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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Nearlybaldandgrey on May 15, 2006, 03:27:50 PM
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Has anyone looked at this fire risk assessment?
www.fpa-fireriskassessment.com
If so, would you accept it as suitable and sufficient under the workplace fire precautions legislation?
This could be of interest to you PhilB!!
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This "risk assessment" is nothing more than a checklist audit of existing arrangements- theres no element of risk evaluation in it as far as I can see. It doesn't meet the tests of the management regs - " suitable and sufficient".
But in its defence remember who it is aimed at- the SMEs. ( Small / medium employers) . Its going to be much better than what 60% of them have at the moment ( nothing if govt statistics are to be believed). Its supported by the FSB so this may help educate people who would be frightened of requesting advice from the brigade and not want to pay a consultant. And the guidance is so tedious that they may well fall asleep before getting halfway through and so decide to call me in anyway! Every silver lining has a cloud.
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If it is intended to be completed by someone without any real knowledge of fire safety then I think the answer is no. Take question 20 for example, 'Are the devices securing final exits capable of being opened immediately and easily without the use of a key?'. Someone without any knowledge of fire safety might look at this question and say that the sliding bolts at the top and bottom of a door and the thumb turn in the middle can all be opened immediately and without the use of a key, but you and I know that is not acceptable. The explanatory notes do not help. I have come across several of these and the example above was one that I found as part of a tenants FRA. I don't think the FPA are doing themselves any favours here.
Baldyman, what would you consider is necessary for an FRA to be considered 'suitable and sufficient'?
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It may be deemed suitable by some, I have seen many better examples. To be fair it is useful as a checklist and fine as long as the person using it knows the limit of their competence. It covers most but not all of the areas required by RRFSO.
I would question if printing off the resulting form constitutes all the significant findings that should be recorded. In my opinion this should include conclusions and reasoning as to the suitability of the building with regard time Vs tenability for the occupants.
Ignition sources, fuels and structural hazards should identify the type of fire likely to be encountered. The building should then be assessed to determine the adequacy of existing control measutres. i.e. can occupants escape safely before conditions become untenable. I dont think the checklist does this.
Having said that I was shown a risk assessment carried out on behalf of a well known establishment very very near to me that was quite frankly pathetic.
It was a very small document listing ignition sources, sources of fuel and comments like travel distances are deemed suitable!!!!!
We will have to wait until some of these inferior assessments are challenged by enforcing authorities in Court.
Interesting times ahead!
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I agree with PhilB its only a checklist and depending on the ability of the person using it will determine whether the FRA is good, poor or pathetic.
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As regards whether this FRA method results in sufficient FRAs, it surely depends on the combination of the nature of the risk and the competence of who has completed the form.
For instance: If I was handed this by the owner of a small corner grocery shop/Post Office employing 5 part-time workers with minimal risk, I'd be happy(ish)
But I couldn't say the same if the business were a light engineering workshop in a multi-occ building, employing the same number, with flammable liquids, gas cylinders, hot working etc etc
In my (humble) opinion, the quality of the FRA must be proportionate to the risks presented. The danger of this electronic format FRA is that the employer might well sit at his/her PC and knock it out in 10 minutes (as if it were a lifestyle quiz from a magazine) without the type of quality evaluation of the risks which may be required
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I wouldn't accept it at all.
There is no way of establishing how the answers have been arrived at, the thought process used to arrive at a conclusion.
It certainly doesn't seem to be appropriate for the people it is aimed at, small/medium businesses. The employers guide gives better information.
In answer to the question aimed at me, some of what I would expect to see is :- a record of the protective and preventative measures, the deficiencies identified by the risk assessment, a management plan to address the deficiencies aswell as an assessment of the means of escape using time/tenability.
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I am bemused by the responses here. It is quite obviously a risk assessment. What you as individuals think of it is beside the point. If an employer, or for the future a Responsible Person uses this format, then so be it. All a risk assessment is, is a journey from A to B. The important bits are whether the employer/Responsible person understands it, how they got to the decisions they made and what guidance they looked at to assess their respective premises. You can guage that by questioning the individual and the staff and having a wander around. A risk assessment is the means to an end, it is not the end. The structure becomes immaterial, providing all parties have undertaken the process with knowledge and/or guidance and in the end have an action plan to deal with any deficiencies they have noted. FSO's will not have the time to undertake a detailed look at either a Risk Assessment or the premises and it is unlikely that an employer/Responsible Person will ahve the time either. After all, they have a business to run, part of which is the risk assessment for fire.
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I don't think the FPA are doing themselves any favours here.
I couldn't agree more, I find this totally irresponsible of them to call this as a FRA.
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I am bemused by the responses here. It is quite obviously a risk assessment.
Jokar, it is not obviously a risk assessment. It is a series of questions. It is not a risk assessment until answers have been entered against the questions. Depending on what answers have been given and the thought processes behind it will determine if it constitutes a suitable and sufficient risk assessment. The questions are aimed at SME's, intended in my view to be answered by persons without any knowledge of fire safety. The accompanying notes are there to assist the person completing the assessment. If the accompanying notes are sufficient then why are we waiting so long for the guidance notes to accompany the RRO to be produced?
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The whole idea of these things is to put the wind up SMEs who will not be able to answer the questions and ,therefore, will need to employ a consultant.
clever
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Or they could seek advice from the Fire Authority!!
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Is that seek advice from the Fire Authority who tells them it is ok to leave a disabled person in a temporary refuge and wait for the fire service to rescue them or the fire authority who accepts an escape route through a commercial kitchen or would that be the fire authority who sanctions the removal of MCP's from Halls of Residence?
Sorry, just a few examples I have come across recently.
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No, its the Fire Authority with officers that will give them good advice.
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And charge them for it ? or suggest they call back when they are off duty for some consultancy
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That's a bit harsh Wee Brian.
I'll have you know I'm a professional and do not do any work outside my employment, after all, I'd hate to think I was taking work from you consultants!!!
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Anyway, is there any chance of getting back to the topic in hand rather than wasting my thread with banter?
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The question was, I believe, is this a suitable and sufficient risk assessment. The answer is, it is a suitable and sufficient risk assessment methodology. Whether a suitable and sufficient risk assessment for fire comes out of it, is a different question entirely. But that question is not for FRS personnel to answer, their role is too enforce (police), (the only legal enforcers in the UK are the Judiciary), the legislation. FRS personnel do not have to conduct a suitable and sufficient risk assessment they have to find out by questioning the employer, currently, or the Responsible Person after RR(FS)O is enacted, whether that person has conducted a suitable and sufficient risk assessment for fire. The recorded RA or FRA is a journey not the end of the journey. You can get from London to Manchester in a variety of ways, RA Methodology, but the outcome is being in Manchester. Whether the journey is suitable and sufficient is in the eyes of the journeymaker not anyone else. In this analogy, it is for the FRS person to find out how the journey was undertaken and perhaps advise a better one if possible taking all things into account.
Whether consultants like the methodology is a different matter entirely. Have an opinion by all means, but make sure yours is suitable and sufficient first, after all that is how you make your money. The same things apply to yourself about the journey, it is only your version, may not be the best or the worse, but do not humpy if someone with a different opinion questions it, that may be there job.
5 Step approach: Risk Assessment for Fire
1. Hazard = Fire
2. People at Risk = everyone
3. Evaluation = 5 causes of fire The Sun, Lightening. Friction, Electricity and Chemical Reaction. Therefore, we need some Control Measures which in the first instance may be behavioural for people, such as training, management and policies. But even then a fire could occur, so we need some detection and warning and then we may need to put it out. Eventually we may need to leave the premises, not all that often so may have to look at means of escape issues or compartmentation/separation.
4. Need to write it up, including any additional control meaures.
5. Review when necessary.
Now take the above apply it at home or better still eduacte and inform your partner/children in how to do it and see what they come up with. You may be surprised.
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Sorry Jokar but I disagree with most of that.
The Fire Authority should first be interested in the outcome- ie the level of residual risk that the responsible person has achieved through his risk assessment process. If it is as low as can reasonably achieved that is the end of the matter. The route taken to achieve this is irrelevant.
The FSO may wish to query risk assessment methodology as part of an investigation if something has gone wrong.
But during an inspection they dont have to be that helpful. All they need to do is to point out that the level of risk is unacceptably high naming the aspect they are dissatisfied with. And tell the RP to review their assessment.
Hazard may be fire, smoke or explosion, or slips trips and falls, crushing due to inadequate means of escape or lack of provision for slower moving people on staircases.
People at risk could be employees, visitors, patients, contractors, customers, people with little or no eyesight, people who use wheelchairs, very young people, old people, people whose first language is other than English, people who may not recognise European graphic symbols etc etc. All people who could be affected by fire should be considered and their special needs taken into account. It can never be as simple as everyone. Now where did that checklist cover issues like those?
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Agree Kurnal,
I think the FPA have let themselves down here. Even if we consider the guidance that supports PAS 79, we can see what must be considered in assessing the overall assessment of a premise / occupancy. I think as a minimum the PAS 79 should of been used. Not a big fan of it, but it does use a simple methodology that if used by a suitably qualified / experienced person would result in a suitable and sufficient assessment, as it does consider the elements you point out Kurnal.
In saying that, as Kurnal says, the end result of this has to be policed, as everyones perception of risk is different. Although I feel this is a double edged sword in itself.
P.
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Kurnal, your impression of what FRS's are to do after RR(FS)O may well be limited. The CFOA documentation is not about inspection as old school FPA people will know but more linked to the question set approach. The Policy is available on the CFOA website and the 20 page form that a FSO will have to complete will take longer than the allocated hours that the HO use now without any inspection process. Out of that they will not particularly have to form an impression just follow the flow charts and numerical values to get to whatever notice they are led to. All roads point to self compliance and the majority of small to medium businesses may never see an FSO again if there programmed Very High and High risk premises are large in terms of quantity and that is without consultation with the local authority and Licensing, if they still make representation under the 2003 Act of course.
As regards PAS 79, like all things, completion is easy, but knowledge can be a good or dangerous thing. I have seen a number of completed ones and they do not actually consider risk too much, just test the control measures already in place.
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I agree Jokar. I have seen many PAS79 samples poorly completed. If the commentry boxes are not used sufficiently it becomes a glorified tick box type assessment. As you are all probably aware I am not a great fan of PAS79 but if completed correctly by a competent assessor it does the job unlike the FPA checklist being discussed.
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Jokar,
The CFOA/ODPM/DCLG audit form is far from perfect but two thirds of it is assessing compliance with the RRO. It doesn't, in itself, take longer than an hour to fill in although a properly conducted audit may/should take longer than this. (The actual form should be pre-populated with the majority of details).
In any event it is much better than the true 'tick box' inspection that we used to carry out with a fire certificate plan!
The aim of the audit/enforcement activity is to leave the premises safer than it was before and the scoring system doesn't take away professional judgement but does provide a transparent and consistent method of assessing relative risk and taking appropriate enforcement action. Trials have shown that it produces similar actions from inspectors with a variety of backgrounds...surely this must be a good thing.
Returning to the suitable and sufficient theme, I agree it is tremendously hard to come up with a definition of S & S. Even the Courts have not tried that!! If the premises, in the judgement of the enforcing inspector, has fairly serious hazards and significant risks then the FRA is neither suitable or sufficient. Conversly, if the premises have no significant dangers then the FRA must, by default, be S & S.
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Jokar
Out of interest who do you think will be filling in most of the forms? Is it likely to be a qualified Fire Safety Officer or will the volume of the task require fire crews to compile the data? If I recall (I did get involved in the early stages of their development before I bailed out) much of the data to be gathered relates to operational risk, heritage risk, societal risk and environmental risk.
Quite appropriate for operational crews to gather the info. But will they have the training and experience in most brigades to make a realistic judgement on the S&S of the RPs risk assessment?
But assuming that brigades need this information to inform their IRMP and populate the risk management model, they need the data in a hurry and so will naturally start with a desk top exercise to identify high risk premises for the first batch of inspections. And in some brigades a desk top exercise based on looking at plans and past history may be as far as it will go?
I thought that allocated hours had died with many other great traditions!!! Or is the 1100 hours still alive and well? As long as you all wear caps and salute each other I can still sleep safe in my bed knowing the old standards are being upheld.
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As I said in my previous post, I am not a big fan of PAS 79 either but as an example of a methodology that I assume most on here are familiar with, it does work providing it is carried out by a suitably experienced person. Yes I agree, anyone can fill such forms in and the issue is then that it takes the form of a tick sheet, as with any predetermined proforma FRA's.
I too have seen very poorly completed assessments, not just of the PAS 79 method. This I feel is down to the individual, not the methodology, and that brings me to my point ( eventually). Any person who is carrying out a FRA and uses the FPA suggested method, then they should n't be in the business as Kurnal you say, it does not come close in assessing some key elements that are absolutely essential such as occupant characteristics.
I think we all agree the FPA method is poor and its a shame its been portrayed in this way. However equally important is the competency of the person carrying out the assessment itself, as a competent person would not use it.
P
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Kurnal, I would imagine, and I do not know, that FSO's will complete the form. For some Brigades, the process of training operational personnel in fire safety is a massive step forward, shouldn't they have been doing it since the seventies? Part of the process is a look backwards at previous history, although how that affects current management is a worry, and then a huge step forward into thinking and communicating with RP's and Consultants. On top of that professional judgement and no bullying tactics, oh and 1500 hours or so I am led to believe.
Val, the form relies in some sense on computers, handheld or laptops, and a system that allows this data to be inputted into a Brigade mainframe. This will not happen in some Brigades and will be a hand-draulic process, doubled, as the information will then need to be fed into the computer by someone. As much as I agree that the scoring is consistent, and by heavens do we need that, the process of inputting FSEC and IRMP data takes time and needs information on builings whereby RR(FS)O is about premises and never the twain shall met. I have to say I really like the Risk Calculator Matrix for re-inspections but getting some FSO's to divorce 1 score from the other will not be easy. Some even have difficulty with the stair calculations in B1.
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Having looked at many FRA templates some good, some crap and some not even as good as that, it is more important that the person who conducts the FRA is "competent". We all know the definition of that word. (Sufficient training and experience or knowledge or other qualities.)
Many responsible persons assume that they can fill in "the form" themselves, regardless of the size, construction, layout or occupancy.
It is obvious that many "practitioners" are not competent in that sense.
We have people calling themselves Fire Risk Consultants because they spent 30 years sitting in the back of a Fire Engine.
It is time that Regulation was brought in with third party accreditation. I am not neccessarily beating the IFE Risk Assessor Register drum but it is a start.
The last bit of the rant concerns Jokars' assertion that operational personnel will be auditing the FRA. I can see HMI being swamped with appeals.
The interpretation of the guidance is going to be crucial. I hope we are not going to go back to quoting paragraphs from ADB or Technical Standards. The Guidance for Residential Care Homes issued by the Scottish Executive gives The Technical Standards as benchmarks which is fair. Uniformed personnel will have to realize that the benchmark, if required, can be raised or lowered depending on circumstances. They are not set in stone. Even for new build. How many of you have seen buildings designed to DD9999?
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sorry jokar. I misread the first line.
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Jokar,
If the premises, in the judgement of the enforcing inspector, has fairly serious hazards and significant risks then the FRA is neither suitable or sufficient. Conversly, if the premises have no significant dangers then the FRA must, by default, be S & S.
Val I don't agree but you raise a good point. If you follow your reasoning an inspector of a brand new building completed in accordance with Building Regs would be told by the responsible person "I have carried out my assessment, there are no significant findings because there are no deficiencies."
CFOA make the same misleading point in their draft policy directive. They say the significant findings should be recorded together with the measures taken to deal with them. Suggesting as you do that significant findings are defects only! The draft guidance for RRFSO had poor definitions of significant findings that also said SFs were defects only.
There are plenty of premises out there that have no signifcant dangers but do not have suitable and sufficient risk assessments to ensure the premises remain safe.
To be suitable and sufficient the assessment should record the significant findings. Significant findings should include:
A record of the preventitive & protective measures
An accurate list of deficiencies together with an action plan for their remedy
Proof that a suitable & sufficient assessment has been made. i.e conclusions with reasoning.
In my opinion many RAs are not suitable and sufficient because there is no conclusion that the premises is safe in terms of time vs tenability for the occupants. This conclusion must be supported by sound reasoning.
A CHECKLIST AS RECOMMENDED BY FPA IS NOT SOUND REASONING!
Finally as I climb down from my soapbox can I remind everyone, and the FPA that both existing legislation and RRFSO also require that fire safety management arrangements are recorded. i.e. planning, orrganisation, control, moitoring and review.
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I think that there is one important point that you seem to have not mentioned. Currently under the WP Regs an employer or responsible person can only be guilty of 2 offences: Failure to comply with the WP Regs and failure to comply with an enforcement notice issues under the WP Regs. Therefore by conducting an assessment in what ever format, they have complied with the requirent to conduct a fire risk assesssment, what is then debatable is if the FRA is suitable and sufficient in the professional opinion of the auditor (FSO or otherwises)
To my knowledge there is no case law to determine what is suitable and suffiecient (fire safety or H&S) but is seems that the sutability of a FRA can be directed at the level of detail which would normally be proportionate to the risk whilst the sufficency is directed at the required competency of the assessor.
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Hi Sarahjayne
Welcome to the forum!
I reckon you have hit the nail on the head in the first paragraph, but I think that both suitable and sufficient relate to the level of detail proportionate to the risk and its the level of potential risk that will determine the required competency of the assessor
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Currently under the WP Regs an employer or responsible person can only be guilty of 2 offences: Failure to comply with the WP Regs and failure to comply with an enforcement notice issues under the WP Regs. Therefore by conducting an assessment in what ever format, they have complied with the requirent to conduct a fire risk assesssment, ....
To be precise the offence under regulation 11 is to fail to comply with the Workplace Fire Precautions Legislation(Not the WP Regs).
Reg 3.1 of Management Regs requires the assessment to be suitable & sufficient......so if the assessment is not in a suitable format they have not complied with the legislation.
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Having looked through the FPA site, I have to agree with those who feel it is more of a checklist than a risk assessment (RA). While checklists can form part of an acceptable RA, they cannot be the principle means of complying. Comparison with "Fire Safety - an employer's guide" quickly shows up the holes in the FPA document. While the FPA document will encourage some thought, I do not think it will provide sufficient thought for the higher-risk premises, as does the above guide. I understand that the RR(FS)O guides will be similar in standard to the above guide, so at present we need to follow the existing guidance?
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In response to PhilB, I am surprised being new to the forum and given the original question regarding suitable and sufficent that there seems to be a hint of "putting people correct" on minor issues, I was merely making my point and attempting to add contsructive points to the debate.
With reference to your comment the term WP Regs was just used for convienence and Regaulation 3 (1) 3rd paragraph links back to Part II of the FIRE PRECAUTIONS (WORKPLACE) REGULATIONS 1997 (AS AMENDED 1999)
I also still feel that by conducting the assessment they HAVE complied with the legislation, an enforcement notice would have to be served stating that the assessment conducted was not S or S. You would then have to argue or prove that it was not suitable or sufficient and at present this would ultimatly have be determined by a court of law.
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Sarajayne please don't take offence. It's not a question of putting people right on minor issues it is an important point of law.
You may have used the term WP Regs for convenience but many people miss the point that FRS enforce the Workplace Fire Precautions Legislation not the WP Regs on their own, see Reg 10.
By virtue of Reg. 3.1 of Management Regs the assessment must be suitable and sufficient....if it is not they have not complied with the law.
An enforcement notice would not have to be served, although that is one option. If the failure had placed one or more employees at risk a prosecution may also succeed under Reg.11.
Also by virtue of Reg.5.2 the arrangements for managing fire safety must also be recorded.
And I agree totally that ultimately a Court would need to decide what constitutes a suitable and sufficient assessment. Presumably they would refer to the Approved Code of Practice to MHHSW Regs for guidance as this does explain quite clearly what is required.
However many enforcers and practioners have not read this ACOP, perhaps they should.
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Phil B, Thank you for your reply, no offence taken, of course there would be several options to an enforcement notice the point I am making is that the suitability and sufficency of the assessment is open to opinon by whoever audits it as there are so many bench marks to use e.g PAS 79 - 9 step method , HSE 5 step approach, 7 step method etc, etc, etc
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We have people calling themselves Fire Risk Consultants because they spent 30 years sitting in the back of a Fire Engine.
I find that comment insulting.
I'm not a consultant but have spent 20+ years "in the back of a fire engine". I do not consider myself qualified by any stretch of the imagination, in fact with my time in Fire Safety, I'm only beginning to scratch the surface of a vast subject area.
I would also point out that (and no offence meant here) that there are consultants who have never seen the back of a fire engine, yet alone a fire.
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Baldyman.........absolutely correct......I too find novascot's remarks insulting.....and I agree there are far to many who call themselves consultants who have never seen a fire let alone sit in the back of a fire engine for 30 years....perhaps you would like to enlighten us all of your fire service experience novascot ?
Conqueror
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Baldyman, if you find that comment insulting then I make no appology for it.
There are too many retired Fire Officers who have never set foot in a Fire Safety office never mind learned the "black art". Fire Safety is an ongoing learning experience and to offer yourself as a consultant without any Fire Safety background is quite frankly....dangerouse. Remember the meaning of competent is:" a person with suitable training and experience or knowledge and other qualities."
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But Novascot why get wound up about ex firefighters putting their operational experience to good use? There are also many young graduates out there working as fire engineers who have never seen a fire other than on the news. They produce fire strategies and fiddle about arguing the toss about hot smoke layers and tenability, pinching a degree here and a metre there and justifying designs to approved inspectors with a 200 degree smoke layer at 2 metres above the floor. I would rather listen to most firefighters who may at least have scorched their tabs a time or two in a fire than someone whose only understanding of what its all about is from computer graphics.
But I must also point out there are some pretty excellent chappies out there too who do understand the real world.
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Kurnal,
I am not speaking through ignorance. I spent many years in all seats of a Fire Engine. I know what practical Firefighting is all about and the exoerience is invaluable. The point I am trying to make is that many people retire and see the Fire Risk Consultancy field as a way of supplimenting their pension without having the neccessary qualifications and experience.
I have seen FRA's completed which are embarrassing. If we had third party accreditation this would, hopefully, raise the standard.
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Everyone is entitled to an opinion and everyone is entilted to work in any field they wish to. The opinion may or may not be valid and they may not have sufficient experinece in their work. However, that is their inalienable right, we all try to do our best, whatever that is and wherever that takes us. The best deterent for will be under RR(FS)O. See PhilB's thread from today, if those out there get it wrong they could suffer the consequences.
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Novascot..... I'm astounded that you have managed to insult me and possibly other people on here within 4 posts.
You are obviously retired from the fire and rescue service whereas I'm still a serving member.
I do not consult, I offer advice and guidance while enforcing fire safety workplace legislation.
From your comments, I will assume that you are a consultant.
What is this "Black Art" you refer to?
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Before this turns into a great bun fight let me have my pennies worth.
I am a consultant and I have also spent time on a fire truck. My abilities when I assist a client come to the fore and the benefit of both knowledge gained from books and experience enhance the level of service I can provide. To be a consultant you not only need experience that is gained from the sharp end but you also need to have very good communication skills so that you can get your point across to your clients. No matter how much you know if you can't transmit that knowledge to your client orally then you will fail!
I know fire-fighters that are very good at there job but will never be consultants because they cannot communicate effectively. I know consultants who have degrees and work for large fire consultancy companies, again they lack communication skills so would never make it on there own. However, you will always get good and bad in any profession. The only way to be sure that the 'consultant" has the experience and knowledge is to become registered, i. e BRE, IFE, etc. Even this will not be fool proof but it is a start.
Without a doubt, my experience on a branch has given me a different perspective than perhaps a university graduate may have. I am now constantly immersed in legislation, books, technical manuals and the like but that is the nature of the beast.
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Baldyman,
what is your problem? I made a valid point regarding people setting themselves up as Fire Safety consultants without the knowledge or experience required. The point I was making was; you cannot gain the neccessary skills to be a Fire Safety Consultant if you spent your whole career as an operational firefighter.
How can you disagree with that? Or did you agree and you were just insulted?
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Playing devils advocate here,
Do you really need to be ex brigade to be a fire safety consultant. If we consider that Health and Safety professionals don't spend their lives before becoming qualified dealing with what they will later be providing advise about.
Do Fire Safety Consultants need to be attending fires for years before they can understand the principles of fire safety? Is it essential to be a fire fighter and to have spent many years dealing different incidents to then provide advice on protecting a building / lives etc. Much of which is learnt from text books??
Only asking the questions.
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Novascot......
If your point was about not being able to gain the experience to be a consultant by spending a career as an operational firefighter then you should have put that..... plain and simple.
I would disagree anyway, after all, an individual may take it upon themselves to gain qualification/accreditation outside their normal employment.
Never mind..... another 8 years and I can call myself a consultant....... can't wait!!
I (and this is my own opinion) feel that with my operational experiences, I have a better understanding of how a fire both spreads and affects a structure, not something that can be learnt looking at a computer screen studying a model. This means I can explain the subject better to those I deal with and in a way they understand.
I learn day to day from other officers and apply those new skills as I go and am not afraid to get stuck into the books.
Anyway, enough banter for now, lets get back to discussing the subject matter of my original post!!
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Baldyman
if you want things to be plain and simple, you have chosen the wrong career move. I haven't seen legislation for Fire Safety which is plain and simple. Yes let's get back to your original point. If you want to buy a consultancy in 8 years time give me a call.
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Novascot has been talking in general terms and I, as a serving fire safety officer with an operational role, agree with him. You have insisted on taking it personally - you may be wonderful but I can assure you that some aren't.
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Cheers for that Big A
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What is this "Black Art" you refer to?
It was term used by Opps to describe Fire Safety but we retaliated and referred to them as knuckle draggers (lowest form of primate) how I miss that old banter :D
I agree with you Novascot we had this augment 30 years ago, lost then and would lose again. (Our main protagonist was dear old Colin T) Having an operational background is of some use but there is a great deal of study required and the application of that accrued knowledge to become a competent Fire Safety Officer or Fire Safety Consultant.
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Thanks for that explanation.
I feel someone should re-read my posts as things seem to have been misinterpreted, but hey ho, all part of the fun of debate!!
For the record, I do not consider myself wonderful ....... I know how big a learning curve I'm on and happily meet that challenge head on, especially at the present time. I certainly don't think I've made a wrong career move either ......... I see it as personal development. In fact, following some training today, I've even managed to identify some personal training needs so it isn't all bad.
Not sure I'll be in the market to buy a consultancy in 8 years, but thanks for the offer!!! :-)
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What do you all think of the sample formats provided for recording the significant findings in the new guides?
Whilst accepting that the record is of the outcome of the RA rather than the process I think it rather pulls the rug from under the feet of those wanting more comprehensive reports showing matters taken into account in evaluating the risk as per the old management regs approach.
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I assume you mean the new Example form (in Appendix A2) which is, I think, an improvement on the simple list on page 21 of 'Fire Safety - an employer's guide'.
I do have a minor problem where the new Guides keep saying 'Evaluate ...'. This to me implies a mathamatical process, such as I was taught some years ago, about estimating the overall hazard from both the potential for harm/damage from a risk and the probability of it happening. But in the new Guides it seems to be a rather more subjective process possibly lacking a firm basis?
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That's just honesty.
Nobody actually uses real numbers for Fire Risk Assessments.
Probablistic assessments are specialist stuff.
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Theres a place for both qualitiative assessments based on judgement and quantative assessmants, eg based on probalistic analysis in fire safety and risk assessments.
The probabalistic and quantitative techniques will come into fire engineering, calculating likely fire growth rates and tenability limits etc.
But those who use wholly probabalistic techniques ( and some do) then fall down when they try to extend their technical calculations with those issues relating to human characteristics. They then start to thow in guestimates such as "its 50% likely that a person discovering a fire will not do the right thing". ( actual example used on a risk assessment course I attended). These figures are usually so great compared to the technical data that it throws the whole calculation into disrepute.
Cant beat a qualitative subjective judgement for human factors.
But the new example forms dont appear to have a facility for me to point out that for example shortcomings in passive measures are compensated by strengths elsewhere.
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Regarding kurnal's comment re facility to point out things, could you either use the back of the form with a "See overleaf" in the appropriate part of part 3, or add a suitable section called "Comments" below Step 3 - take away the A2 heading and the form will have room to expand to include this new section.
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After reading kurnal's post ref human factors, do you include that as part of the risk assessment?
I know that occupancy behaviour should be anticipated in terms of likely reaction, and this is something I encourage responsible persons to include, but I don't actually find many that do.
Would this be classed as a significant finding?
Views appreciated!!
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Yes Baldyman I believe they are significant findings. However the new guides have a different definition of SFs to the one that we know & love from the ACOP to MHSW Regs. The glaring difference is that the definition in the new guide does not include....."proof that a suitable and sufficient assessment has been made".
So according to the new guide there is no need to show conclusions with reasoning as to why the building is safe. How people are going to evacuate before conditions become untenable. You just list what you have and what actions you are going to take.
Let's face it...we all knew it was coming. I have been ranting on about this in this forum for ages and it has now come to pass!
Poor old blokey on the street will have to carry out a fire risk assessment to comply with the fire safety order. To assist him a guide has been produced that defines significant findings.
He also has to do a risk assessment to comply with the relevant statutory provisions of the HASAW Act. There is an Approved Code of Practise to assist him, but the definition of SFs differs!
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phil
I have watched your comments about the new FSO and coold not agree more the acop version of suitable and sufficient was laid down and this should have been continued however I believe that it can work with a robust enforcement regime does any one know hoe the Fire authorities are prepairing for this? I would be interested to hear about the metro brigades who have struggled with self compliance in the past.
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Enforcement will be mostly applied during inspections and audits of premises, dependant on the outcome of course!
Personally I think it will be difficult for most small /medium businesses to comply as they have no idea about the fire safety order, yet alone fire risk assessments!
I sincerly hope that the goverment advrtise the fact that businesses will need to comply and that there is a change in legislation coming.
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He also has to do a risk assessment to comply with the relevant statutory provisions of the HASAW Act. There is an Approved Code of Practise to assist him, but the definition of SFs differs!
Phil I am puzzled by this statement. Surely in terms of article 47 the management regs and its ACOP are not relevant in respect of a fire risk assessment?
"Article 47
Disapplication of the Health and Safety at Work etc. Act 1974 in relation to general fire
precautions
47.—(1) Subject to paragraph (2), the Health and Safety at Work etc. Act 1974(b) and any
regulations made under that Act shall not apply to premises to which this Order applies, in so far
as that Act or any regulations made under it relate to any matter in relation to which requirements
are or could be imposed by or under this Order.
(2) Paragraph (1) does not apply—
(a) where the enforcing authority is also the enforcing authority within the meaning of the
Health and Safety at Work etc Act 1974(c);
(b) in relation to the Control of Major Accident Hazards Regulations 1999(d)."
If I am right my risk assessments will be much shorter in future.
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Kurnal HASAW Act is only disapplied by article 47 if those matters can be dealt with using the fire safety order. The fire safety order only deals with general fire precautions.
Other safety matters, for example process risks, trips & fall etc. will need to be addressed using the relevant statutory provisions of the HASAW Act.
My point is that there are now two different definitions for significant findings. In my opinion the definition in the new guides is inferior to that given in the ACOP. This was pointed out during the consultation period. Originally they defined SFs as defects only!
They finally agreed that the definition was defective and agreed to amend it, this was one of the reasons for the delay. However rather than use the same definition as the ACOP they have opted for a new definition. That new definition is, in my opinion, poor.
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But Phil the requirement to carry out a fire risk assessment is made under the fire safety order. So the mnagement Regs ACOP does not apply to the fire risk assessment, which only has to be suitable and sufficient in terms of the more limited Fire Safety Order definition.
Surely for the purposes of the fire risk assessment the ACOP L21 has no relevance? I agree that it still applies to all those other aspects of the workplace.
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however I believe that it can work with a robust enforcement regime does any one know hoe the Fire authorities are prepairing for this? I would be interested to hear about the metro brigades who have struggled with self compliance in the past.
By civilianising fire safety departments, slashing wages and going softly softly - it seems that inspections could be increasingly be post fire reading some prosecution cases in the fire press, except for a few high risk premises
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Surely for the purposes of the fire risk assessment the ACOP L21 has no relevance? I agree that it still applies to all those other aspects of the workplace.
It has no relevance I agree, but it will surely lead to confusion. Why have one definition for significant finding for a risk assessment carried out under the fire safety order and another for HASAW Act.
A cynical person might think that those responsible don't really understand the risk assessment process.
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Baldyman, 2 things 1. The Government have been actively publicising the coming of the RR(FS)O throughout this year and will continue to do so. FRS's will also have a part to play and will have to give information to the public over the coming months. Ignorance of the law is no excuse and thats where RISKassessments views about FRS's enforcement regimes come in. All FRS's will adopt the CFOA model which includes the HSE's Enforcement Mangement Model and the collation of IRMP data. These forms are quite detailed and will involve a lot of interaction with the RP and FSO's will have to make professional judgements on the quality of a FRA perhaps without an inspection, after all the FRS role is enforcment.
The 2nd point was about Significant findings. All things are significant findngs and whether there is a control measure or not. The preventative bits, policy and procedures is one answer and the protective bits another. For example with your human factors, dependent on the level of movement for people you may have a FRA that says increase travel distance or decrease travel distance. The first way could add a further control measure of preventative procedure or policy and the second additioanl passive fire safety. The guides are exactly that, not words of stone for people to blindly follow, but for consideration, dependent on the circumstances in any one particular set of circumstances.
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I have come into this debate a bit late, however I am particulary interested in the definition of 'suitable and sufficient' from a legal point of view. When carrying out a risk assessment identifying the problems is relatively easy for an competent risk assessor, as suitable control measures (ericpd) can be put forward with suitable time scales, however if you find for example that all the escape routes are clear and unobstructed, and you put a yes in a box, how do you prove this in a court of law?
Proving the NO's I would say is the easy bit as they have been identified, and you have backed this up with control measures. But if someone did get injured or hurt in a fire, how do you back up your YES answer, does this mean that anything with a YES answer requires a qualifying paragraph?
And lastly, where does this leave the majority of 'tick box' type FRA's used by a large number of assessors?
Will the judge be able to run rings around the poor old risk assessor as he has no way of proving that a YES answer means anything at all?
P.S, I have never had to sit in a court of law and be grilled by a judge, but I know of people who have and according to them it is not a pleasant expierience!
I would be interested in your feedback on this, as without a doubt, someone somewhere is going to have is FRA closely scruntinised.
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Thats's my point Gary. The ACOP gives excellent definitions of suitable & sufficent and significant findings. The explanation of both those terms in that code of practice includes the requirement that conclusions should be supported by sound reasoning.
Therefore a tick box type risk assessment cannot adequately record the significant findings or be suitable and sufficient. However the guides for the RRFSO do not support that view. This will lead to confusion for enforcers and those who have to comply.
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Its only confusing if you choose to use the ACOP when trying to comply with the Fire Safety Order.
But tha's hardly suprising - its the wrong guide!
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So all this means that under the Fire Safety Order the record of our risk assessment and its outcome can be far inferior to any other type of risk assessment and less thorough than those we produced under the WP regulations. although the process of carrying out the assessment will be similar.
Was this what the Government intended do you think?
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Its only confusing if you choose to use the ACOP when trying to comply with the Fire Safety Order.
But tha's hardly suprising - its the wrong guide!
Until October the ACOP is the guide that anyone who is required to carry out a fire risk assessment should refer to. Without wishing to teach my grandmother or Wee Brian to suck eggs at present the principle fire safety legislation is the Workplace Fire Precautions Legislation. That consists of Part 2 of the workplace Regs and certain regulations of MHSW Regs, including Reg 3.1. How therefore can you say the ACOP is the wrong guide!!!!!!!
Some of us have been delivering fire risk assessment training to FSOs, consultants and others for many years. There are two definitions that anyone invlolved in this field must understand; suitable & sufficient and significant findings. In the past I have directed delegates to the ACOP for those definitions.......................I thank Wee Brian for pointing out my error.
Perhaps we should continue to refer to the ACOP until October and then begin using inferior definitions poorly explained in the new guides????? Where is my dear friend Mr Toddd.... he must know the answer!
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Perhaps we should continue to refer to the ACOP until October and then begin using inferior definitions poorly explained in the new guides?????
Maybe you should, possible a little tongue in cheek and then move heaven and earth to have the new guides changed if there is a consensus then you should succeed.
I am sure Val who appears to be very informed on the DCLG could give us a suitable contact.
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wee brian wrote:That's just honesty.
Nobody actually uses real numbers for Fire Risk Assessments.
Probablistic assessments are specialist stuff.
Agreed Brian. Probabalistic assessments are "specialist stuff" and was/is taught at The FSC and Brigades did not support the courses. Did they think their FSO's were not specialist enough? Have we dumbed down the concept of Fire Risk Assessments? Prob Assessments are still used for business continuity/interuption assessments. The background knowledge is invaluable in "ordinary" FRA's.
Bring back The Method
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I think you may find HSE moving rather than DCLG. HSE are getting worried, quite rightly in my view, that they have created a sea of paperwork rather than a safe workplace.
The new guides are promoting a straightforward apporach to FRA - thats a good thing.
I see no point in using probablistic methods except in very unusual circumstances. There are some methodologies that pretend to offer some numerical analyisis but most of them are just smoke and mirrors.
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Fire Risk Assessment is all about estimating the CHANCE of fire (or the spread of fire) or in other words the PROBABILITY of fire (or the spread of fire) in given circumstances. You don't even have to be a mathematician to work out the % chance of something happening. This is what assessments are about so smoke and mirriors it may be to some but it is fundamental to assessing risk.
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Its only simple if you use probability instead of words, for example in a qualitiative judgement I might say that a mobile phone charger in use sitting underneath a whole insulating heap of paper constitutes a high fire risk, and I might say there is a high probability that it will overheat and I might give a figure- say 75% liklihood of it causing a fire.
But thats the smoke and mirrors bit- the 75% is no better than the words "very likely". It may deceive people in thinking my assessmet is more technical than the gut feeling it really is.
It only becomes a quantitative analysis if I get technical and start calculating heat outputs, the rate of heat growth, insulation factors of paper, ignition temperature of all the constituents, duration unattended, proximity and perhaps add in the average failure rate of these things in ambient conditions.
But even then it falls apart if its got the wrong fuse or someone has done an unauthorised repair. So in my opinion quantitative assessments are ideal for designing new buildings or installations but in the real world of life risk and existing building I will stick with my gut feeling and qualitative judgement.
And after all my gut is more than ample for the purpose.
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kurnal,
if you quantify your gut feeling with a figure, your outcome will be the same but making it understandable to Joe Public. He will understand the % likelihood of something happening but he won't understand your gut feeling no matter how big it is. haha
Numbers replace phrases like: Tolerable, not tolerable, satisfactory, substantial etc. etc.
You can thenrelate those figures to a graph which will show the likelihood of a fire starting and if it starts the likelihood of it staying in the space/room of origin then the likey path of the fire. At a glance you can see the predictions and know where the problems lie in the premises/building.
But hey, gut feelings are good too.
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Ah. Theres method in your madness.
To be honest I slept rather well through those sessions and dreamed of more inspiring curves.
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well kurnal I hope I wasn't your tutor when you fell asleep. No, you wouldn't fall asleep in my lecture room. haha. I also hope those curves were not of the insect variety.
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It's all very well producing a risk assessment full of likelyhoods, percentages and nice graphs, but does the person you produce it for fully understand it and more importantly, will they be able to give an explanation and demonstrate understanding when subjected to an audit by an inspecting officer?
I've come across this situation many times when the responsible person produces a risk assessment but hasn't got a clue on the process used yet alone undestands the outcomes.
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Hi Baldyman,
this system has been tried , tested and proved by both practitioners and end users. Some FRS have been using it for years and it is very easy to understand. I know some Brigades who will be using this way of thinking for auditing purpses.
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I understand the process, but the responsible persons I audit don't.
I've seen some really good assessments provided by consultants but when probing the responsible preson, it's obvious they don't have an understanding of the document or the process.
I personally think it is important that they understand, afer all, it's them I am firing questions at. The only other option is to have the person who did the risk assessment at the premises when the audit is carried out, which is not always possible when you're a busy person!
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Gary, I can assure you that one is never seated when grilled by a Judge (or more likely a lawyer). However, looking at some of these posts we may be in for some fun times - seated in the Public Galleries!
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Baldyman,
I assume you are a serving Fire Safety Officer which confuses me when you say that you "fire questions at them".
What happened to the enforcement concordat? When you audit a Fire Risk Assessment what questions do you have to fire at people? Surely it is the assesasment you are auditing not the occupiers.
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Novascot,
The answer to your question is yes I am!
I should have worded my post better ....... by fire questions I meant that I have to ask questions of the responsible person. These are to clarify information and test their knowledge and understanding of the fire risk assessment.
True, I'm auditing the fire risk assessment, but also the management of the premises. The fire risk assessment is only effective if supported by effective management who actually understand the process and reasoning.
With reference to the Enforcement Concordat, I work well within the gudelines and mention it as part of my brief to the responsible person.
Hope this is clearer.
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Novascot,
Although 'fire questions at..' is not the expression I would have used, what other method would you suggest for testing that 'the responsible' person has carried out the risk assessment or, at least, understands it, and that the 'relevant persons' have received any instruction?
I also have had a number of inspections/audits where a fairly dusty looking (but beautifully produced) risk assessment is brought down from the shelf where it has been sitting ever since it was delivered by the consultant (next to the very dusty fire certificate that never gets looked at either).
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Big A
Point taken. It was a poor choice of expression. We tried to get away from the jackbooted FSO some years ago with a gentler approach and "firing questions" did not seem to be appropriate. Of course the responsible person must show an understanding of the assessment and it is his/her or the consultants duty to make sure that happens.
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Glad we all agree there!!!
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As the RRO looms a bit closer and all the sad ones like me are reading it in a bit more detail I submit the following point for debate ...
RRO Art 18(1) states that the Responsible Person must appoint a competent person "to assist him in undertaking the preventive and protective measures"
The definition of "preventive and protective measures" in Article 2 is "measures which have been identified by the responsible person in consequence of a risk assessment"
This clearly implies that the "preventive and protective measures" have been identified by risk assessment before the competent person is appointed.
Perhaps "undertaking" is just a poor choice of word ........
I guess consultants will hope so anyway
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Dont presume there is only one kind of Competent person. The term appears three times in the order covering different activities and diferent competencies.
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if anybody is still interested in fire risk assessment topic...
i have found quite a good source of info.
it is www.simply-docs.co.uk
they have a lot of fire and safety documents, especially different fire risk assessment forms and checklists online . It might be worth having a look at what they have.A lot of the documents can be downloaded for free.
However you need to register.
good luck