From my experience the majority of different employers and premises I see, they all prefered prescription. They admitted a moan about being told or even nagged at by the fire officer, but said at least they knew where they stood.
Most companies want to stay within the law as quickly and simply as possible and get on with their business - great when the FPO came in and gave them a list of theings to do - employer grumbles a bit, but then simply follows the list and can get on with the widget production.
But now - he's got to decide for himself what's right - but that takes more time and money and how does he know he's correct afterwards anyway - oh for the simple notice of steps!
A common conversation between consultant and management surveyor caused by non prescriptive risk based precautions is as follows:
MS - your FRA says we need to do x, what bit of law says we must
C - well x is required to ensure suitable and sufficient precautions against y as required by the FP(W)Regs
MS - but which bit of law actually says do x?
C - er, none as specifically as that, our assessment of risk says in z situation x is the best method to safeguard y
MS- so how do I tell my client to spend on x if the law doesn't say?
C - because by not doing x he won't have suitable and sufficient precautions against y as required by.....
MS - so which bit of law says do x again?
C - ARRGH!
Pre '99 it was much simpler:
C - you need x to comply with your fire certificate
MS - OK, must comply with the specific conditions in it, musn't we - consider it done
So most premises don't bother with an FRA at all (not helped by ignorance through a pitiful lack of publicity about the scheme including by FSOs). Those that do usually produce one of the following;
- a tick sheet pro-forma from a brigade, website, or similar
- a H&S risk assessment that includes a paragraph on "Fire Precautions"
- a fire extinguisher service certificate ("this company looked around the office and told us what we needed....." yes, rubbin gtheir hands all the way to the bank)
- a copy of a FP Act (or even OSRP Act) Fire certificate
Those few places with cracking good FRAs are the few that probably didn't need long letters from the FSO in the first place under the old system
The idea and principle is good, but it will fall apart in reality, especially in multi-occupancies (our main area of work) where there will be no co-ordination across the building and anarchy - it' already happening, especially with alarm systems.
But as is traditional no one will be bothered until there is another Woolworths/hendersons/Rose & Crown etc etc
The old system is by no means perfect, but isn't it strange that we haven't had any really major fire disasters since the FP Act had eventually settled into place (Valley Parade a special exception)? Will this continue for the next 20 yrs under the new system?
