duty for local authorities to “give notice” to Primary Authorities when deviating from inspection plans should be amended so that local authorities are obliged to obtain consent in advance from the Primary Authority

Local authorities should be obliged to provide feedback on inspections to the Primary Authority so that inspection plans can be updated to accommodate current compliance activity by business and to ensure that local issues can be addressed.

Last time this was reviewed, Fire Safety legislation was omitted for the following reasons:

0.12 We feel that including the Fire Safety Order would be impractical as it conflicts with the principles of Integrated Risk Management Plans. The Government is concerned that Primary Authority involvement would be limited to giving extremely high level advice to any business that is partnered.

The nature of the risks presented by fire (i.e.that it can spread from one business to another) are extremely localised. Consequently, two identical branches of a multi-business site could be required to take two very different approaches to fire safety because one neighbours a business that stores flammable goods and the other does not. This position was strongly supported by the Chief Fire Officers Association and the majority of Fire and Rescue Services, including the two largest authorities, Manchester Fire and Rescue Authority and the London Fire and Emergency Planning Authority.

10.13 The Government also feels that including the Fire Safety Order in the scope of the scheme would require Fire and Rescue Authorities to divert resources from high risk premises to large multi-site businesses and retailers that are, in the main, considered to be low risk. Such an outcome would contradict one of the core principles of Hampton – that regulatory activity should be focused on those businesses that present highest risk.

What has changed since then?

[wee brian]

A General Election. A financial crisis. CFOA being a bit cack

[colin todd]

Fire and Rescue Authorities taking no heed to LAPS agreements, contrary to what CFOA tried to convince people would happen with such agreements?

[kurnal]

Yes but whats in it for the brigade and more to the point the local ratepayers?

[colin todd]

Nothing Kurnal. Sometimes you just need to be altrusitickzwy.  In our consultation response, we have offered to give evidence of why you need such schemes.

[kurnal]

Now you are talking my language Colin. I am absolutely in favour of being altruistic with other peoples money.

Assume I run a chain of cere homes lets call it Kurnals Cross Health care. I have 800 care homes and reach a lead authority paranership agreement with Toddshire fire and rescue service. How many person hours will it take to service this agreement if each care home warrants a 2 hour annual inspection and say 1 hour to follow up on those where things were not as they should be. 2400 person hours per year onm inspections and the same to provide admin and management of the partnership. At the ratepayers expense, the cost of two employees just to service a relationship with one partner.

How can this be cost effective and fair on ratepayers at a time when we are cutting jobs and making savings across the board?

[colin todd]

Big Al, I am lost.  If the homes need inspected they need inspected.  They will be inspected by their friendly local FRS. In Kurnalzwxskshire, the officers will tell them to upgrade all the doors to 60 minutes.  In Gadanskshire, they will tell them to fit smoke seals and strips to all the exiiting 15-20 min doors.  Of your 800 homes, Big Al, you will get 796 different recommendations, even though they are identical in design and management.

Then you will come to Toddshire F&RS, the PAS (I love writing those letters!).  They will say just a cotton-picking minute.  The party line for Kurnal Cross Healthcare, who we know very well and for whom there are agreed policies is that existing BS 459 doors are fine but there is a policy to upgrade them all with strips and seals over the next 24 months , and Big Al the proprietor is budgeting for it by cutting down imports of Polish vodka.

Now Al, you could have had a LAPS agreement already.  You might think it would have done the same thing. The problem is they are an arrogant bunch of officers in Kurnalzwxskshire.  The officer dealing with it is 150 years old and still yearns for the return of the F P Act. His boss has been in fire safety for 3 months as a punishment for allowing the King of Kurnalland's palace to burn down.  So the old geezer says to you, Big Al, a plague of locusts on your LAPS agreements, Al, they are not legally enforceable and so we pay no heed to them in Kurnalzwxskshire. Then what do you do, Al??

The Fire and rescue service have brought the PAS ( I wrote it again!) on themselves.

Please note the above story is purely fictitious to make a hypothetical point.  Any resembalnce to any party living or dead is purely coincidental.

[kurnal]

Seems to me that there would be much better ways to address inconsistencies in approach.
For example
Someone could write some guidance documents for fire doors, care homes etc like that old geezer who recently wrote a tome on flats. 

Then someone could offer training courses on fire risk assessment at a central fire training establishment or better still on a mobile basis. It would be easy to justify additional training from a cost/benefit/efficinecy  and dare I say better regulation standpoint. Regulators should be consistent and competent after all.

Then someone could introduce a register of competent fire safety auditors and it could be the expectation that all fire safety auditors employed by fire brigades  should aspire to the register and indeed a third party certification scheme for fire brigades- lets say when two such UKAS accredited schemes become available? 

I think PAS schemes are like driving nails into the plaster of the enforcement wall to cover up cracks. Cracks that can only be properly repaired by underpinning the foundations. And banging nails in will only make the cracks look worse whilst doing nothing to stop them spreading.

And that whilst the foundations  are not being supported very well at the moment, it would be too easy to listen to the predators who for their own self interest would love to see the wall fall down so they can build a new house of cards in its place.

[wee brian]

Yes that would work if the local enforcement bodies played nicely. one option is to put them on the maughty step.

Thats what this consultation is about (ish)

[colin todd]

Should I name them and shame them Wee B ? Can I please, pretty please. I offered the nice consultation people chapter and verse.