Fire Risk Assessment - Drawings

[Bill J]

I know this has been debated till the cows come home, and I have watched with interest both sides.

When Assessing I almost always compile a single line sketch for myself, as often the Fire Certificate Drawings are not available until I get to site, and are the only copy, so clients would not be happy with my clumsy scrawling over them.

2 Questions....

Is there any way in which I can get the drawings before going to site? Electronically or Hard Copies would be Ok. Managing Agents rarely bother to have a copy away from site, and almost never send one to me. Most of the work I complete is in the London area.

What is going to happen to all of this (IMHO) Vital information now that Fire Certificates are no longer being issued, will these drawings become a lost resource.

Thanks in advance.

[Paul]

Bill,

I always try to get the drawings copied before I go to site.  Most good printing companies such as Prontoprint copy up to AO size.

I also have Autocad / PDF facility, therefore if an electronic version is available I ask for this.  I can print just over A3 so this can be useful.  Most large companies have facility for this inhouse.

Agree, the need for this to be captured in the FRA is essential as Fire Certs will go.  It is also useful if putting together a building emergency file that indicates key isolations / hazards / useful info etc.

Paul

[Bill J]

Try as I do, I rarely get to see the drawings before I arrive on site, I normally take a photograph of the Site copies, (if there are any), but thats no good for note taking.

I was wondering if there is a way to obtain the existing drawings held by local Fire Authority before going. Also as the majority of buildings have a Fire Cert at present, what is going to happen to the files, when the FA are no longer interested?

I hope some enterprising Individual keeps a copy......now theres a thought.

Bill

[AnthonyB]

Some brigades have CAD files of the plans and will send you everything on CD instead of printed copy (same price though!)

However this only works with certificates of recent vintage - some premises have quite old plans that will have been hand draughted & only exist in print.

I always try & get plans even thought the flor layouts are usually wrong as the core stairs & escapes usually are the same 7 it's a useful memory jogger to the building

[fred]

This will give some idea of the thinking behind the RRO with regard to plans.  These Q and A have been copied from the Minute so Evidence of one the RRO Committe reports .

Q91 Mr Brown: CFOA and the FBU have both stressed the importance of building plans in preparing risk assessments and thereby providing assistance to fire fighters should the need arise. The proposed Order contains no requirement for plans to be attached to risk assessments and no power for enforcing authorities to provide plans. Why does not the proposed Order require relevant persons to provide building plans alongside their risk assessments?

  Phil Hope: The purpose of the risk assessments is to target activity on those areas of buildings and properties most at risk. When the Fire Service does its inspections and looks at those buildings, the responsible person for those buildings has the responsibility to ensure that the building does conform to the fire safety regulations. Upon inspection, the authority does have the ability to check that that is in line with what is safe and to recommend changes if there are breaches. Ultimately, they do have the sanction of taking the responsible person to court if that does not work but we are pretty confident that that interaction between the fire and rescue authority and the owner of the building or the person responsible will create the improvements to ensure that the building is as safe as it needs to be.

  Mr Jack: The Order as drafted provides for the provision of reasonable information to the fire authority. If plans exist, CFOA and the FBU would expect to be able to see them and perhaps to mark the location of fire fighting equipment. The Order as drafted would allow them to do that. It allows for obtaining the documents and so forth and for reasonable information to be provided by the responsible person or any other person who appears to have that information within the premises concerned. What the Order would not allow for would be for a fire authority to demand perhaps an architect to be appointed to specially draw up plans just for this purpose. That would seem overly burdensome.

  Q92 Mr Brown: It makes sense that that information should be made available. Do you feel, if there was a statutory requirement to provide plans alongside risk assessments, there would be a substantial burden on the relevant persons?

  Phil Hope: Yes. We feel, through the consultation, we have made the right judgments.

[ian gough]

I've been asked for plans by two fire authorities. They can have them with pleasure - so long as they pay a proper fee. There was no further discussion!

[Carol]

Regulation 27 (c) of the RRO, Powers of Inspectors states that they may "require the production of...any records (including plans)
...which are required to be kept by virtue of any provision of this Order...
This was a fairly late addition, possibly after the Scrutiny Committees.

BS 5588 Part 12, Management of Fire Safety, also makes it clear that the 'fire safety manual' would need detailed plans showing all fire safety measures including the usual M o E, smoke control, provisions for disabled persons, etc. (Indeed, fully complying with this standard would effectively re-introduce certification to ALL premises via the back door)

My FRS will interpret this as allowing us to require plans in those premises where it would be almost impossible to demonstrate compliance with just a written FRA, for example shopping centres or entertainment complexes.

Ian, your FRA and the management of the relevant premises better be very good if you try that trick with me!

[ian gough]

Be nice to know what Fire Authority you represent.

[colin todd]

I agree with Ian. There is no requirement for plans with an FRA, and Mr Jack is right. It would double the costs of an FRA if plans were to be produced. A fire safety manual is a whole different animal from a FRA. The palns bring nothing to the table as far as recording the significant findings of an FRA are concerned.

[ian gough]

Just to clarify a little more: I do object to fire officers requesting plans when they already have plans on file (and before anyone suggests it - this is very rare indeed - unless they've thinned their files and dumped them!). And also when they are now making their plan tracers/drawers redundant!

Furthermore, to be requesting up to date plans fully marked with all fire equipment (really as per what would have been attempted for a fire cert) is not reasonable for the reasons Colin has stated - and mine ie cost.

Carol (not 'Tom' is it?) you would have difficulty enforcing your requirement I feel, as this is really about making life easy for inspecting officers - rather than ensuring the building's fire precautions and management were reasonable. Have you discussed this with your legal dept?

I knew this problem would arise, however, Chief Fire Officers have not.

The bottom line is that inspecting officers may well now have to spend more time on their inspections - and know what they are doing. Ask anyone who used to inspect buildings with the old s40 Factory Act or s29 OSRA certs!

[wee brian]

I am sure that Glynn Evans from the FBU raised this with the RRO scrutiny committee. They decided that plans would not be a requirement.

[carol]

We have rather hijacked the initial post but heh...

In auditing/checking/enforcing/inspecting the significant findings of a FRA I still hold that it would be next to impossible, in complex premises for the responsible person to do this without a plan.

I am aware of the school of thought that says FRS should confine themselves to auditing the methodology empolyed to carry out the FRA, (fine system published by Colin via the BSI), but this would not, in my opinion, enable the  FSO to fully confirm that the Order is being complied with. If this was the case then we should just require the responsible person to forward a bald statement listing the British Standards complied with and the Third Party Accreditation utilised.

I did not say that plans could be required as a matter of course, just that FRS have the power to require them 'where necessary'...to use that lovely term. 'Where necessary', because the Government cannot bring itself to define, will no doubt be decided in the Courts.

Maybe Andy Jack is being a good civil servant, but he told me that plans could, in certain circumstances, be required.

And Ian, as I am, pretty much the legal advisor, I look forward to letting some crusty Judge decide whether it is an intolerable burden on 'Bluewater' to include plans.

[colin todd]

We need to distinguish between various things, which are becoming muddled. There is the legislation itself, and there is the FRA, which is just one requirement of the legislation.  Then,there is compliance with the Regs and  there is inspection/enforcement to confirm compliance. Taking these in turn, there is no specific requirement for an FRA to include a plan. Let the crusty judge decide Carol, because if your fire authority push this (which it is unlikely your senior officers would allow you to do, lets not bull****) there are plenty of us who will be happy to convince him on the subject. It is also nonsense to say that a fire risk assessment cannot be done without a plan. Plans are becoming a luxury, which people carrying out fire risk assessments every day are not afforded the benefit of having available to them. Its time to stop living in the past and yearning for the old fire certs, most of which had drawings that did not reflect the premises as they are anyway. An FRA is not a fire cert. A fire safety manual is another animal entirely, and ideally would have a set of plans. It is NOT the FRA. The illustrious Mr Jack (who I was just musing to myself this morning, will no doubt put on his CV when he moves role about all the fine work he did in reshaping fire safety legislation, but will not mention the mess he has left behind for hands on practitioners) may have been referring to the emergency plan, and not the FRA. It, again, is a different animal and is a requirement of legislation.
Now we turn to enforcement of the legislation. Oh dear oh dear, I am reading more hankering back for the good old days of our old friend the FFO (fascist fire officer) doing a complete and detailed inspection of the building. Oooops, these days are no more. They went out with mains radios and wee men who checked your oil while they filled the car up with fuel. Nostalgic I know, isn't it, but there are very few aggressive and arrogant I/os left any more (OK Messey, I know you keep some that you just cant bear to get rid of), but they went out with the concept of it being his role to sort out the fire precautions in the premises. There will be no, or very few, thorough and detailed inspections. It will be sampling and lots of discussion with management, given the new realisation, which most FRSs are forward looking and signed up to, that inspection and enforcement does not involve looking in every nook and crannie. There will be a lot more coffee drunk by I/Os under the new regime, while they investigate whether management are complying.

[carol]

I shouldn't bite.

I believe I work for an enlightened FRS. I did not say a FRA was a fire certificate, I am always willing to work with the responsible person, (must more productive than forcing people to do things), I am also well aware of all the distinguishing features or FRA, emergency plans, fire safety manuals, etc. I also know what sampling is, the need for better targeting, risk based inspection policies, enforcement management models...have I forgotten anything? We also subscribe, where appropriate to the concept of advice and education rather than inspection and enforcement. Is that modern enough for you?

And please don't patronise me about my wee senior officers keeping me in check!

I think your outlook on fire safety, as practised, is coloured by the fact that you carry out FRA for organisations that have invited you in, are prepared, having paid you for professional advice, to carry out most of what you recommend.

The sort of places I normally visit/inspect still haven't heard of the WP Regs and fire safety is usually bordering on the 'section 10' state. The responsible person, when you can find them, has absolutely no intention of complying with legislation and will do everything to frustrate the FSO. Against this background we attempt to be business friendly, consider their financial woes, devise agreed action plans which are generally ignored and eventually after about two years find they have sold up and we start all over again. Bet you don't have these problems with the "a customer" [Admin Edit].

To return to the law. I have copied out bits of Reg 27.

"...to enter any premises which he has reason to believe it is necessary for him to enter for the purpose mentioned above and to inspect the whole or part of the premises

(c) to require the production of, or where the information is recorded in computerised form,
the furnishing of extracts from, any records (including plans)—
(i) which are required to be kept by virtue of any provision of this Order or regulations..."

I emphasise the 'whole or part of the premises' and regarding plans, we can of course interpret it in two ways...the production of 'something that doesn't already exist or the production of, with a flourish,  'something that does.'
Perhaps the definition of the words 'production of' mean something else north of the border!

Enforcement is easy when organisations are willing to comply.

You are wrong about the cups of tea, we used to get these when we inspected cosy office blocks!

[colin todd]

Nice balanced view of life.  If there are no plans its difficult to require an extract to be furnished.  And you know quite well certainly at present your senior officers would not allow yo to go the distance, so keep dreaming about a brave new world, because it is not going to happen. (And the customer [Admin Edit] do have a fire safety manual for every premises in the land.)