Recording a FRA

[kurnal]

Ken- to quote your post

"which, whilst not being prescriptive, does prove useful in letting you know what is expected by the enforcing authority".

There were as many different interpretations of the the old prescriptive guides as there were Fire Brigades, let alone formats for fire certificates, exemption certificates???  etc. Why should this be any different?
The new order and the old management regs are perfectly clear on what constitutes a suitable and sufficient risk assessment.  The guidance makes the process crystal clear. As long as the assessment meets the criteria and the significant findings are expressed what difference does the format make? And what is wrong with letting the court decide?  

Theres no prescribed format for a manual handling, coshh, working at heights, workplace, display screen regs etc etc risk assessment, the guidance sets out the matters to be considered and leaves the choice how it will be recorded to the assessor. Why should fire be any different?

[PhilB]

BSI produce some excellent documents for guidance; that, I believe, most readers of this forum will agree. I personally think their decision to climb into bed wth a well known fire consulltant was misguided, but that of course is my opinion only.

Prescriptive fire safety is a thing of the past as are prescriptive ways of achieving the goals. PAS79 may be adequate if used by competent assessors, there are however many other frameworks, templates, etc that are much better.

Unfortunately, the two most important terms with regards risk assessment are not defined in the RRFSO. i.e. suitable & sufficient & significant findings. PAS79 does not clarify the issues and Mr Todd has made it clear on previous posts that he interprets those terms differently to many others. It is apparent that some contibuters to this post are aware that ACOP to MHSWR provides excellent definitions that are soon to be watered down in the new guidance!

When RRFSO comes into force the poor old man on the street will have to comply with the new Order and the HASAW Act, both require significant findings to be recorded but that term is soon to be confused by the new guidance documents.

National guidance to assist consistency of enforcement would be helpfull but PAS79 is not the answer.

[Chris Houston]

not even worth answering that 1

That's your choice, but I think when you compared the BSi to a butchers shop, it would be myself that would have had a stronger case to suggest that a comment was not worth answering.

[Reg]

Am I being a bit dense here but isn't risk assessment about the outcomes - not the method by which they were arrived at.  If an enforcing authority uses PAS79 to provide a benchmark to validate a submission, it does not matter a jot what method the assessor used as long as the outcomes are similar and all the bases are covered.  Remember ERICPD and persons at particular risk and you've jusy about got it covered

By the same token, any fire risk assessment should be completed or audited by a competent person.  There is no fool proof method yet devised.  If there were there would be alot of consultants unable to pay for their daughter's school fees wouldn't there.  

From my experience most risk assessments are either "Suitable and Sufficient" or bl**dy rubbish with very few in any type of grey area.  Those that are bad are usually due to the competence of the assessor rather than the method used

Therefore gents no matter which side of the statutory fence you sit, let your outcomes do your talking.  At the end of the day the enforcing authority is only empowered to see the significant findings anyway.

[PhilB]

Reg, how do you define significant findings? some will have you believe they are defects only.

[Reg]

PhilB

Is that a leading question?!?!?

IMHO a significant finding includes anything that affects the suitability and sufficiency of a risk assessment, both deficiencies and positives.  For an auditor to fully appreciate the risk assessment, the building and the way they work together they must be able to have a holistic view of them.  

As with any audit process there must be a standard by which the risk assessment can be judged, be it a RRFSO guide ADB, 5588 or any other guide appropriate for the use.  That in itself can be a significant finding.  Any deviations form the "norm" for that particular use should be recorded particularly if a positive feature is being used as a compensating feature for a deficiency.  It is as important to get a handle on the thought processes as the risk assessment itself.  The only time that there may be a problem is where there is a clear deviation from the norm where either it has not been recorded or a rational for it not being an issue is given.

In my experience this usually occures with the simplistic tick box questionaire that purports to be a risk assessment being completed by, in good faith, an non practitioner of the dark arts.  Simplistic questions as "does the premises have a fire alarm yes or no are a nonsense without an understanding of what level of detection should be there.

[PhilB]

Why not stick with the guidance given in ACOP to MHSWR i.e The significant findings should include:

i)a record of the preventitive and protective measures in place to control the risks
ii)what further action, if any, needs to be taken to reduce risk sufficiently
iii)proof that a suitable and sufficient assessment has been made.

In many cases, employers will also need to record sufficient detail of the assessment itself, so they can demonstrate (i.e. to an inspector) that they have carried out a suitable and sufficient assessment.

Also many people think that only significant finding need to be recorded, that is not the case. Under existing and proposed fire safety law there is also a requirement to record measures taken for the effective planning, organsiation, control, monitoring and review of the preventitive & protective measures.

[Ken Taylor]

It's something like the ACoP and Guidance to the MHSW Regs plus an enforcement authority- backed example RA format that I am still hoping for.

In the H&S world, when companies offer their expensive RA computer based programs with complicated mathematical calculations you can refer to the HSE's '5 Steps to RA' format and assess risks as high, medium or low - thereby removing the shroud of mystery and magic and producing readily understood documentation. If management are going to act upon and maintain control measures, they need to understand what they are, how they operate and what they are there for.

In my book, defects should be remedied (with temporary risk controls until done) and it's essentially the remaining inherent risks of operating the undertaking that need to be adequately recorded and controlled.

[Reg]

Phil

Were we not saying the same thing different ways?

[PhilB]

Nearly Reg. I agree totally that tick box RA's are useless as they do not show due process, i.e conclusions with reasoning. What concerns me regarding the new guides is the array of wierd definitions for significant findings.

It would have been nice to have 'suitable & sufficient' & 'significant findings' defined in the new Order but they're not and this I think will lead to confusion.

[stevew]

I have been using the principle of PAS 79 now for some months. The original document is too restrictive however with some tweaking i am certain that it can work.

My  main criticism is that it has been ok if the number of points identified is limited.  Anything else then completing it becomes a headache.

[Reg]

I think that these definitions will become tested and refined over time as we become more familiar with and use the guides. Lets face it most of us have not seen anything but drafts although we are reassured that the final version should not be toooooo different!!!!!!  

As for causing headaches - is that not the reason why fire risk assessments should be completed by competent professional people?  If it were easy, anyone could do it.

[kurnal]

But Reg
The ODPM appear to be taking the line that  anybody can do it and that there will be  no additional burden on industry as a result of the RRO.
At least that seems  the hard sell approach given on the seminar circuit  and the senior officers and ABE people sitting on the panel and who know better dont appear to want to rock the  PR boat.
Well that was the impression I got.

[Reg]

And of course we believe everything that the government says don't we?
Sorry - was the impression you got: was that anyone could do it or no-one wants to rock the boat?

RRFSO
Safety assistance
18.—(1) The responsible person must appoint one or more competent persons to assist him in undertaking the preventive and protective measures.

[Tom Sutton]

As for causing headaches - is that not the reason why fire risk assessments should be completed by competent professional people?  If it were easy, anyone could do it.

I aree with you Reg but all the guidance that I have read follows Kurnal's understanding. "The ODPM appear to be taking the line that  anybody can do it and that there will be  no additional burden on industry as a result of the RRO."