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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Guest on December 13, 2004, 01:45:19 PM
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Risk assessment
For discussion: does the introduction of purely risk-based fire legislation mean that an approach to fire safety along the lines “I probably won’t have a fire, therefore I need do nothing” or even “…I am spending too much and can get away with much less” legitimate?
Consider the following – an organisation uses established risk assessment methodology to assess the risk from fire for its premises. Based upon past incidents of fire; statistics from similar properties and the use of the premises (good training, strong management ethos and relatively well-controlled fire load, perhaps), they are able to make a quantitative assessment that the risk of having a major fire is demonstrably very low. They also regularly practice evacuation and are able to reliably and fairly rapidly clear their building(s).
They conclude from this that they can dispense with much of their fire-resisting structure, all sprinklers and first aid fire-fighting equipment. They conclude that they do not need to follow British Standards (e.g. BS 5588) or other relevant guidance (including that from the Regulators), because they control risk to a sufficient degree that compliance would be unduly onerous – the cost of doing so (and maintaining the kit) would be disproportionate to the risk reduction achieved.
They are similarly satisfied that property / asset risks are sufficiently controlled and they self-insure.
If all the law requires is that risks are as low as reasonably practicable, it is certainly possible that the fire risk in many relatively low-risk premises is so low that there could be a strong argument that existing fire protection is unnecessary. If the guidance on what is represented by ‘as low as reasonably practicable’ does not consider how ‘good practice’ and risk assessment methodology interact, we shall shortly be facing the situation where some larger organisations start to question the ’value’ of their existing fire protection (let alone improvements in fire protection).
As you may infer – this is not a theoretical discussion – there is at least one major organisation who is actively considering the above approach. The organisation is big enough so that the property / asset risk can be ‘absorbed’ without undue risk.
We would be very interested in the views of those on the forum on the whole issue of ‘risk assessment’ vs. ‘good practice’. Existing guidance in pd 7974-7 appears to be silent on this issue.
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I think this whole argument is based on a minunderstanding of the concept of "risk."
In most environments the probability of fire is quite low, but "risk" is defined "as the combination of the probability of an event and its consequences" (ISO/IEC Guide 73)
Therefore, the consequences of a fire must be multiplied by the probability. If the result (risk) is still low, i.e. low probability and low consequences, then fine - do away with the sprinklers, but if the conseqences are high (i.e. include possibility of death, or large expence) then risk control is needed.
So the real problem is a minunderstanding of risk, due to a lack of competant risk management professionals.
Probability x Consequences = Risk
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Absolutely not - the risk assessment methodology used in the above is industry-standard and fully considers the hazards, probability and consequences on an 'event'. If probability is low, the value of the 'consequences' part of the equation becomes largely immaterial. The method does not, however, take any heed of ACOPs, BSs, ADB & other guidance - the assessment claims that risk is low so there is no need to.
The issue is not just sprinklers - it relates to most of the fire protection - if the 'purist' risk assessment methodology is followed there will be little fire protection left.
It is a fact that the probability of having a major fire in any one commercial premises (over its design life) will be very small indeed. Even if you do have a fire, generally speaking the probability of death or serious injury (in an office building, for example) tends not to be high.
Once we have 'pure' risk-based legislation, the route will be open for any employer to reduce/remove their existing / future fire protection measures if they believe that they can demonstrate that the risk reduction they provide is disproportionate to the cost of provision / maintenance. We could end up with little protection left.
As a fire engineer, deciding not to provide well-established and proven 'safe' levels of protection, as enshrined in British Standards etc, on the 'assumption' that you won't have a major fire (dress it up as 'risk assessment' if you like) fills me with concern! I would welcome the views of others!
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In the above scenario, the likelihood of a fire occurring is deemed as low. What is the basis of that assessment? Is it historical data? If so, was the data set collected from premises with reduced fire precautions?
If it had been collected from premises with approriate fire preacuations as per the appropriate standards then using this data set to argue a reduction in the very precautions that had influenced the data would not be a valid argument. Such a data set could not be directly releted to premises without the level of preacuations that existed in the premises for which they were collected.
The argument being proposed is is akin to stating that your trousers have not fallen down for at least a decade, so now you can remove your belt! :oops:
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Exactly.
There is an argument that risk assessments should consider the "gross" and "net" risks. That is, the risk as it occurs without the control measures and then with them.
The gross risk of a fire without the risk control measures (ranging from compartmentation, alarm, fire escapes, etc) surely could result in significant property damage and death in the worse case scenario.
Therefore, to most organisations, irrespective of their risk culture, death and loss of the building, is most likely to be considered catastrohpic.
I could concur that the risk of a fire in most workplaces may well be low, however, a "low" probability of a catastrophic event cannot be acceptable. The control measures must reduce the probability to "impossible" or "unlikely ever to happen" before such a risk can be deemed as being properly controlled.
I would not work in a place where the net risk of death was just "low".
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While risk assessment depends on identifying hazards what about the hard to identify ones like arson and terrorism? Commercial sector buildings are recognised as targets more and more post 9/11.
How does this equate with the 'low' probability cited by the large organisation our guest is involved with?
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I think those most at risk of terrorism are probably very aware of it - however for the rest of the organisations in the UK, the risk control measures for dealing with terrorism risks are often the same as those that ought to be deployed to prevent break-ins, theft, tresspass and other risks that have been faced for many years.
Any risk to staff health or safety has to be assessed and controlled under existing health and safety legislation.
Arson should be considered as part of the fire safety risk assessment. It's a daily event in the UK and should not be considered a rarity. In some sectors it is the most likely cause of fire. Unlike an accidental fire, arson attacks can have more than one seat of fire and may be aided by an accelerant.
"The Risk Management Standard", AIRMIC, ALARM and IRM 2002 is available from the IRM website http://www.theirm.org/
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It'll be interesting to see how the RRO deals with this - will it be acceptable for an organisation to assume that it controls the risk of a significant fire occurring so well that it doesn't need to have detection, suppression, fire resisting construction etc, because the cost/benefit of doing so is so low?
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The ODPM has been banging on about the concept of carrying out a FRS by reducing the risk to a minimum before applying general fire precautions to control the remaining risk. All very sound but it does open the door to the argument that if the risk has been so reduced that it is neglible then, as said above, the need for any protective measures becomes redundant.
This is a dangerous route, made more so by expecting 'nominally competent' people to make this judgement. Professor Everton has been trying to make this plea, largely falling on deaf ears, for months.
The result of poor fire precautions is demonstrated nearly every week by some fire disaster in a largely unregulated part of the world.
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It is not necessarily a bad thing that companies are reassessing fire risk, if done correctly it should be a good thing.
However to do so on a high level, looking at the occurrence of major fires and not taking into consideration minor fires is deeply flawed. Further to then not adhere to the fire safety standards (ie flammability, surface flame spread, fire withstand and containment etc) that are in place to mitigate the consequence from minor fires, then removing the means to extinguish those minor fires is wrong.
Apart from not providing necessary fire extinguishing equipment, it must be assumed that all minor fires will grow unimpeded, until there is an external intervention by the FRS, therefore any arguments based on the level of risk must treat minor fires as major fires in this case.
Hope this helps
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To follow on from Chris's points, we need to consider the risk from fire as well as the risk of fire. That's what the compartments, sprinklers, etc are there for. Unless you are dealing with a guaranteed fire-free zone (empty concrete box?) you need to control the risk to occupants and others who may be affected. Does anyone imagine that those in control of the building will escape litigation after a death or injury from fire by arguing upon the basis of such an assessment?
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Thought I'd resurrect this one...
Does the RR(FS)O have any impact on this thread? Are we any closer to the Responsible Person's risk assessment being based almost entirely on the principle that it is unlikely that they will have a fire... and if not, why not?
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Yes we are. Following the RRO guidance the first steps of the RA are to identify sources of ignition and fuels that may burn, and the risk that the two may come into contact.
If you have neither, then theres no risk and there is no need to incorporate any risk control measures.
Example - large shed where concrete slabs are manufactured, cast and stored, almost entirely by human effort supplemented by a diesel fork lift.
The only risk control measure is that bins for empty bags are removed on a daily basis and taken out of building. No fire alarm, no FFE, only most basic of emergency procedures.
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'No risk' is fairly straightforward - but what about risks that could be regarded as 'broadly acceptable', according to the HSE guidance? If you look at the UK fire statistics, next to no-one dies in an office fire each year, despite the fact that there must be tens, if not hundreds of thousands of them in the Country. Why, then, should we make any great effort to mitigate a risk which is already demonstrably acceptable? As a manager of such a premises, can I not conclude that much of the existing fire precautions (which cost me money to manage and maintain) are unnecessary, because it is so unlikely that I will have a big fire, and even then there is a low probability that anyone would die?
I have my own views (which aren't entirely in agreement with the above); it's intended to provoke discussion, because there are Responsible Persons out there thinking along the above lines...
...and please let's keep the Insurers out of the picture at the moment - we all know they have a legitimate interest, but it's compliance with the law that's of primary concern.
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Some good discussion points here chaps!!!
I have always argued that the likelihood of a fire happening is not really that important. You have to work on the assumption that a fire could happen. It may happen only once in 400 years but that once could be tommorow.
Yes you can have a building that has no ignition sources, and no fuel. Perhaps a concrete shell with no electricty supply and no furniture. As soon as people resort to the building you introduce ignition sources and fuel.
Therefore in my opinion there is a reasonable likelihood of fire occuring in all buildings. What you can do is reduce the likely development.
What worries me is that some people, including my dear friend Mr Todd, believe that if you reduce the likelihood of fire occuring you can reduce the preventive and protective measures required. This is a load of gonads in my opinion.
If you reduce the potential for development you can reduce the preventive and protective measures but only so far so as to maintain minimum standards for life safety.
And as far as the Fire Safety Order is concerned the responsible person must take general fire precautuions to ensure the safety of relevant persons.
This includes people in the vicinity i.e. your neighbours. Therefore the old arguement that all persons can walk away from my building so I need take no further action has gone. You must reduce the risk & mitigate the effects to ensure that neighbouring buildings will not be effected.
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Colin Newman hit it on the head with his belt analogy.
It is not acceptable to remove your belt just because your own and nobody else's trousers have fallen down for 10 years.
If I can prove however that MY trousers will not fall down if I remove MY own belt then there is nothing wrong with doing this. But I will have to keep a regular check on the clasp on the trousers and my wasitline to make sure they are still secure. Otherwise I may face the consequences of prosecution for indecent exposure. I may choose to take that chance - and just to make sure there is no public outrage the government may set up trouser police to check on decency and issue advice /enforcement/ prohibition notices or take me to court if they think I have not done enough.
In short only case law will decide this. There will be no hard and fast answers until it has been tested in the courts. But it would be very unwise to rely on past history as the basis for your defence. It is only one very minor matter to be taken into account in the risk assessment process.
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Fishy you would not have made that assumption in the 1960`s (500+ fatalities in non domestic premises) it was only the fire legislation that originated then that allows you to make this assumption today. If you start reducing fire precautions, like you suggest, then I can only see us on the slippery slope back to the 1960`s.
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As someone that can recall smoke-filled office buildings, occupants escaping to the sound of ringing alarms and portable extinguishers used with success, I have no doubt of the need for such control measures in office accommodation as well as the indefensibility of claiming a sufficient risk assessment for non-provision in a subsequent court case.
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One of the problems seems to be that few (if any) people have any idea what the precautions required in the past have done to affect the statistics on which much current thought is based. It is extremely difficult to estimate what hasn't happened; ie how many fires have not occured because people have been taking the precautions they were advised (or required) to do to avoid such an event.
As PhilB says, you have to presume that a fire can occur and take reasonable precautions to ensure firstly that people can get out promptly and secondly to minimise property loss. As the precautions for the first can often give assistance to the second, I have found that management is sometimes easier to convince if one can show the overall picture to them as well as their statutory obligations.
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One of the problems seems to be that few (if any) people have any idea what the precautions required in the past have done to affect the statistics on which much current thought is based. It is extremely difficult to estimate what hasn't happened; ie how many fires have not occurred because people have been taking the precautions they were advised (or required) to do to avoid such an event.
I believe it was Wellington who said "Lies, Damn Lies and Statistics" and I agree to some extent with that. I would agree you cannot be absolutely certain but making an educated guess would you not agree that the fire precautions required in the past have been a principle factor in reducing fire fatalities in non domestic premises. As to your second statement "people have been taking the precautions they were advised" this has not been my experience quite the opposite both manager and employees seem to constantly find ways to negate the fire precautions provided.
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I think the fact that fires and fire fatilities in non-domestic premises show a decline means that many have been doing what they ought to do. Not everyone does , alas, which is why we have the enforcers to back up the legislation. My own impression of commerce is that over 50% do attempt to do what is required; or maybe I've just been fortunate in the firms I have visited?
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I would disagree that fires and fire fatalities in non-domestic premises show a decline means that many have been doing what they ought to do its mostly due to passive and active fire precautions installed over the past forty years. I also think you have been very fortunate in the firms you have visited.
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The real test of any judgement will be in a court of law if you can argue your case in mitigation should the proverbial hit the fan then you will only be fined and you wont go to jail. I agree with all points of view the first contributor was quite right as an academic with current data there does not appear to be any risk therefore his assessment does not find significant reason for action. I have long argued that current data is not valid as reporting and data collection of fire occurence is far from accurate by authorities as a function of fire definition and hate of paperwork.
The more traditional arguments are also valid as a function of knowledge and experience and I am sure as a function of the shear horror of injury by fire. the emotional view will certainly be recognised by the courts in terms of punitive damage and Directors liability as it was in the recent train crash where fire was involved.
This brings me to my real point about business risk assessment and where the cross over occurs and due consideration must be given as the risk of fire may be low to moderate but the business risk of doing little is extremely great if the proverbial does hit the fan.
My last point is that you overlook guidance documents and British Standards at your peril unless you can justify your deviation from establishment best practice you will need a very clever and expensive defence lawyer or an expert witness from the BRE to admit that they don't know their **** from their elbow.
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I look at this arguement in the light of the National Lottery. If you look at your personnal chance of winning the lottery statistically it is very small even your chance of winning a small amount is not good. However most weeks someone in the country gets very rich, very quickly.
For a big organisation you are in the role of someone entering the lottery many times a week, your chances of winning (or losing) are increased.
I know the statistical arguement that the cost of the fire precautions over the years is probably greater than the actual cost of a fire and if they put that money into an account they would probably win. The problem is they don't and suddenly they have a major shock.
Incidentally, if I have my information correct put the arguement to a major DIY retailer who lost their unsprinklered store in Leicester a few years ago and whom I understand is busy fitting sprinklers to the rest of their stores.
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- and the risks to be assessed aren't only financial!
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'No risk' is fairly straightforward - but what about risks that could be regarded as 'broadly acceptable', according to the HSE guidance? If you look at the UK fire statistics, next to no-one dies in an office fire each year, despite the fact that there must be tens, if not hundreds of thousands of them in the Country. Why, then, should we make any great effort to mitigate a risk which is already demonstrably acceptable? As a manager of such a premises, can I not conclude that much of the existing fire precautions (which cost me money to manage and maintain) are unnecessary, because it is so unlikely that I will have a big fire, and even then there is a low probability that anyone would die?
I have my own views (which aren't entirely in agreement with the above); it's intended to provoke discussion, because there are Responsible Persons out there thinking along the above lines...
...and please let's keep the Insurers out of the picture at the moment - we all know they have a legitimate interest, but it's compliance with the law that's of primary concern.
I sadly had the misfortune of going into a public building about 5 months ago, which was a multi used, and the management have the same sort of "weve never had a fire, so whats the point" attitude, similar to your views, well after my observations of such contempt they showed regarding not giving a stuff about any other member of the public, I reported the various issues to the HSE and the local FSO and the outcome was that they had broken many safety regulations and they have been told, now, to comply.
Its just not good enough that there are big organations out there that are so willing to take a risk with "other peoples lives" and thats it in a nutshell! its not about "money" "it might never happen" one must remember the law of averages! the longer you approach green traffic lights, the more the chance of them changing their sequence to RED, as the closer you get, and also what Phil B said about so long as everyone can walk out of your house, but youve got to think how your fire will affect your neighbours, the point I will make is, you must consider that not everyone is able bodied!!! not everyone can scale down stairs quicksticks, before your fire (or any other emergency) takes hold.
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The original question related to varying established standards by considering the probability of fire occuring.
These established standards are developed by considering, amongst other things, the probability of fire occuring in generic groups of buildings. On this basis if a specific building has a particullarly high or low probability compared to the norm for that building type then it would seem reasonable to vary the established standards.
Obviousely I dont think that a client saying "i've never had a fire so I'm alright" is sufficient but perhaps where a building has no significant fire load then some variation may be justified.
This is a fundemental principal of risk assessment. Although, in practice, most of us will be happy if the building and its management systems are in line with the norm.
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I've been driving for 30 years and I have never had an accident.
But I still wear a seat belt.
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Wee Brian, first and foremost the persons responsible for this building actually wrote to my solicitor and stated just that! and I agree, totally unsufficient, the building is very grand 16th century one, example; long heavy most probably antique bone dry velvet curtains, luxury carpeted stairs, chandaliers (excuse spelling) lots of oak and other wooden furniture, and not only that, it has an awful lot of people frequent this building and even though it has a fire limit of 200 for a wedding venue, when there is a craft fair of 100s plus in attendance...no-one has ever given a head count... so on the basis of this, I would think a risk of fire in this building that has kitchens in the basement possibly would hold some sort of "risk" but nevertheless the owners and users are going on the assumption of "well weve been lucky so far so whats the fuss"
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There's a great quote from the Kings Cross enquiry - the absence of accidents is not evidence of safety - or something like that. I'll try and find it.
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It appears that there is a consensus of opinion that companies should maintain a minimum level of fire safety precautions but there will be those who ignore the legislation for various reasons and the “I have never had a fire why do I need fire precautions” may develop more widely.
If this is the case do we have an enforcement regime that will curtail those companies or have the FRS cut back on enforcement officers to a level that may give concern and those that we do have will they have the necessary training.
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Whilst there will be some buildings where the risk of and from fire is negligible (such as unoccupied concrete or brick boxes) once you introduce persons, work activity, plant, equipment, materials, substances, heating, electrical installations, etc, etc into the equation, the risk must increase to, at least, a level requiring appropriate controls - which for life safety will need to include information, warning and extinguishant. History may be a guide but risk assessment needs to consider what could happen in future and it's consequences.
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But we’re not discussing ‘negligible’ risk – there is no obligation in law to make risks negligible. The obligation is to reduce them As Low As Reasonably Practicable (‘ALARP’). This means that you do NOT have to address all foreseeable risks.
The HSE framework for tolerability of risk separates risk into ‘Unacceptable’, ‘Tolerable’ and Broadly acceptable’ regions. If you have reduced a risk so that it is in the ‘Broadly acceptable’ range (or it is inherently in that range) the guidance says that you generally need do no more – the risks can be regarded as insignificant and adequately controlled. The HSE limit for ‘Broadly acceptable’ is a risk of death of 1 in a million per annum. HSE guidance quotes the annual risk of death from “fire, explosion or carbon monoxide poisoning” in the UK population as roughly 1 in 1.5 million per annum. The bulk of this risk must be when people are in their own homes; in the vast majority of cases the risk in their workplace will be lower. So why should the people responsible for those premises be expected to shell out hard cash to mitigate what is already a vanishingly small risk? Can the above not be their risk assessment? If not, why not?
As a fire professional I am not particularly comfortable with the above line of argument – but I find it difficult to spot why it isn’t legal! There are a few potential flaws; for new works it takes insufficient heed of good industry practice (British standards) and the HSE also obliges those assessing risk to take into account societal concern (difficult to do, unless you adhere to the Codes, which are written with that in mind). If there are other flaws, what are they...?
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The 'theory' may meet some HSE terminology, Fishy, but I wonder what the Courts will make of it. To take the Carbon monoxide example, imagine the response to quoting national statistics as a defence to not servicing heating appliances or providing adequate ventilation.
I would, of course, gladly replace the term 'negligible' by 'insignificant' in my contribution above - a term which the HSE are on record as saying describes risks that can usually be ignored. When we get round to recording and addressing the significant risks, I cannot imagine personal injury or death by fire within buildings as being excluded or that the provision of the normal control measures for these is not reasonably practicable.
Risk assessments need to be suitable and sufficient and published guides and codes do seem to indicate measures generally deemed to be of this nature. Departure seems a risky course to take or advocate.
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If the risks are ‘Tolerable’ or Broadly acceptable’, surely this is because steps have been taken to reduce these risks, so to continue keeping the risks low these steps must still be taken.
To use the carbon monoxide example, the death rate is low because rules are in place to ensure that appliances are serviced. To keep the deaths low servicing must be continued.
Hope this makes sense.
Dave
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If the risks are ‘Tolerable’ or Broadly acceptable’, surely this is because steps have been taken to reduce these risks, so to continue keeping the risks low these steps must still be taken.
To use the carbon monoxide example, the death rate is low because rules are in place to ensure that appliances are serviced. To keep the deaths low servicing must be continued.
Hope this makes sense.
Dave
Sorry to go off the topic for a min, Regarding the carbon monoxide bit, When it came to the news the terrible accident where those children lost their lives in Corfu back a couple of months ago, I thought, hang on a minute, (as this sad news gave me a kick up the backside) Im one of those who qualify for the well advertised "free annual, carbon monoxide checks" endorsed by the government, (available to Disabled or pensioners) I had not ever had a check before, so I tapped in to the relevant info web page and followed links to see how it could be arranged, it said to contact whoever supplies your gas to you, and they would sort it out,
Well to cut a long story short, after many many telephone conversations, It is only for Natural gas customers! and misses out the thousands of gas users who sadly live in areas where they have NO MAINS GAS available and have to rely on LPG, so lets think about this for a minute, what is one more likely to do with a portable appliance, (my personal lpg fire is fixed in the wall, but some peeps do have those wheeled ones with blue bottles in ) on low income, maybe someone confined to one room, yes exactly that! and its those people who actually are the more vulnerable and so more at risk! so I gave a lot of ear bashing to the people who are the regulaters of gas, and even one told me that LPG does not give off carbon monoxide, I obviously has a quick sticks apology when I asked to speak to their manager! but nevertheless, Until the government recognise that LPG has as important dangers as natural gas regarding carbon monoxide then its the same old chestnut,
One rule for one, and a different rule for another, no wonder we are all so confused to whats a risk and whats not....
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Portable heaters with gas cylinders within are a big concern because as you know they do not have a flue and there are no checks to ensure inlet air is provided in the rooms in which they are used.
All the products of combustion- mostly carbon dioxide and water vapour are discharged into the room leading to condensation. The instructions always say open a window- but how many do that whenever they are using the heater? Just a few years ago there were many deaths each year from monoxide poisoning.
If I recall one key factor was the condition of the ceramic radiant panel on the front of the heater, the gas was always intended to burn up the front of the ceramic panel, but these were mounted in a bed of fire cement which can crack and fall out. When this happens gas can burn at the back of the ceramic panel, usually accompanied by a popping sound. When this happens the heater gives off large quantities of carbon monoxide.
The moral of the story is not to use this type of heater in sealed rooms, and most important to have them inspected and serviced regularly. Do not use it at all if there are any cracks or gaps in the ceramic panel or if it makes a popping noise as it burns.
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Your Quite right Kurnal, I personally hate those wheeled portable heaters, (which we used to call a "super ser") but I used to know 2 old ladies in my area, who Did use these, and they stayed in the same room with them all day, with all doors and windows closed, (they are now in nursing homes) this was because it was the cheapest heating they could afford, as they regarded the electric storage heaters too expensive, and years ago we used to have loads of power cuts and the elderly couldnt take the risk of their heat sorce failing, even though I dont get out visiting anymore to "see" this still happening, I do not have a doubt that this IS happening in 100s if not 1,000s of homes around the country, who do not have the pleasure of mains gas, (I was so surprized to how many villages dont have mains, when I looked into it)
But my point was is that the government recognise that there is a need for advertise these free checks for the vulnerable, but to exclude LPG when (in my opinion) its these users are at the most risk ,is very very unfair and (again in my opinion) negligent!
Its ok for us to say that providing these heaters are serviced regularly they are ok, but in reality its down to money (peeps on low incomes) and then it comes down to hoping the vulnerable person actually has an "on the ball" visitor or relative that will actually organise a service and or Pay for it to be done!
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Bang on Donna.
Many Fire Brigades in conjunction with Age concern and other charities do free electric blanket checks for vulnerable people. If they find a defective blanket- usually around 40-50%- they give a voucher for a discount on a new one- or in some more unusual campaigns they replace them free of charge.
A campaign on portable heaters / LPG systems would be of equal value especially in view of what you say about the free safety checks. May be worth emailing a few environmental health departments and fire brigades to see what the current statistics for death and injuries are. Then targetting the charities that serve any particular groups identified as being vulnerable.
Most of the LPG based fixed installations will be in rural areas and of course whist rural poverty is less visible than inner city poverty, where it occurs it tends to be more extreme because of a lack of infrastructure and support services.
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I totally agree,
I did make a few phone calls, and tried to rattle a few cages, but I was (and still am) embroiled in another personal campagne, and I just had to "but it on the back burner" (pardon the pun) for a while as I was trying to do too many things at once...but it is something that I will follow up, Ive just got a few more weeks of (this DDA thing Ive got going on) another annoying campagne for fairness and justice to fight for, first.
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It's not just gas appliances with a CO risk, donna. Solid fuel burning will also produce CO when the oxygen supply starts to reduce (eg when chimneys and flues are not regularly swept). Ventilation is essential for all heating involving the burning of fuel. CO detectors can be useful but must not be a substitute for maintenance.
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I'm not sure that The Carbon Monoxide example is entirely relevant. Firstly, sticking in a CO detector is cheap; fire precautions can often require engineering that is far more expensive. Secondly the discussions above are on domestic installations - are there similar requirments for non-domestic installations?
Going back to Donna's other threads - could the approach outlined be used to justify not making provision for means of escape for people with mobility impairments? If a Responsible Person can demonstrate that their level of risk is in the Broadly Acceptable region without having any particular plans in place, does legislation demand that you do anything to reduce risk further? This is a potentially huge issue...
PS - Don't assume that I'm advocating this approach - I'm just putting it forward for discussion!
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I had a look at the RRO itself (not the Guidance) and there it states in Emergency routea and exits 14 (2) "The following requirements must be complied with in respect of premises ............in order to safeguard the safety of relevant persons. (b) in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible;"
This looks to me as if the legislation demands that the means of escape must be available to relevant persons ie anybody legitimately in the premises. It does not define any special cases ie mobility impairment. So the risk assessment arguement cannot stand, the magic ALARP phrase does not appear.
In other threads I know there has been the arguement about Stay Put Policy and Phased Horizontal Evacuation but nowhere has the issue been raised that these policies should replace adequate means of escape. As I have read it these practices are in addition to the MoE due to the particular features of the situation.
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Subject: Key Boxes
I recently inspected a new build HMO [ completed August 06 ] and found that some doors deemed by the Approved Inspector to be FIRE EXITS..were secured by keys in boxes. I recall from my FPO days that these arrangements were outlawed by the then HOme Pffice in the middle 1980's....anyone any comments.
Conqueror.
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Mike the reasonableness bit is there even if its not actually in the law - (a Government lawyer explained this to me)
As quickly as possible could mean a firemans pole (dont get smutty) next to every desk!
Conq - Keys are pretty much frowned upon - it makes you wonder if we should go back to prescription!
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The pole may be quick, Wee B, but hardly as safe as possible for most prospective users!
Do you know whether the key boxes were part of the CDM design or quickly retro-fitted by the users, Con?
I've had a few concerns about the Approved Inspector route.
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Key boxes are rather archaic and their use for fire routes always brings back the Woolworths & Summerland fire reports which frowned on them as being possible contributory factors to some of the deaths & injuries.
Sadly with respect to workplaces although a lot of the guidance uses the 'without resort to a key' type phrase the actual order IIRC doesn't when describing the basic duites re exits
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If the HMO is new build in Aug 2006 then AD'B' 2000 edition applies. Para 6.11 under door fastenings clearly says "...these fastenings should be readily apparent and without the use of a key..." So it seems that there is a breach of Bldg Regs in this case?
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Ahh, we are back to risk and assessment again. There may be a feasible reason for a scenario with the use of a key, for example a care home where patients abscond for whatever reason and all staff carry the key. I don't know about the rest of you but I lock my doors at home of a night, perhaps it is the area in which I live!
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Thanks for everyone who contributed to my observations on key boxes. Jokar if you read my narrative you would have known that it referred to HMO occupation by key workers......I don't subscribe to your example if workers carrying keys.......there are many other ways of securing doors without the use of keys.
Conqueror
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And we have the old issue that the ADs are not the actual Building Regs - even though there is a lot of reference around to key boxes not being 'acceptable'.
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I had a look at the RRO itself (not the Guidance) and there it states in Emergency routea and exits 14 (2) "The following requirements must be complied with in respect of premises ............in order to safeguard the safety of relevant persons. (b) in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible;"
This looks to me as if the legislation demands that the means of escape must be available to relevant persons ie anybody legitimately in the premises. It does not define any special cases ie mobility impairment. So the risk assessment arguement cannot stand, the magic ALARP phrase does not appear.
In other threads I know there has been the arguement about Stay Put Policy and Phased Horizontal Evacuation but nowhere has the issue been raised that these policies should replace adequate means of escape. As I have read it these practices are in addition to the MoE due to the particular features of the situation.
Mike: the bit that you missed out is important. The full quotation is:
"The following requirements must be complied with in respect of premises where necessary (whether due to the features of the premises, the activity carried on there, any hazard present or any other relevant circumstances) in order to safeguard the safety of relevant persons".
The 'where necessary' removes the (perceived) demand to provide the list of 8 risk reduction measures that follows. If you conclude that it isn't 'necessary' to comply with all the 'musts' and 'shall's you don't have to. This is at the core of the issue - there's lots of specifics in the legislation, but they are all modified by the 'where necessary' obligation. How do you work out what's 'necessary'? By means of risk assessment, consideration of good practice etc - hence my question. If you could prove that risk was broadly acceptable, could you legally get away without catering for means of escape at all, especially if disabled people were in your premises only infrequently?
I stress again - I'm NOT supporting this view -I am just seeking discussion on its legality!