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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: norfolknchance on September 19, 2006, 06:32:14 AM
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The provision of alterations notices gives us a mechanism to maintain a higher level of survillience on risk and monitor accordingly. Are brigades intending to apply a retrospective approach to the application of alterations notice i.e a list of premises that already have got poor performance history or traditional generic risk will receive notification as from the 1st Oct. OR are bgd's going to apply the alterations notices to premises post 1st October on a basis of as and when they find a problem or risk that needs monitoring ?
My opinion is that if we are mindful of premises that have performed poorly in the recent past or a premise that owns a particular risk process then the notice should be used now. The old section 8 required notification to the FA, but most of these premises were relatively low risk, therefore some of the generic (percieved risk groups under certification e.g offices required a higher level of control but didnt always need it)
any views ?
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Further, this depends on how any continuity is monitored when the regs change. And, how any outstanding issues are dealt with. I think FRS' could be negligent if 'slates' are wiped clean and a start again aproach is taken.
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London's approach to this is that Alteration notices will be used in two areas:
All sub surface rail stations and
Mainly on buildings with complicated FS engineered solutions which require a greater degree of management control and competence.
Such notices will be issued by principle LFB management (not local team managers) when requested. I anticipate that many will be issued to exisiting buildings
There are no plans to use Alteration notices to correct/monitor poorly performing RPs. That is a matter for enforcement and prosecution
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I think London have got it right Messy. It worries me that the draft guidance and many brigades seem to be missing the point. I think the intention was to impose the old section 8 conditions only on premises that deserved that degree of control and I would have thought that premises with an engineered solution such as shopping malls would be the category of premises that these notices should be used for.
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I am not sure I agree with the concept of alterations notices at all. Whilst accepting London's approach of keeping tight control over the issue and accepting that sub surface is a discrete group of premises over which control should be kept, what is the purpose of alterations notices??
If it is to maintain some on-going 'control' over premises then it drives a coach and horses through the responsible person principle...in effect a back-door fire certificate.
Is it is because the premises are inherently dangerous...then we should be addressing that via other enforcement.
Is it because they are complex...therefore the premises management need to be pretty competent.
We should already be maintaining some control over any or all of these premises by identiying them within our risk based inpection programme and breathing down their neck on regular basis. (Those FRS with any inspectors left).
If we issue an alterations notice to the responsible person and they leave...do we have to re-issue it? Do they have to tell us? What level of detail or change do they have to inform us about? Notification prior to alteration under the FP Act didn't work very well. If the RP tells us about every change we will spend all our time looking at sofas being moved or light fittings relocated!
Bite the bullet and call the government's bluff...these were only included as a political sop to the FP Act anoraks. The real dangerous premises out there are the ones we don't know about...not the multi-million organisations who should be forced to employ/have someone who is competent to manage their premises safely.
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I totally agree with Val the sub surface premises is a fair cop because they did not have the WPR so they need a beding in time but as for that alterations notices are a joke. They only have to inform thr FRS if in thier opinion a SIGNIFICANT increase in risk if they dont think that they dont have to tell anyone.
Also with no requirement for plans how will the Officer know if they made changes anyway when they go back to inspect.
Val is right it is issued to the RP not the building so each change of RP means new notices issued.
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quote=val]....If we issue an alterations notice to the responsible person and they leave...do we have to re-issue it? Do they have to tell us? What level of detail or change do they have to inform us about? quote]
Again London's view appears to be that alterations notices -if/when issued- will need to be written carefully to ensure that a change of management(RP) is considered 'Significant' and thereby triggers a notification.
Again London will not be issuing these willy-nilly (thats why an AC -I think- has to sign them) as it is accepted that it flies in the face of devolving responsibility to the RP
I doubt whether there will be more than 40 -50 across London (excluding LUL premises of course)
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Mainly on buildings with complicated FS engineered solutions which require a greater degree of management control and competence.
Will the likes of a large FSE school/college/library/university building be likely to be in this category?
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An Alterations Notice is not what you seem to think. It is a notice that is issued when a serious risk, not defined in the legislation, is noted. That si it. The second bit is that if the RP believes that the already serious risk has increased significantly then the RP should inform the enforcing authority. They can be asked to send a copy of their RA, but which one, the one they already have or the new one to take account of the alterations that significantly increase the already serious risk. Leave well alone, it is a minefiled, plus it may well cost FRS money as they are appealable, if that is a correct term.
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What does this mean then? Is the risk of fire in any building not a serious risk?
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Are we talking property damage or life safety? The FSEC categories to be used by FRS in their new regime under RR(FS)O are built on stats provided about fires. The risk categorisation indicates that the probability of a fire in many premises would indicate that fire is not a serious risk and therefore not all, if ever very many premises will ever be issued with an Alterations Notice. My question is will LUL appeal against the Notice for every sub surface station, that could cost the LFB lots of money. Proving that a premises has a serious risk when that term is not defined antwhere could be difficult. The RP accepting that an already serious risk has increased significantly, again a term not defined, is in the mind of that RP. With a inspection programme that concentrates on high risks, the FRS service may have a mind to issue Notices to certain premises and then just continually inspect these. Afetr all, the legislation is built on self regulation.
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I believe that this is an attempt to cover the gap between Building Regulations alterations (which can only deal with structures) and increasing fire risks (which may be nothing to do with the structure and therefore not caught by Building Regs) - but at the same time relaxing the old s8 FP Act requirement which was often ignored anyway.
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Another part of the minefieid is that the Enforcers Guide offers no help when you discover changes to a premises which has an Alterations Notice on it - a slap on the wrist will just deem them useless, and an instant prosecution will often be too heavy handed ? I think we should leave them well alone. Val hit the nail on head about FPA anoraks.
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FPA anoraks.
Fire Precautions Act, not the Fire Protection Association.
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We reckon they're a 'safety net' - intended to address premises where fire safety is particularly dependent upon high levels of management vigilence, or where the fire engineering is particularly complex. Sub-surface railway stations are a good example (and by the way, R.I. Skassessment, they have been subject to the Workplace reg's since the post -97 amendment). An additional factor is that they're not subject to the Building Reg's, as LU is a Statutory Undertaking, so this 'leg' of fire safety legislation is missing. Also applies to other transport infrastructure managers - another reason for the delay in the Transport Guide?
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My question is will LUL appeal against the Notice for every sub surface station, that could cost the LFB lots of money. Proving that a premises has a serious risk when that term is not defined antwhere could be difficult. .
With the LU system, virtually every item on our FS shopping list is non applicable, in the sense that the features of the underground system are unique: Travel distances measured in miles. Compartments measured in scores of miles. Occupancies in tens of thousands.
Until the late 1980s LU's management of FS was appalling. Limited AFD and FFE. Poor training and responsibilities. Poor maintenance and hardly any proper procedures.
I attended a fire involving a wooden sleeper in a tunnel which, despite sparks being drawn into the the tunnel every time a train passed overhead, LU wanted to allow it to burn all day so that engineers would have less timber to remove overnight. (Yes a controlled{?} burning in an occupied public transit tunnel!). I later attended the Oxford Circus 20PF (just prior to Kings X) which was caused by smokers material discarded into uncontrolled builders storage on the platform, in which we nearly lost a number of FFs and LU staff.
Since Kings X, LU management have evolved - indeed were forced to evolve- and have introduced £millions of pounds of changes. The most significant is their management regimes.
I understand that it is the management structures/systems which are likely to be involved in any Alteration notices, rather than the actual infrastructure, as it's the quality of that management that is key to maintaining the systems within this difficult environment.
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Messy...your arguments are compelling but, despite the political shennigans which retained the Sub surface regs (wasn't an RMT sponsored MP on the Scrutiny Committee?), why should LU management be treated any differently to every other in the country. If their management structure/control is poor then give them a kicking with an enforcement notice under the fire safety order. (Sorry... that should have been provide advice and encouragement).
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Val
I am not saying that LU management are poor now.
My understanding of the LFB's approach to Alteration notices is to apply them sparingly and only when an applied engineered solution is so critical to the safety of those inside the 'building' that extreme management systems are needed, and those systems therefore should be more closely monitored by the enforcing authority that the norm.
The issuing of an Alteration notice is not therefore, necessarily an indication of poor management. Instead it is a recognition that the risks are excessively high and the control of those risks is critically reliant on complex FS engineering and systems.
My understanding is that LU are not unhappy at the prospect of an Alt notice as after all, they get a lifetime (partial) fire safety consultancy free of charge.
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My understanding of other FRs approaches are to issue the alterations notices to their high risk premises, have that as there inspection programme proactively, react to fires in premises and have a smaller fire safety workforce to meet the perceived need. How will that work in London?
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London's approach to this is that Alteration notices will be used in two areas:
All sub surface rail stations and
Mainly on buildings with complicated FS engineered solutions which require a greater degree of management control and competence.
Such notices will be issued by principle LFB management (not local team managers) when requested. I anticipate that many will be issued to exisiting buildings
There are no plans to use Alteration notices to correct/monitor poorly performing RPs. That is a matter for enforcement and prosecution
Can I just confirm with this one, am I correct in saying that as messy has said above, all london underground stations have been issued with an alterations notice under the RRFSO? and that they also still have to comply with the FP sub surface railway stn regs 89 as well?
I am sure I have read somewhere that these regs will eventually be withdrawn, is this correct?
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The Sub Surface Railway Regulations 1989 are currently still in force, but it has always been the intention to replace them, therefore there has already been some pre-consultation on how this is done. I understand that a 3 month consultation document will be released, possibly in June this year, detailing the proposed changes.
Until the Regs are repealed or replaced, Fire authorities are advised to approach sub-surface stations using the RRO first, and only to fall back to the 1989 regs when absolutely neccessary.
Merseyside FRS has issued Alterations Notices to its 5 stations. This was not done to extend or prolong any control over the premises, but to formalise the arrangements that are already in place requiring notification and consultation prior to any material changes. The fact that by defenition, sub-surface stations can be considered to be premises where there is a 'fire engineered' approach to extended travel distances, was also a significant factor.
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Ricardo, that is not correct only sub surface stations have alterations notices issued to them as meesy has stated. Some Ug stations are above ground and are not subject to AN. Section 12 regs are still in force and are used to be prescriptive in sub surface stations.