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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: PhilB on October 24, 2007, 10:16:04 AM
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Let me raise an old issue. I have always advocated the use of plans when recording the findings of a risk assessment as I can see no other effective way of recording the required information.
Plans are not always necessary in small simple premises but in larger complex premises how can you record the 'General Fire Precautions' without a plan?.......I am of course assuming that you agree that the general fire precautions are significant findings.
The 71 Act never made plans compulsory but most FRS chose to use them to record the information that a fire certificate had to contain.
I am therefore please to note that the RR(FS)O Guidance Note No.1 tends to support my view.
See paragraph ........"61. The suitability of a risk assessment and its recording is partly reliant on its ease of understanding. In some buildings, particularly in complex buildings, the risk assessment may need to incorporate plans showing the general fire precautions arrangements - this may be where it is not possible to identify matters clearly in the narrative of the risk assessment. There is nothing in the Order which would directly compel a responsible person to create new plans. However, for some complex buildings a risk assessment will not be suitable and sufficient or properly recorded without additional plans.
Maybe a bit of a concern to Mr Todddd and his followers. Time to revise the PAS?????
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I agree.
Prose or (heaven forbid) tick box forms make it difficult to indicate effective MoE, travel distances, lines of FR, locations of safety equipment, etc, etc. A picture (and plan) speaks a thousand words and are often easier to understand...
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Nah.
Plans have their limitations too. You can use them to indicate the locations of hazards and to illustrate the nature and extent of risk control measures but they do nothing for evaluation of risk.
They rely on the person interpreting the arrangements and comparing them to the benchmark guidance.
Using a plan theres no way you can say that because of X it is OK to do Y. Thats where the SWOT analysis comes in. It doesnt refer to that in PAS 79 either.
Hey Phil have you seen paras 31 and 32 which link the definition of "suitable and sufficient" to the traditional definition in the Management Regs and is not slightly different definition as we previously thought.
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Hey Phil have you seen paras 31 and 32 which link the definition of "suitable and sufficient" to the traditional definition in the Management Regs and is not slightly different definition as we previously thought.
Yes Kurnal....good news...the ACOP states that there should be reasoning to support any conclusions......something lacking from the guidance issued so far for the Fire Safety Order.
The ACOP has been there for years and in my opinion is an excellent guide as it clearly explains the meaning of suitable & sufficient and significant findings.
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Nah.
Plans have their limitations too. You can use them to indicate the locations of hazards and to illustrate the nature and extent of risk control measures but they do nothing for evaluation of risk.
I totally agree Kurnal they do nothing for the evaluation but they do enable the general fire precautions to be adequately recorded.
Without a plan how else do you record, MOE, means for securing MOE, FFE, means for giving warning etc????
These are surely significant finding that should be recorded and the plan is the best way to record them...in my opinion.
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I use a (fairly long) tick box section of the report which sets out expectation statements and then a tick indicates compliance or if not fully compliant a statement as to why and what needs to be done if anything ( all significant findings) , and if necessary summarised and prioritised in the action plan
Heres an example of one of the items from the checklist
The external fire escape was protected by having all windows within the specified distance (horizontal distance 1.8 metres, vertical distance above 1.8 metres and vertical distance below 9 metres) fitted with fire resistant glazing to a half hour standard in frames fixed shut.
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I'm not suggesting for one iota of a second that your risk assessemnt is not suitable or sufficient but I can see how an enforcer...following Guidance Note No.1 may consider it so if there is no plan.
From the Order itself.....preventive & protective measures are measures that have been identified in a RA as the general fire precautions you need to take.
Therefore general fire precautions are significant findings.......and article 4 clearly defines what general fire precautions are...including MOE, FFE, AFD etc.....now if you can record all that without a plan ok...but often a plan is the only effective way.
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I think enforcers like plans because it makes it easy for them to enforce using traditional code hugging methods and it is only of benefit if everything is simple and correct.
You cannot tell from the plan that we have justified an increased travel distance due to ceiling height or utilised borrowed light in lieu of escpe lighting luminaires?
That smoke detection has taken account of downstands or that fire doors are upgrades to the English Heritage standard?
Or that there is a risk of fire spread in undivided cavities in between floors
Or fire resisting partitions only extend to the false ceiling etc etc.
Thats why in the old days the plan was used to rubber stamp the fire certificate standard once the benchmark had been achieved and maintenance was the only concern. Before we got to that stage the plans were marked up in red and the key information was in the schedule of requirements (in text ).
I tend only to use plans in simpler buildings or if someone else draws it. In former certificated buildings I have even stopped using fire certificate plans in my risk assessments because they are so often a work of fiction and confuse the issue.
Reading one of my tomes may be a pain for the enforcer but I hope all the info is there.
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Does a plan not help to capture the layout of a building on the day the risk assessment is carried out. When a risk assessment is complete goodness knows what the owner/occupier would do the the layout. At least it would give you protection from liability if any layout changes compromised the means of escape for example.
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The RP can use and do what they want to secure the FRA, plans prose, tick box, anything thing that assists. The FRA is theirs and if plans help them to manage fire safety on a daily basis thats good for me. However, if someone can point out to me how a plan defines the risk from the hazard that would be more than helpful. A full audit of the premises in prose and then a calculation of the risk surely is a risk assessment and that can only be done in prose and with a matrix.
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The point is though Joker that the enforcers guidance note seems to suggest that risk assessments without plans may not be suitable and sufficient. I would tend to agree. Don't forget that this is guidance issued by the Secretary of State and enforcers must take note of it.
Having said that the latest animal farm guide apparently "has been approved by Ministers and has official status." and that shows horses in inner rooms, cows in bedrooms on upper floors and horses in dead end corridors........I give up do what you want the world has gone mad!!!!!
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Perhaps the author has been to the FSC in the past with the "animals"
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The next argument will be what exactly constitutes a "complex" building.
Is it the expectation that if suitable plans do not exist (no mention of scale cf licensing act) the RP will have to draw them to meet the requirement of the fire safety order? The guidance clearly states not. So any plans will do???
On animals- all the cows were of the same ethnic mix.I would have expected a few brown cows, a few black and white ones as well as the white ones. Plus a footnote to point out the need to provide adequate ventilation to avoid a build up of explosive methane. Otherwise Phils canary may perish.
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Can you tell me how you incorporate the drawing or CAD time into the fees for the FRA AND remain competitive? It is not an issue if you have good up to date plans provided by the client but if not the cost and time implications can be more that the FRA itself. I would like to include plans in all my FRA's but cost does not allow it.
I still feel you can do a suitable and sufficent FRA without plans and there is no required to do so under the RRFSO. Phil, would an FRA ever be rejected by an efforcing authority solely the non production of plans. Would a F and RS issue a notice as such? Maybe ONLY if they could not understand the FRA without plans.
I also feel that if it were a requirement to have plans then some FSO's may return to the plan hugging days and we may as well produce fire certs again. Just my opinions..........................
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It's not just the risk assessor and IO who need to view AND understand the risk assessment, but the RP and possibly maintenance guy, managers, etc who may not be as conversant with fire risk assessments; a quality plan with all necessary written words can be easier to understand than a full ream of text. If the risk assessment is only read and used by the author and IO it's of no value is it?
There were no cows in the bedrooms! They were in the udder rooms...
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Right, we'll have neigh mare jokes about horses in bedrooms etc. How long will it be before we receive a complaint from goats who have been discriminated against in repect of MOE?
Are they not entitled to the same basis animal rights when they stay in a hotel or guesthouse?
How could the authors of the guide forget to include themselves?
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I still feel you can do a suitable and sufficent FRA without plans and there is no required to do so under the RRFSO.
There is however a requirement to record the prescribed information = significant findings = preventive & protective measures = general fire precautions. i.e. MOE, means for securing MOE, FFE. fire alarm etc etc.
Now if you can record that without a plan fine....if you cant, in my opinion a plan should be provided. That is why I have never been a fan of PAS79.
Would IOs serve a notice if there were no plans....in truth most people out there wouldn't know a suitable & sufficient FRA if it kicked them up the backside......
Hopefully though, now that the ACOP to MHSW Regs is referred to in the enforcers guidance notes...that may change.
Anyway....A Horse, a duck and a cow walk into this hotel and the barman says........sorry being silly again!!!
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Anyway....A Horse, a duck and a cow walk into this hotel and the barman says
" What will it be boys?"
The horse, a white one, says "We'll have whisky".
The barman asks what type of whisky.
The white horse replies "What do you have?.
The barman says "We have Bells, Stewarts, Jamesons and we even have one named after you"
The horse says "What, you mean to say you have a whisky called Eric?
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Article 9 para 62 from the RRO(FS) order guidance note 1-
'The suitability of a risk assessment and its recording is partly reliant on its ease of understanding. In some buildings, particularly in complex buildings, the risk assessment may need to incorporate plans showing the general fire precautions arrangements- this may be where it is not possible to identify matters clearly in the narrative of the risk assessment. There is nothing in the order which would directly compel a responsible person to create new plans. However, for some complex buildings a risk assessment will not be suitable and sufficient or properly recorded without additional plans. Similar considerations will apply in respect of article 11(1) and other articles which require information or arrangements to be recorded. Enforcing authorities should seek practical solutions with the responsible person where such plans are not adequate.'
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Hold on, that says building. There is no definition of a building in the RR(FS)O they are all premises, so what happens next? And as stated above what does complex mean?
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Good points jokar, also the clue is in the title "guidance note" for use by FSO's when auditing in my understanding. How is the responsible person expected to know that an interpretation of the Order COULD mean the production of plans when producing their FRA?
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How is the responsible person expected to know that an interpretation of the Order COULD mean the production of plans when producing their FRA?
Because they should either be competent themselves or if not appoint someone who is competent to assist them.
A competent person should be able to read the Order and understand what needs to be recorded i.e. the precribed information.
If you can record the prescribed info without a plan ok...but as the guidance note correctly points out...sometimes a plan will be required.
Unfortunately some people don't appear to undertsand what needs to be recorded.
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Thanks for the comments Phil, but no one has still addressed my point regarding the cost of producing plans and as stated previously I would prefer to include them but cost and time on site does not allow it, unless the client is prepared to pay for the additional service.
I know an argument could be that hand drawn plans would be suitable but when you are producing professional looking FRA's (in both content format) I am reluctant to include sub standard plans.
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Agreed. And in practical terms I was asked in May to carry out a risk assessment in a large factory. As I pointed out they had made unauthorised and dodgy alterations without building regs approval and this needed to be addressed. they appointed an architect to prepare plans for the risk assessment and to support a retrospective building regs application. Its now nearly 6 months later and the plans are still not finalised so the risk assessment has not yet been completed. It becomes another expensive and delaying obstacle to progress. Still I guess soon a year will have passed and the BCO will then have lost any control.
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I know its a problem Kurnal but you mentioned on another post that you wouldn't wear slippers because your fireboots were too tight...well something like that.
The fact that plans may cost money or take time is not really relevant....if they are needed they should be provided.
Having said that I don't see why the plans have to be to scale or drawn by an architect........as long as they record the general fire precautions.
Please, please note I am not saying that plans are alaways necessary...but if they are provide them...and the client will have to pay.
...and yes I know the client may go to a cheaper consultant who provided a tick box, or a checklist...without a plan that is supposed to record the necessary info.
The answer to that is competent auditors and effective enforcement ....a problem I know.
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Hold on, that says building. There is no definition of a building in the RR(FS)O they are all premises, so what happens next?
Don't see your point there Jokar. Under the 71 Act we used to "require" plans of buildings yet building was not defined.
The meaning of the word building shouldn't be too difficult to fathom out by even the most incompetent assessor!
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It is always good to be in agreement with PhilB. Leaving aside the RP, competent assessor and cost, the trick is to educate enforcers when a plan may be reasonably required and not give them carte blanche to ask for plans in every single storey industrial unit.
Perhaps I do not get out enough but I would think that many premises/buildings already have some form of plans.
I believe that the term 'complex' was deliberately chosen because of its potential for wide interpretation. At both ends of the complexity spectrum it should be obvious. What happens in the middle is what keeps us all coming back to this site.
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Fire precautions Act 1971 - Circ. No.5
DEFINITION OF "BUILDING"
The definition of "building" has been interpreted variously but the courts for purposes of other legislation
and is therefore subject to some uncertainty. However, to ensure uniformity in the administration of the
Act, it is considered desirable that a building should generally be regarded as extending from its lowest
level to roof-top and that the horizontal limits should be regarded as set by party/separating walls
through which there is no internal communication with neighbouring buildings. Doors provided in party
walls solely as fire exits should not be regarded as a means of internal communication. Nor is it
considered that the effect of imperforate floors extending over the whole area of a building is to create
two (or more) separate buildings, notwithstanding that there may be no internal means of communication
between the parts.
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Hey, that's not one of the circulars that was removed from use when the brave new world appeared is it?
Simple really buildings can be built, altered or extended. FRA are on premises and perhaps the 2 will never meet.
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A couple of questions:
Where in the Fire Safety Order does it state that a fire risk assessment has to be recorded?
Article 9(6) states that the prescribed information must be recorded, that information being
9(7) The significant findings; and
persons especially at risk.
Is Article 27 (Powers of Inspectors) not clear on the issue of plans?
27(c) "to require the production of, or where the information is recorded in computerised form, the furnishing of extracts from, any records (including plans)-
(ii) which it is necessary for him to see for the purposes of an examination or inspection under this article,
and to take copies of, or of any entry in, the records"
I agree that plans will in no way show the level of risk in the building, that will be done through your FRA, but as an enforcing officer I will need to make a judgement regarding the suitability of your General Fire Precautions in relation to the level of risk within your premises, and in all but the simplest premises a plan would greatly assist me in doing that.
If there is no plan in place, it will undoubtedly take me longer to look at the General Fire Precautions, especially when the person dealing with me isn't the, or a, person appointed to provide safety assistance (as is normally the case). This will mean that my audit will take longer, and therefore I will carry out less audits over a period of time, and will therefore have less effect on driving down the risk of fire in the community that I serve.
I can't remember where I got it from (may have been the original training session covering the Fire Safety Order in Lancs or GMC Brigades) but I understood it to be the case that if the enforcing authority required plans then they would pay for them (although I might have imagined that bit).
Many apologies if my observations are wrong, feel free to tear my contribution to shreds.
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You are correct John FSO only requires the prescribed information to be recorded which includes the significant findings.
Now look at the definition of preventive & protective measures......these are the measures that have been identified in a risk assessment as the 'General Fire Precautions' you need to take....with me so far???.......
Now from that surely you must agree that general fire precautions must be significant findings and therefore they should be recorded.
Have a look at what general fire precautions include...article 4...and then you will see why I say that sometimes it is best to use a plan.
On the question of recording the assessment itself the Approved Code of Practice to the MHSW Regs 1999 says ..."in many cases, employers will also need to record sufficient detail of the assessment itself, so that they can demonstrate that they have carried out a suitable & sufficient assessment."
On your final point of the fire authority paying for plans if they require them...don't know where you got that from but the point is the fire authority are not requiring plans.......it is the complexity of the building that makes plans necessary if the assessment is to be suitable and sufficient.
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I absolutely agree with you Phil. The Fire Risk Assessment Guides give a clear definition of what the significant findings should include (Page 31 of the Offices and Shops Guide).
My thinking is, that unless there is a plan to refer to, (the Guide states "It can be helpful to include a simple line drawing to illustrate your fire precautions. This can also help you check your precautions as part of your ongoing review" (Page 31 again) then the Responsible Person would need to produce something akin to the old Means of Escape Schedule that used to be produced under the Factories Act.
Good reference to the Management Regs ACOP, I hadn't picked that one up (one for me to store away)
As I said in my previous posting, I may have dreamt the bit about the enforcing authority paying for the plans, or it could have been a Principal Officer trying to placate my tirade of annoying questions.
So not much objection to your comments from me.
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Good answer Phil.
This will mean that my audit will take longer, and therefore I will carry out less audits over a period of time, and will therefore have less effect on driving down the risk of fire in the community that I serve.
This is a tetchy point and I recognise that your audit covers more than compliance, but your role in this respect is surely to enforce the order- to make sure that the RP is driving down the risk, yours is a policing role in fact? This may have an indirect effect on driving down risk just like the threat of punishment can deter some of us from committing offences. (whereas the rest of us just dont fancy sheep).
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This is a tetchy point and I recognise that your audit covers more than compliance, but your role in this respect is surely to enforce the order- to make sure that the RP is driving down the risk, yours is a policing role in fact? This may have an indirect effect on driving down risk just like the threat of punishment can deter some of us from committing offences. (whereas the rest of us just dont fancy sheep).
Absolutely right kurnal,
I am there to enforce the requirements of the Fire Safety Order on behalf of the enforcing authority, in my case the Fire Authority.
As we generate our audits from:
A risk based inspection programne (RBIP) which ensures that we target the highest potential risk (high life risks etc);
Complaints (e.g. someone phones to complain about blocked fire exits);
After a fire (a failure will have occurred somewhere for a fire to start); and
As a sampling measure (to look at certain groups of premises that may have grabbed our attention for some reason)
this ensures that we are driving down risk and targetting the highest potential risks at the same time.
I approach every audit looking to ensure that the requirements of the Fire Safety Order are being complied with. If the premises I am looking at are complying, I will say 'well done, keep up the good work', plus it gives me an opportunity to offer best practice advice if they require or want it.
If they aren't complying, then I have the full range of enforcement powers at my disposal, including prosecution in the worst cases.
I think that ultimately it is everybodys interest that we all work together to drive down the risk from fire and its often devistating effects.
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Kurnal
Matlock? Sheep?
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Baaa humbug. Its all lies. Anyway you cant get wellies with wide enough legs anymore.
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Let me raise an old issue.
Check out one of the old threads at http://www.fire.org.uk/punbb/upload/viewtopic.php?id=664 if you would like to hear some pearls of wisdom from Toddy on this subject and I am sure you will not like this one Phil
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Like it??? I love it...a blast from the past.
That was the debate where Toddy and his pals were telling me that plans were not necessary and the ACOP to the MHSW Regs was not relevant when dealing with fire risk assessments.
Now thanks to Guidance Note No.1 they have been proved wrong on both counts!!!
Seriously though I am pleased that the ACOP is now referred to in the Guidance note. Anyone involved in carrying out or auditing fire risk assessments should read this document as it clearly explains the meaning of suitable & sufficient and signifcant findings.
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Now thanks to Guidance Note No.1 they have been proved wrong on both counts!!!
It is only a ''Guidance Note'' nothing more, just guidance for the ill informed :)
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I made this point earlier in the debate. To sum up in the overall scheme of things when IO's are doing their best just to get PR's to do any sort of FRA is the fact that they contain plans or not going to affect their judgement as to if it is suitable and sufficent. I do take Phil B's line on the recording of the significant findings POSSIBLY not being able to be recorded without a plan but still feel it unlikely that an IO or a senior officer would reject a FRA soley on the basis of no plans.
And I still go back to the cost element to the RP's
Purpose
3. The purpose of this guidance document is to provide enforcing authorities with advice
about enforcement of the duties contained within the Order. It should be consulted
together with the Order itself, not instead of it. The guidance is founded upon
current knowledge and legal advice. It must however be accepted that any defi nitive
interpretation of the Order will be made by the courts.
FSO Guidance Note No 1 (Page 6)
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Now thanks to Guidance Note No.1 they have been proved wrong on both counts!!!
It is only a ''Guidance Note'' nothing more, just guidance for the ill informed :)
Yes but this guidance has been issued by the secretary of state no less......
...and.......to quote the Statute.....26.(2) In performing the duty imposed by paragraph (1), the enforcing authority must have regard to such guidance as the Secretary of State may give it.
....and you know how IOs love to guide hug!!!!!
Let's hope that the guidance is treated as guidance....some times a plan will be necessary....many times it will not.........let common sense prevail.
But I do sense that some of you consultants out there may becoming twitchy because your chosen method doesn't include plans............I bet old Toddddy is shaking in his fur lined slippers as we debate this one.
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Where can I get hold of FSO Guidance Note No 1?
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Where can I get hold of FSO Guidance Note No 1?
http://www.communities.gov.uk/documents/fire/pdf/guidance1enforcement2005
See paragraphs 32 & 62
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Thanks Phil I found 1 and 2 after I post my question. I haven't found time to read it yet but I will shortly.
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I have never done a fire risk assessment or likely too but I am trying to understand the procedures for my own benefit. One area confuses me is the recording of information.
Let’s take Means of Escape, an assessor conducts a FRA and finds the MOE satisfactory, does he record it simply as MOE - satisfactory or if he finds deficiencies, highlights them, prioritises them and how they can be rectified, this is what PAS 79 appears to recommend.
This would mean a third party (RP) reading the report would not know what the MOE scheme was, he would only know it was satisfactory at the time of the assessment. Furthermore he would not know which doors need to be available, which doors need to be FR, which areas need to be covered with AFD or emergency lighting, etc. So how does he maintain the MOE standard to a satisfactory level?
If the assessor choose the PAS 79 recommendations then I would imagine plans are not necessary in most cases. If he decides to extend his report to providing a MOE schedule then a written schedule and plans would be required for the larger and more complex premises.
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Let’s take Means of Escape, an assessor conducts a FRA and finds the MOE satisfactory, does he record it simply as MOE - satisfactory or if he finds deficiencies, highlights them, prioritises them and how they can be rectified, this is what PAS 79 appears to recommend.
This would mean a third party (RP) reading the report would not know what the MOE scheme was, he would only know it was satisfactory at the time of the assessment. Furthermore he would not know which doors need to be available, which doors need to be FR, which areas need to be covered with AFD or emergency lighting, etc. So how does he maintain the MOE standard to a satisfactory level?
If the assessor choose the PAS 79 recommendations then I would imagine plans are not necessary in most cases. If he decides to extend his report to providing a MOE schedule then a written schedule and plans would be required for the larger and more complex premises.
Exactly my point TW stating MOE satisfacory is not recording what means of escape there is.....PAS79 can read like that if not completed with enough info......I have seen many assessments carried out using PAS79 that are far from suitable & sufficient.
Hence the reason Toddy didn't like it when I said plans would sometimes be necessary. By far the easiest way to record the general fire precautions in all but very simple premises is with a plan....it doesn't take that long and often plans are already available.
The ACOP to MHSW Regs explains that significant findings should include:
1) A record of the preventive & protective measures;
2) An action plan for remedial work
3) Proof that a suitable and suffcient assessment has been made.
A tcked box stating MOE is satisfactory is not a record of 1) and is not proof i.e. no reasoning to support the conclusion.
A simple template with a plan does record all the prescribed info.
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bring back the plan drawings as with the old 1971 Act then?
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no Jasper, that clearly is not what I'm saying! If you can RECORD the info in some other way fine, but many assessments I have come across do not record the precribed info.
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PhilB, Whilst I understand where you are coming from and the Article quite claerly states that you have the record the prescribed information at some stage an assessment of the risks posed by the fire hazards has to be doen and that can not be doen on a plan. part of a package maybe but it is not thwe whole thing.
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I never said it was the whole thing!! My simple point is how in a complex building do you record the prescribed info without a plan???
Some people are doing so without a plan, some are just ignoring the fact that the info needs recording because it would make life too complcated.
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no Jasper, that clearly is not what I'm saying! If you can RECORD the info in some other way fine, but many assessments I have come across do not record the precribed info.
I was only having you on mate!
Personally I go down the descriptive route i.e. what risks etc are present and the existing control measures. However for large complex buildings (don't ask me how I define large and complex) I do go for plan drawings with salient information on them.
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Phil, I agree absolutely.
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Those opposed to the use of plans how do you record, in the larger complicated premises, the significant findings as defined by the ACOP to MHSW Regs especially items (1) and (3)? I cannot see how the pro-forma in PAS 79 achieves this also what are the reasons, is it cost or is there other reasons.
Jasper your submission accepted.
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Why would I use an ACOP to the MHSW regs to establish compliance with the FSO?
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Why would I use an ACOP to the MHSW regs to establish compliance with the FSO?
beacuse the Secretary of State told you to in Guidance Note No.1 Enforcement.
"32.Enforcing authorities should note that the requirement for suitability and suffi ciency
is one and the same requirement as that in health and safety law. Detailed advice has
been produced by the Health and Safety Commission as part of the Approved Code of
Practice and Guidance to accompany the Management of Health and Safety at Work
Regulations 1999 (ISBN 0-7176-2488-9). That guidance is equally applicable to the
suitability and sufficiency of risk assessments under the Order."
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PhilB/Wee Brian
Ignoring the guidance only angle, answer me this please.
Joe Public RP buys the Guidance relevant to his establishment, how on earth would he know about the new Guidance Notes? Without you chaps and of course Aunty Lin/Val on FNF to educate/entertain me I would not have known about the shifting of the goalposts on S & S and its the main part of my job.
Surely this should have come out as an Amendment to the Order? It is after all a very crucial point
Does this mean a Mk3 for colin to write?
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PhilB/Wee Brian
Ignoring the guidance only angle, answer me this please.
Joe Public RP buys the Guidance relevant to his establishment, how on earth would he know about the new Guidance Notes? Without you chaps and of course Aunty Lin/Val on FNF to educate/entertain me I would not have known about the shifting of the goalposts on S & S and its the main part of my job.
Surely this should have come out as an Amendment to the Order? It is after all a very crucial point
Does this mean a Mk3 for colin to write?
Davo
I raised this point many moons ago when the Guides were being written. The ACOP to the MHSW Regs was there and explained what suitable & sufficient meant and what significant findings should include.
I thought it a tad daft that the new guides didn't use the same definitions. They did not listen at first but then they agreed to amend the guides and the definition of significant findings(one of the reasons for the delay in publishing them). But they still chose to use terms slightly different to the ACOP.
The biggest difference in my opinion was the lack of a need to show proof that a suitable & sufficient assessment had been made i.e. reasoning to support your conclusions.
Many consultants were quite happy because it meant they could use tick box templates and that would comply with the guide.
If you look in the guides at the further reading section it does refer you to the ACOP, but most people wouldn't spot that link quite understandably.
There is no need to amend the Order, nothing has changed!! There has always been a statutory requirement to record the prescribed info......only now are they explaining what constitutes a suitable & sufficient way of recording that info.
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Unfortunately only the enforcers will look at, hopefully, the Enforcers guide. The Rp will pick up the copy they want and just do their thing. An addendum to the guides for the RP would be good just so that all are aware of the change in stance.
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What about photographs?
What could be better for recording and for identification?
Stu
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One of my clients has just been served an enforcement notice by a fire authority in the West Midlands. (No names no pack drill!!)
The notice is an absolute disgrace. And then some of you have the audacity to ask for plans to make the risk assessment clearer and easier to understand!
The notice is dated 5 November and the follow up inspection to check the work has been completed will be on or after the 20 November. Any problem with that do you think????
Heres the worst bit. Direct quote from the notice.
Action required
The Responsible Person must take such fire precaution measures in the premises, (as defined in Article 4, paragraph (1) (a) to (f) of the Order) as will ensure the safety of employees. With regard to the deficiencies identified in particular, take, From Article 4(1):-(a) measures to reduce the risk of fire on the premises and the risk of the spread of fire on the premises (b) measures in relation to the means of escape from the premises (c) measures for securing that, at all material times, the means of escape can be safely and effectively used
(Part 2, of the relevant HM Government Fire Safety Risk Assessment Guidance Booklet refers)
So thats fine then isnt it. Clearly sets out what is to be done.
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Kurnal,
I understand your dismay but it is not the enforcers job to tell the RP how to do what needs doing it is for the FRA to do that. This is a straight follow on from notices that the HSE send out and they have been criticised in the courts twice over recent times.
1. Doing as above and directing the RP to do something that was explained. The court said that was not enough.
2. Being prescriptive with what had to be done. The court stated that wasn't the role of the HSE, their role was to identify ares in the legislation that had not been complied with and then the RP through the RA had to come up with answers to the Notice to the staisfaction of the HSE.
I have spoken to HSE inspectors about how they go about their Notices and the stance is to do what you have in front of you and then have a meeting to decide what to do between all parties.
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One of my clients has just been served an enforcement notice by a fire authority in the West Midlands. (No names no pack drill!!)
The notice is an absolute disgrace. And then some of you have the audacity to ask for plans to make the risk assessment clearer and easier to understand!
The notice is dated 5 November and the follow up inspection to check the work has been completed will be on or after the 20 November. Any problem with that do you think????
Heres the worst bit. Direct quote from the notice.
Action required
The Responsible Person must take such fire precaution measures in the premises, (as defined in Article 4, paragraph (1) (a) to (f) of the Order) as will ensure the safety of employees. With regard to the deficiencies identified in particular, take, From Article 4(1):-(a) measures to reduce the risk of fire on the premises and the risk of the spread of fire on the premises (b) measures in relation to the means of escape from the premises (c) measures for securing that, at all material times, the means of escape can be safely and effectively used
(Part 2, of the relevant HM Government Fire Safety Risk Assessment Guidance Booklet refers)
So thats fine then isnt it. Clearly sets out what is to be done.
Kurnal, even though an enforcing authority do not have to include directions on how to put matters right……………see article 30(3)…
“(3) An enforcement notice MAY, subject to article 36, include directions as to the measures which the enforcing authority consider are necessary to remedy the failure referred to in paragraph (1) and any such measures may be framed so as to afford the person on whom the notice is served a choice between different ways of remedying the contravention.”
case law under HASAW may make it desirable to give such directions because confusing notices may be considered invalid by the Courts……
BT Fleet Ltd v McKenna QBD (Admin) 17/3/2005
Improvement notices under s.21 of the Health and Safety at Work Act 1974 should state what was wrong and why it was wrong. The notice had to be clear and easy to understand. If the statutory option was exercised so as to proscribe how a recipient could comply with a notice, any directions given as to compliance formed part of the notice and, if confusing, could operate to make the notice invalid.
It MAY be worth pointing this out to WMFRS
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Thanks Phil and Jokar.
The first problem as I see it is that only 14 days have been allowed from issue to re-inspection. Whatever happened to the time for appeal?
I quoted just the action required from a three page notice of which only two lines gave any meaningful direction to the RP. In fact the only two requirements are to furnish certificates to prove that a timber lining to part of a ceiling has been treated with fire retardant varnish (it has been as a result of my risk assessment but certs are outstanding) and to fit a panic bar to an exit from a meeting room - the exit may be used by up to 100 people, has a lever handle and is actually the main way into the meeting room from the car park).
Nowhere in the three pages is there any mention of right of appeal.
Also nowhere does it actually state that it is an enforcement notice.
The reference to employees is surprising as the premises are a hotel and bar so the relevant persons are actually in the main customers and guests, rather than employees.
Finally how can the RP make an appeal based on such undefined actions required?
It would be tantamount to appealing for a relaxation of the duties imposed by the articles?
I will of course be discussing all of this with the fire authority tomorrow - there no need to appeal- the work has already been done.
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Kurnal
If I was a mischievious sort I'd avise your client to appeal the notice........if the notice gives less than 28 days it is clearly invalid and your client would win his appeal and costs.........if only I was mischievious!!!
The work may be done...you could still appeal just for the fun of it!!!
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You mischievous? Perish the thought.
After a good winge I usually take a pragmatic view. Lets just consider an appeal. An appeal would not help the RP or the relevant persons. If the work needs to be done it will still need to be done (or an equivalent standard of safety achieved in a different way) after a successful appeal. Unlike the old FP Act- where if you saw the fire authority off in court they would go away and not re-visit the issues- winning an appeal does not end the matter under the RRO - and does not absolve the RP from his duties!!
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I note Phil’s comments re Article 30 (3) but the FRA should still be acting in line with then fire safety concordat surely?
As a fire safety manager it was my policy that where possible notices were hand delivered and an explanation given as to what was required. This also ensured that the work was more likely to get completed in the time scales within the notice.
Just before the RRFSO came in to force I was involved in some regional training for FSO's where it was stated at the time that up to 80% of notices that were issued by FRA's are issued illegally. Which seems to have happened in your case Kurnal.
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Just to get back to the plans issue;
Even if you do not 'have' to have plans, what a lot of people seem to forget is that carrying out a risk assessment and confirming/providing a satisfactory evacuation strategy etc. is not primarily done for auditing consultants or inspecting officers it is done for the 'responsible person'. You are supposed to hand over the risk assessment to the responsible person to manage it, and take control of it ;
a. You should state what measures you have taken, or are in place to reduce, prevent, control etc. etc. therefore text explaining and justifying your conclusions, and ;
b. To support the responsible person ( who pays the bill), who we assume does not have a fire safety background, we should provide them with every means to assist them in maintaining those fire precautions, which also includes providing employees with information. If 'we' by risk assessment provide the building with the correct features to confirm/provide a satisfactory evacuation strategy etc. Then by indicating how the building is laid out and 'used' (risk indication) with fire safety features indicated, a plan is a very 'helpful tool' for the client, to assist him in maintaining the fire precautions. it is not prescriptive it is to assist, if they want to change anything from the details in the script or on the plan, they are aware that a review of the risk assesment is required it is fluid.
You ask any employer/ owner they want the management of the fire precautions made as simple as possible, they have a lot of other things to do, and it is easier to inform employees of what is their for their safety by using a plan.
I am not in the debate of whether we must or must not, but an advocate ( no sticky yellow drink jokes ) of using what we can to provide and assist people in manageing their fire safety .
Having a 'Rant ' on here sets you up for the day !!
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Just before the RRFSO came in to force I was involved in some regional training for FSO's where it was stated at the time that up to 80% of notices that were issued by FRA's are issued illegally.
What national training do IO's get these days?
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At a time when, the fire safety IO's are being civilianised ( i.e. not a negative term, but just stating they are new and generally without any form of 'fire' background, so if you have someone new they needs training). There appears to be a lack of national and sometimes local provision of satisfactory competence based training strategy. Hence more inconsistency and lack of understanding. Some have been trained in tick box auditing to populate databases, so I cannot say no training.
(personal views only)
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There is very little National training it seems to be regional. Larger Brigades have adeqaute training sites and staffing levels to ensure that staff from non and uniformed backgrounds receive induction and continuation training. However, a problem arises in the management of teams by conflicting workloads and lack of experience of fire safety managers and in some incidents the old stager/code hugger/prescriptive person wins out and as they are with newbys their strength of character takes over and the training falls apart.
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If the training is regional do they use a national syllabus or do what ever they fancy?
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I know this is going further off-topic but training is a shambles.
There is no national syllabus, the Fire Service College is, for whatever reason, (and that is worthy of a thread on its own), not meeting the needs of a large part of its natural customer base. Pressure on costs, above all, mean that every six months the type, place, supplier and extent of delivery is re-evaluated meaning that any medium term planning is rendered pointless. There are competing agencies from FPA, arm's length trading companies, in-house training centres and the College. There are competing standards from Engineering Council, IFE Assessor/Auditor, various regional accredited training places (accredited to what?). I recently argued that after flirting with the other suppliers for several years, (all of which takes up a huge chunk of management resources) the College actually provided the most cost-effective solution but in the micky-mouse world of fire authority finances and overblown egos, that didn't go down too well. And don't even get me started on IPDS!!
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Theres nothing wrong with IPDS is there Val?
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I know this is going further off-topic but training is a shambles.
There is no national syllabus, the Fire Service College is, for whatever reason, (and that is worthy of a thread on its own), not meeting the needs of a large part of its natural customer base. Pressure on costs, above all, mean that every six months the type, place, supplier and extent of delivery is re-evaluated meaning that any medium term planning is rendered pointless. There are competing agencies from FPA, arm's length trading companies, in-house training centres and the College. There are competing standards from Engineering Council, IFE Assessor/Auditor, various regional accredited training places (accredited to what?). I recently argued that after flirting with the other suppliers for several years, (all of which takes up a huge chunk of management resources) the College actually provided the most cost-effective solution but in the micky-mouse world of fire authority finances and overblown egos, that didn't go down too well. And don't even get me started on IPDS!!
I'm afraid I have to agree with Val on this one, particularly the comments regarding the Fire Service College.
No Kurnal, nothing wrong with IPDS it's all going swimmingly!
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Aren't the last 2 letters diddly squat?
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Val, your comments would very much be appreciated concerning the following approach that we have taken for Fire Safety Training (anyone elses too).
The Fire Safety National Occupational Standards are available:
http://www.ipds.co.uk/public/site/newsdocs103/1-Fire_Safety_Standards_Approved_October_04.doc
Although I believe they were not formally issued by the IPDS hub (which I understand has been dismantled) they are used for the Fire Safety NVQ's created by Edexcel. (They even had draft fire safety role maps at one time, but they have since dissappeared)
We have used the knowledge elements from the Fire Safety related elements as an outline curriculum, adding to it the enforcement tools that we use, such as the Enforcement Management Model (EMM), our standard letter package etc. and the other Knowledge, Skills and Attitudes that our IO's have been identified as needing (through a formal training needs analysis (TNA)) to carry out their roles competently. In addition we are in the process of attempting to incorporate the 6 Key Skills (Which have been signposted for us by LGE):
http://www.ipds.co.uk/public/site/newsdocs107/5-Fire_Safety_Key_Skills_Signposting_Approved_October_04.doc
This provides a basic introductory course for new entrants into the Fire Safety Department, and it appears to work well, although that will only be proven when our formal evaluation has been carried out over a longer period of time.
We use the Fire Service College's Outreach Training for the Fire Safety Solutions Courses, which cuts the costs dramatically.
We also use the College to provide the Fire Engineering Courses which the students attend on a residential basis.
We use CS Todd & Ass's for Fire Risk Assessment Training; and
Bond Solon for Legal Procedures and Courtroom Skills.
However when you look at the downsides of using the College:
Course costs of well over £1000 a week;
Appalling accomodation in some cases;
The College dictating when their customers (our students) will be allowed to attend the courses;
Large class sizes 30+ which rules out any real student centred activities or individual attention;
Appallingly laid out lecture theatres which are totally unsuitable for modern teaching practice;
The ocassional instructor who knows less about Fire Safety than the students (Present company excepted);
Padded out courses containing irrelevant material and 'Personal Study' time (even on some of the one week courses!)
etc etc etc (Starting to get RSI)
Is it any wonder that previous customers are looking elsewhere for their training providers, which is borne out by the fact that the place is more or less empty every time I've been down there over the last couple of years.
It appears to be the same old case of Fire Safety being pushed to one side again, which as we know always happens as our FRS Senior Managers are overwhelmingly from a solely Operational background.
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Apologies for hijacking your thread Phil, I will put it up as a new post if you would prefer?
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We use the Fire Service College's Outreach Training for the Fire Safety Solutions Courses, which cuts the costs dramatically.
We also use the College to provide the Fire Engineering Courses which the students attend on a residential basis.
We use CS Todd & Ass's for Fire Risk Assessment Training; and
Bond Solon for Legal Procedures and Courtroom Skills.
However when you look at the downsides of using the College:
Course costs of well over £1000 a week;
Appalling accomodation in some cases;
The College dictating when their customers (our students) will be allowed to attend the courses;
Large class sizes 30+ which rules out any real student centred activities or individual attention;
Appallingly laid out lecture theatres which are totally unsuitable for modern teaching practice;
The ocassional instructor who knows less about Fire Safety than the students (Present company excepted);
Padded out courses containing irrelevant material and 'Personal Study' time (even on some of the one week courses!)
etc etc etc (Starting to get RSI)
Is it any wonder that previous customers are looking elsewhere for their training providers, which is borne out by the fact that the place is more or less empty every time I've been down there over the last couple of years.
It appears to be the same old case of Fire Safety being pushed to one side again, which as we know always happens as our FRS Senior Managers are overwhelmingly from a solely Operational background.
We really have strayed from the original subject here but you make some valid comments John which should promote some debate.
My personal response...........yes I have to agree FSC (FireSafety) at present very poor ...not the fault of the few remaining secondees but it appears that the senior management are no longer interested in providing quality fire safety training........the few secondees that remain have no time for course development so the situation is unlikely to improve in the near future.
Poor lecture rooms...yes...but they have a lovely reception now...and a new restaurant!!! if only 8 hours a day could be spent there!!!!!
Yes some instructors past and present could be much better...but that is no criticism of any existing tutors as it is not their fault having no development time.
Some previous instructors shouldn't be let out on their own!........lets's start a new thread on that one!!!!!!
Whilst I love Collllin Toddddd dearly I can never understand why a FRS would choose to train their auditors in the use of one methodology for fire risk assessment....particularly one that doesn't recommend or even mention the use of plans!!!!.
Bond Solon for Legal Procedures and Courtroom Skills.......why??????????????????????????????????????????? their courses are not tailored specifically for the one piece of Statute the FRS must enforce.
Yes it does seem that in many FRS (but not all) that fire safety is being pushed to one side, that is wrong and we all know it....but until it becomes flavour of the month or good promotion fodder it will remain to one side.
On a positive note some of us obviously care and there are some very good alternatives to the FSC emerging and growing from strength to strength.
It must surely only be a matter of time before one of the new breed of FRS managers realises that fire safety is important and will only be achieved if their employees know what they are doing.
.............................apparently managers who can use the correct buzz words and can play the role of a pretend leisure centre manager will ensure the future of fire safety in our modern FRS.
.
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Apologies for hijacking your thread Phil, I will put it up as a new post if you would prefer?
no apologies necessary....good points that need discussing John.
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Johno67
I have had a number of glasses of claret, but here goes!
My post was not an attack on the College, although there are some serious failings there. It was an attack on the pervasive culture of trying to get something on the cheap. Your post is very detailed and no doubt factual but it does not address the fundemental malise because FRA are not able or willing to develop medium or long term stategies for selection, appointment, development and retention of fire safety professionals.
As far as I am aware, almost no FRA has adopted the NOS in anything other than name.
We too use TNA, Bond Solon, teach EMM and all the rest but more by default than any planned and coherent strategy. Most FRA's ran a mile from the proper implementation of IPDS when they began to fully appreciate the costs and resource implications.
I remember a presentation in front of a hundered senior fire safety officers at Washington Hall when the presenter tried to sell the concept of the NOS but thought that fire safety officers had no role in taking offenders through the Courts...according to the presenter, (who had been involved in writing the NOS), the police did this! If ever a concept was destroyed...this was it.
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Phil & Val, many thanks for your comments:
Phil,
I agree with virtually all of your comments.
I believe that the Fire Service College should be the Centre of Excellence that I think most of us want it to be. But it would take a lot of investment (from Government, if they want it to be a beacon) and a lot of bridge building to bring the majority of FRS' back through its doors on a regular basis. When run and funded properly, it is in my opinion a learning experience second to none.
We use the Colin Todd course as it is based upon the Accepted Methodology for Fire Risk Assessment (PAS79). I agree that there are certain aspects (such as plans) that don't sit right, but in my experience these are always, without exception, hotly debated by students and instructor(s). I think there are some very good aspects to the course, and besides, we don't swallow everything we are told. We apply the parts that we think are suitable and omit those that we consider are not. Are you aware of any alternative providers that would provide something more appropriate, as we are always looking to provide the best training that we can for our students?
Are you aware of a provider that supplies a more suitable legal training course than Bond Solon? I completed my training as part of the old B module at the College and thought it was very good (especially the day in court). I've never received any seriously negative feedback on Bond Solon's courses, and the officers that are using PACE and interviewing on a regular basis, seem to have the knowledge and skills required to carry out the role competently.
We also now have Fire Safety Managers who have never worked in the Fire Safety Department before.
Val,
I agree with your comments completely.
As an example, last year we received just over half of the training budget that we requested for the development of our Fire Safety Officers. And the full amount that we asked for was only to ensure that as a department we didn't move backwards!
We also held a seminar on the Fire Safety Order, that was attended by two of our PO's, who both spoke during the introduction to the day.
One said that he had completed a short time in the Fire Safety Department but had decided it wasn't for him, and the other said that for him Fire Safety is a very dry subject (that still makes me smile now) - great motivational speaking, which I think shows the general attitude of the FRS' Senior Management to the subject.
However, as we are only too aware, this is very unlikely to change in the near future, therefore we have to make the best of a bad situation (which I am sure we are all trying to do).
Maybe, as Fire Safety Departments tend to be comparatively small, and there appear to be fewer inflated egos, we could look to develop best practice and even a National Curriculum for Fire Safety ourselves. (or is my thinking too simplistic?)
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we could look to develop best practice and even a National Curriculum for Fire Safety ourselves.
John if not you the DCLG should and now they have the RR(FS)O guidance notes, which appear to be similar to the old FPA Circulars, they could produce a National Curriculum for Fire Safety which may address some of the adverse comments about today’s FSO's you hear on this forum.
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If the external people ( say consultants) are doing audits using a system devised by one individual.
And then that individual is teaching the new people doing the enforcing (say fire authorities ) about that system, and that they must accept the system devised by the individual.
Are we ever going to get the findings of that system done by a consulatnt, criticised or faulted by the enforcing authority ?
If that same individual is then assessing people to go on a register of ' approved risk assessors', who would be best advised to use the aforesaid system or others but must fit the doctrine, does it not then self perpetuate ?
Is there only me thinks something is not quite right here ?
Today the UK, tomorrow the World !
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AFD,
Colin doesn't post here anymore although I see he is still trying hard to make friends, (see his letter in IFE Journal).
Good job he's right most of the time.
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I think you know my views on this AFD, I totally agree with your concerns.
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Why would a consultant be doing an audit, unless to verify their own process is correct or as part of a review of the risk assessment?
The audits are surely the remit of the enforcing authority inspectors ....... or are consultants now doing enforcement?
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AFD just say Colin Todd and PAS 79 if I had to use it I wouldn’t be happy neither but what other national guidance is there.
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I rest my case, its now called a 'national guidance' !
I thought it was one persons idea of a risk assessment ! if you thought it was OK, you paid the fee and could follow it, which seems fair enough if you thinks its alright buy it and use it. I have no problem with that ( big of me, I know).
Some people will look at an Hyundia car and think its OK , its efficient and cost effective. But it is not the 'national standard car'.
Until the driving examiners say you must take your test in one, and the chancellor says they are tax exempt and can run only them, on red diesel ( I know they don't make a diesel but it would spoil the story ), and all other cars must provide CO2 emmision levels the same as the Hyundia.
Then you would say 'Bloody Clever at Hyundia' !
But are they any good ?
This is only my personal opinion and no offence to Hyundia owners !
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Val, your comments would very much be appreciated concerning the following approach that we have taken for Fire Safety Training (anyone elses too).
The Fire Safety National Occupational Standards are available:
http://www.ipds.co.uk/public/site/newsdocs103/1-Fire_Safety_Standards_Approved_October_04.doc
Although I believe they were not formally issued by the IPDS hub (which I understand has been dismantled) they are used for the Fire Safety NVQ's created by Edexcel. (They even had draft fire safety role maps at one time, but they have since dissappeared)
We have used the knowledge elements from the Fire Safety related elements as an outline curriculum, adding to it the enforcement tools that we use, such as the Enforcement Management Model (EMM), our standard letter package etc. and the other Knowledge, Skills and Attitudes that our IO's have been identified as needing (through a formal training needs analysis (TNA)) to carry out their roles competently. In addition we are in the process of attempting to incorporate the 6 Key Skills (Which have been signposted for us by LGE):
http://www.ipds.co.uk/public/site/newsdocs107/5-Fire_Safety_Key_Skills_Signposting_Approved_October_04.doc
This provides a basic introductory course for new entrants into the Fire Safety Department, and it appears to work well, although that will only be proven when our formal evaluation has been carried out over a longer period of time.
We use the Fire Service College's Outreach Training for the Fire Safety Solutions Courses, which cuts the costs dramatically.
We also use the College to provide the Fire Engineering Courses which the students attend on a residential basis.
We use CS Todd & Ass's for Fire Risk Assessment Training; and
Bond Solon for Legal Procedures and Courtroom Skills.
However when you look at the downsides of using the College:
Course costs of well over £1000 a week;
Appalling accomodation in some cases;
The College dictating when their customers (our students) will be allowed to attend the courses;
Large class sizes 30+ which rules out any real student centred activities or individual attention;
Appallingly laid out lecture theatres which are totally unsuitable for modern teaching practice;
The ocassional instructor who knows less about Fire Safety than the students (Present company excepted);
Padded out courses containing irrelevant material and 'Personal Study' time (even on some of the one week courses!)
etc etc etc (Starting to get RSI)
Is it any wonder that previous customers are looking elsewhere for their training providers, which is borne out by the fact that the place is more or less empty every time I've been down there over the last couple of years.
It appears to be the same old case of Fire Safety being pushed to one side again, which as we know always happens as our FRS Senior Managers are overwhelmingly from a solely Operational background.
Johno
You've really sold the concept to me. Sounds like you have got an excellent set up in your brigade have you got any jobs for trainiers!!??
BB
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I rest my case, its now called a 'national guidance' !
I thought it was one persons idea of a risk assessment ! if you thought it was OK, you paid the fee and could follow it, which seems fair enough if you thinks its alright buy it and use it. I have no problem with that ( big of me, I know).
No I do not think it’s OK, there are parts I would accept, and combined with Part 1 of the DCLG guides you could come up with a reasonable standard. This is what the DCLG should have done, mind you with the animal guide as an example maybe not.
At the moment everybody seems to be going their own way and to do an audit it must be a nightmare. I believe audits like re-inspections under the FPA are an essential part of the legislation.
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However when you look at the downsides of using the College:
Course costs of well over £1000 a week;
Appalling accomodation in some cases;
The College dictating when their customers (our students) will be allowed to attend the courses;
Large class sizes 30+ which rules out any real student centred activities or individual attention;
Appallingly laid out lecture theatres which are totally unsuitable for modern teaching practice;
The ocassional instructor who knows less about Fire Safety than the students (Present company excepted);
Padded out courses containing irrelevant material and 'Personal Study' time (even on some of the one week courses!)
johno - you forgot to mention the food :)
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johno - you forgot to mention the food :)
I wondered why they called you Dinertime Dave!!
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I seem to be in a minority but I think the food is fine (suppose it's what you are used to!) :/
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OK , so we all agree that PAS 79 as was, was 'poor' but we were all told at the time by the 'wise one' that we were out of step with the 'wise ones' thinking ! Which was always right.
But now it changes 'slightly' because of the new legislation or guidance !
The prinicples of means of escape or risk assessment have not changed, it is just that ( I hope ) the professional and passionate amongst us, are gaining a voice.
The principles of means of escape and justifying a decision, as opposed to ticking a box and saying ' means of escape are satisfactory' I hope are coming to the fore, and eventually ( I know its a long way off ) can all start to speak as one voice based upon common principles and not on ego, and/or filling your pocket.
Then fire safety will be a professional industry and not a 'bu****it one, that is argued by everyones opinion that suits there cause ( or bank balance) and not on common principles.
if I'm wrong may 'lightning' strike me down !