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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Mushy on September 05, 2008, 08:49:25 AM
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Hi retired ex operational firefighter being asked fire safety questions again!
Someone in my village owns a detatched 2 storey 4 bed guest house with all the bedrooms on the first floor and kitchen, dining and communal lounge on the ground floor...unsure of the layout.
They had a chimney fire the other day (flue from cooker) requiring the attendance of the brigade...followed by a visit from a fire safety officer who issued a 28 day notice? to get a fire risk assessment done...which she has organised and to install a fire alarm system and emergency lighting (I'm astounded that no alarms fitted already!)
Could anyone please direct me to a guide with the standard required for guest houses...or if anyone else on here knows what fire alarm system and E/L is needed...I have told her that this would be flagged up on the FRA but she she would like to have some idea in advance
Thanks for your time
mushy
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Hi retired ex operational firefighter being asked fire safety questions again!
Someone in my village owns a detatched 2 storey 4 bed guest house with all the bedrooms on the first floor and kitchen, dining and communal lounge on the ground floor...unsure of the layout.
They had a chimney fire the other day (flue from cooker) requiring the attendance of the brigade...followed by a visit from a fire safety officer who issued a 28 day notice? to get a fire risk assessment done...which she has organised and to install a fire alarm system and emergency lighting (I'm astounded that no alarms fitted already!)
Could anyone please direct me to a guide with the standard required for guest houses...or if anyone else on here knows what fire alarm system and E/L is needed...I have told her that this would be flagged up on the FRA but she she would like to have some idea in advance
Thanks for your time
mushy
http://www.communities.gov.uk/publications/fire/firesafetyrisk4
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The sleeping risk guide in CLG as noted above. It is a free download as a pdf file. As regards the FA a part 6 system will suffice and EEL could be plug in removable lamps.
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You could also look at the LACORS guide which again is a free download from their website, I keep forgetting about it but it is very relevant to the premises you describe.
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http://www.communities.gov.uk/documents/fire/pdf/151339.pdf
That is the CLG guidance document.
28 days to install a fire alarm is way too soon. (Are you sure that she is not getting confused with the 21 days that is allowed to appeal the notice?) I would usually give 3 or 4 months to allow a reasonable time for quotes, then time for the actual installation itself. If there was no alarm system whatsoever then the inspecting officer should have got interim measures installed such as domestic detection throughout, strict practiced procedures, customers informed of action to be taken in the event of a fire etc. (1 month for a risk assessment is reasonable)
The standards have been discussed in other threads. The guidance describes a BS5839 Part 6, grade D, interlinked. Detection should be in the main escape route, and all rooms off the escape route. (With the possiblity of detection in other risk rooms) A manual call point at the main exit would be nice, although it is not a common requirement in a part 6 system. There should also be self closers on the doors. The actual standard of door is another point where opinions differ.
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http://www.lacors.gov.uk/lacors/upload/19175.pdf
That is the LACORS guidance Jokar mentioned.
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http://www.communities.gov.uk/documents/fire/pdf/151339.pdf
That is the CLG guidance document.
28 days to install a fire alarm is way too soon. (Are you sure that she is not getting confused with the 21 days that is allowed to appeal the notice?) I would usually give 3 or 4 months to allow a reasonable time for quotes, then time for the actual installation itself. If there was no alarm system whatsoever then the inspecting officer should have got interim measures installed such as domestic detection throughout, strict practiced procedures, customers informed of action to be taken in the event of a fire etc. (1 month for a risk assessment is reasonable)
The standards have been discussed in other threads. The guidance describes a BS5839 Part 6, grade D, interlinked. Detection should be in the main escape route, and all rooms off the escape route. (With the possiblity of detection in other risk rooms) A manual call point at the main exit would be nice, although it is not a common requirement in a part 6 system. There should also be self closers on the doors. The actual standard of door is another point where opinions differ.
The 28 days will be to get a FRA completed which im sure you will agree is perfectly reasonable. A finding of the FRA should be to have a FA system fitted which will be checked by th LA. I fully agree with this way of working, why are we being presrciptive so early on? It is their job to get the FRA done not for us to do it!
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I reckon 28 days is indeed a bit steep to get a AFD system & EL fitted. This leaves next to no time for the RP to shop around and get various quotes in, which I reckon is unreasonable.
As far as suggesting the RP should wait for the FRA to suggest that an AFD system is required, I am unsure about this. It will be obvious - even for us lot who have hardly any knowledge of this building- that some kind of detection & EL will be required.
If I were writing such a notice, I too would include the main 'headlines' - the most important requirements- on the schedule and leave the findings of the FRA to mop up all the other stuff.
If not included on the notice, there is a possibility of further delays installing a system. I would perhaps give three months or so to do the lot as a reasonable time scale.
In the event that the work is not completed on time, it would be very difficult for the RP to argue that the notice was unreasonable or there wasn't enough time
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Thank you all for your replies and the links.
It appears I have misinformed the forum by my wording, apologies for that. The 28 days notice was to get the FRA done I'm unsure of the time frame for the installation of the AFD and E/L....She said they asked for LD2 so unsure if that is BS5839 Part 6, grade D..I'll check the links
Do all the bedroom doors have to be fire doors and does it depend on travel distance whether there should be two way travel or a protected route?
edit: although once I read the links I suppose that will tell me...doh!
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LD2 is the coverage required, you need to find out what Grade of system they have suggested, possibly Grade D. All doors will offer protection against fire and with an upgraded fire alarm system you may not need tp replace them. Be wary the FRS inspectors in anumber of cases now are going way over the top in thier requirements which shoyuld be recommendations. The FRA should dictate what will be required on the grounds of ALARP, risk and proportionality, as well as cost effectiveness.
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LD2 is a part 6 system as I described. You could have different grades of system, grade D would generally be the lowest acceptable standard that an FRS might ask for.
It should be a protected route, and two way travel would only be possible with another staircase which would not be required in a 2 storey building. To follow guidance strictly then the doors should be FD30S self closing doors. This would protect the single escape route, and this should also mean that travel distance stops when you are out of your room and in the 'protected' route.
There would be a case to argue whether FD30S doors are appropriate in a particularly small building with limited travel distances. It's down to good old risk assessment. If the FRS are asking for FD30S but once the risk assessment is done it suggests FD20, or maybe that the present doors are substantial enough, then tell her to talk to the FRS about it.
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Be wary the FRS inspectors in anumber of cases now are going way over the top in thier requirements which shoyuld be recommendations.
What should be remembered is the structure of the notice. The initial section informs the RP what breaches there have been. i.e. Failed to meet article 13, No means of giving warning. The second should be very simple advice on what is required to satisfy the enforcement notice. i.e. Supply a suitable means of giving warning. (Duh!) The 'recommendations' bit should not form part of the notice, and is what we suggest could be done to rectify the problem. It should be made clear upon serving the notice that this section is NOT part of the notice, and that there may be other methods that ensure compliance.
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Civvy, without being rude, can you explain what" to follow guidance Strictly" menas. Guidance is exactly that and you do not have to follow it. It is not an ACOP or legislation that has to be followed and is definitely not strictly to be followed. It might be that I begin to understand why certain FRS officer and I am not including you in this, insist on certain elements that are written in guidance. The FRA should demonstrate compliance ith law and how to achieve Article 4.
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Exactly what it sounds like...
Get the guidance document for sleeping accommodation. Look up small B&B, and follow what it suggests strictly. The document says that all doors to sleeping risks should be 30min FR. It also suggests a grade D part 6 LD2 or 3. I would agree with anyone who says that this may not be appropriate in all circumstances, but the premises are pretty much mentioned by name and size (small, B&B) in the document with a specific solution.
Also, it is sometimes orders from above that the guidance documents will be enforced.
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Civvy, without being rude, can you explain what" to follow guidance Strictly" menas. Guidance is exactly that and you do not have to follow it. It is not an ACOP or legislation that has to be followed and is definitely not strictly to be followed. It might be that I begin to understand why certain FRS officer and I am not including you in this, insist on certain elements that are written in guidance. The FRA should demonstrate compliance ith law and how to achieve Article 4.
Jokar. Do you not think that there is an expectation that advise contained in an approved code of practic is adhered to? Codes are there to work around but certainly not to ignore.
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Exactly what it sounds like...
Get the guidance document for sleeping accommodation. Look up small B&B, and follow what it suggests strictly. The document says that all doors to sleeping risks should be 30min FR. It also suggests a grade D part 6 LD2 or 3. I would agree with anyone who says that this may not be appropriate in all circumstances, but the premises are pretty much mentioned by name and size (small, B&B) in the document with a specific solution.
Also, it is sometimes orders from above that the guidance documents will be enforced.
The jungle drums are saying that there is some movement afoot and further guidance in respect of the smaller B&B and specifically addressing proportionality is to be issued by the govt very soon ..................................(though it may be a case of send three and fourpence................)
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LD2 is a part 6 system as I described. You could have different grades of system, grade D would generally be the lowest acceptable standard that an FRS might ask for.
Civvy & Messy
It is worthy of note that there is an anomoly between the coverage of an LD2 system described in BS5839 pt6 and the coverage noted in the CLG guide. LD2 in 5839 says detection in escape routes ONLY (so none in rooms off) but the notes in the CLG guide state detection in escape routes AND rooms opening on to the escape routes. so make sure your risk assessment goes for the latter otherwise the FRS wont agree with the significant findings.
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The jungle drums are saying that there is some movement afoot and further guidance in respect of the smaller B&B and specifically addressing proportionality is to be issued by the govt very soon ..................................(though it may be a case of send three and fourpence................)
I think i have seen a copy of that document and it is mearly a few pages saying to the B&B sector yes it DOES apply to you and YES you will have to comply. i think the B&B sector were hoping for a let off or a document that said if you have domestic smoke alarms you will comply...........sorry carry out your fire risk assesment using the guides availabel from CLG.....
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Lets wait and see!
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Nearlythere, I agree that we should follow an ACOP but the guidnace documents are not that. Lets not forget that we are in a risk assessed methodology not prescription. Civvy, I understand that certain FRS are telling there officers to folow exactlywhat the guidance states but that is not risk assessment. It seems that whilst all signed up to the European directives and the RR(FS)O, FRS don't like it and want it changed. If that is the case then lets see CFOA challenging the Government's legislation across the UK not doing it in an underhand way and making guidance something else. After all, once BS 9999 gets published in October we will start having risk assessed travel distances of up to 90 metres and exit widths getting narrower, what happens to prescrition then?
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Civvy, I understand that certain FRS are telling there officers to folow exactly what the guidance states but that is not risk assessment.
I have said this a few times now. The places where the FRS's are insisting on the guidance standards will be premises that have been found as very sub-standard. They won't be the premises that have been risk assessed properly and sorted out prior to the inspection/audit. It won't be a case of arguing about a technical detail. It will be fixing the 3 storey premises with no protection to the stair and no alarm system.
If this is the case then why shouldn't someone pick the solution out of the book? Protect the stair, fit AFD as the guide suggests. Maybe it is not a sleeping risk, maybe strips and seals could possibly not be necessary... Why should an FSO strive to lower that standard, and then take responsibility for doing something that was the RP's responsibility?
It is worthy of note that there is an anomoly between the coverage of an LD2 system described in BS5839 pt6 and the coverage noted in the CLG guide. LD2 in 5839 says detection in escape routes ONLY (so none in rooms off) but the notes in the CLG guide state detection in escape routes AND rooms opening on to the escape routes.
d) Any requirement for a Category LD2 system (e.g. in a statutory notice issued by an enforcing authority
or in a purchase specification) should be supplemented by information regarding the rooms in which fire
detectors are to be installed (over and above the fire detectors in the circulation areas required to satisfy
the recommendations of this standard for a Category LD3 system).
Sounds to me like a LD2 system can indeed have detection in all the rooms off the escape route and still be classed as an LD2 system. We specify an LD2, then specify where the extra detectors go. It is still an LD2.
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After all, once BS 9999 gets published in October we will start having risk assessed travel distances of up to 90 metres and exit widths getting narrower, what happens to prescrition then?
BS9999 doesn't really give you risk assessed travel distances, it tells you exactly what the travel distance should be in specific scenarios.
i.e. People awake + familiar with the building, slow fire growth rate, high ceiling, sprinklers, over provision of AFD... Hey presto, there's your 90 metres 2 way travel and 2.7mm per person for door width. (This is just for example, don't go trawling through BS9999DPC just to find that it is 2.9mm, I don't really care enough :))
It could potentially be used in more of a prescriptive fashion that any of the other documents. Why should we alter any of the distances/widths etc in that document? They have done the working out for us/you. The differences in risk have already been accounted for in the document, why should the FRS give even 1 more metre than the document suggests?
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why should the FRS give even 1 more metre than the document suggests?
Hey what are the fire service giving? Its not their place to "give" anything.
As an RP its MY job to manage the risk and MY job to decide what is reasonable. Its the fire services job to police this and stop me from doing anything silly and bring me to book if I digress.
As RP and as an enforcer we may both look to the guides for a benchmark of what is reasonable and the way the Law is written if I want to significantly vary from the guide I may have to prove to the policeman that it it safe to do so.
If I can show that for my premises and activities that everyone can get out safely without being exposed to risk of injury - the time available for safe evacuation exceeds the time it will take for the tenability limits to be reached then as far as I am concerned the guides and travel distances can go in the bin.
Its not like speed limits on the road although a lot of enforcers treat it as such.
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Civvy, please do not think I am attacking you on a personal basis. You are the brave one from a FRS that puts his head above the water and staes what is going on. However, I reserve the right to disagree with some of the statements that you make as you do with me. The phrase you use " sub standard premises", what is the fire hazard, what is the risk to people from fire, what is the management of the premises like. These are things that the RP through an FRS should be addressing and then looking to guidance to look for the best outcome on the basis of ALARP. NOT and I repeat NOT being told by an FRS that they should have this that or the other. It may be the FRA and the enforcer have the same outcomes but often as not they will not. The other thing that I am slightly bemused about is the fact that we seem to treat all people as idiots and agian their not. In large complicated premises we have different scenarios but in a small premises I am sure that people who can book accommodation and arrive tat the destination miles from their own homes and find their way to bed and back to breakfast in the morning are able to get about. They are not mentally incompetent and whilst a smoke alarm is good value and a plug in torch will provide light should they need it, to have to provide fire door sets to BS 476 part 22 and 31 when the walls may not be a 30 min standard and destroy a house for what it really is seems ludicrous. After all Article 34 has responsibility on the RP not the enforcer. The other thing of course that for years now FRS have stated that in a 2 storey premises you can block the door with towels or something similar, shout out of a window and if necessary lower yourself by your hands to get out.
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As regards 9999, it is a risk assessed document, it states that right in the front pages, of course scenarios have to be met but that is risk assessment. Look at things like hazard, risk, risk management, ceiling height, numbers of people and anything else and make a judgement, the outcomes will be a risk asseessment.
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The other thing that I find strange is that on the announcement of the RR(FS)O, the Governmentwrote on the CLG website an FAQ. One of the questions was, what type of premises will FRS now look at. The answer and it should still be there is high risk premises only, What is high risk about premises like the topic that started this thread?
Are FRS trying to find work for their FSO's as most large premises are being run properly so we are now picking on the smaller ones of less risk? I do not see M&S or Sainsbury amang the prosecutions, afetr fire audits I understand as the RR(FS)O is basically a reactive H&S document but Lancs are proving that by picking on small business you can make a name for yoiurself and get written up in many areas.
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Jokar
The reason the fire safety officer went round to this small guest house was they had a chimney fire the night before and I presume he/she either went round on request of the crews or that it is standard practice to visit after a fire.
Can I just ask a couple of questions after reading the guide.
With automatic detection systems is it right that an LD2 grade A is a separate circuit to the electrical mains and LD2 grade D is the same circuit on battery back up?
Also if you have a two storey guest house with one route from the first floor to ground floor like this one...are you allowed to have an open staircase as long as all the doors off it are fire resisting...and is this classed as a protected route?
Is the travel distance from the furthest point in the bedroom to the final exit...and if so and if it exceeds the laid down distance in the guide...do you then need two ways out or can auto detection compensate for excessive travel...and what would you class as excessive
Whats a plug in or stand alone emergency light...is it a torch?
ok that's more than a couple :)
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An open staircase is exactly that, a staircase that is open to all floors it passes through such as in some small shops. If you then put fire door sets, thats the doors and associated frames into openings surrounded by FR structure then you have a protected route to the final exit. Travel distance is measured to the protected route as 1 way travel if there is only the 1 exit from a room. The protected route becomes a place of relative safety and therefore travel distance would end there. You can extend travel distance with additional ceiling height or with AFD. However, as AFD is needed in this type of premises then it can not be used as a compensatory feature as it can not compensate for something as it has to be there.
A Grade A part 6 system is almost a BS5839 Part 1 commercial system with a few differences that are highlighted in BS 5839 part 6 as regards height of call points, sound levels and a few other bits. A grade d ld2 system to Part 6 would be more than siutable in this situation with hard wired smoke alarms and a battery back up.
Have you read the LACORS guide, does it assist this situation?
A variety of companies provide a plug in torch which is permanently on charge to be used in an emergency situation
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Mushy,
Does this help:
BS 5839: Pt.6 grades fire detection systems from Grade F up to Grade A. Generally speaking, the greater the fire risk and the more demanding the application, the more comprehensive the system needs to be.
Grade F - System of one or more battery powered smoke alarms (and heat alarms if required)
Grade E - System of interlinked mains powered smoke alarms (and heat alarms if required) with NO stand-by supply. The interlink can be hardwired or radio-interlinked. Please note that Safelincs Ltd will not distribute Grade E alarms, as we only recommend alarms with backup batteries.
Grade D - System incorporating one or more interlinked mains powered smoke alarms (and heat alarms if required), each with an integral stand-by supply. The interlink can be hardwired or radio-interlinked.
Grade C - System consisting of smoke detectors and sounders (which may be smoke alarms) connected to a common power supply, comprising normal mains and stand-by supply, with central control equipment
Grade B - Fire detection and alarm system comprising fire detectors (other than smoke alarms), fire alarm sounders and control and indicating equipment to either BS EN 54-2 (and power supply to BS EN 54-4), or to Annex C of BS 5839: Pt.6
Grade A - Fire detection system incorporating control and indicating equipment to BS EN 54-2, and power supply to BS EN 54-4, installed to BS 5839: Pt.1 with some minor exceptions
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Thanks Jokar and Paul the info is appreciated.
jokar have I got this right the way you describe a protected route
If a staircase is open...by that I mean similar to a domestic house whereby there is no enclosure of the staircase..ie no fire door at the top and bottom..then it is still a protected route if all doors off it are fire doors?
I only ask because I looked up protected route in a building control guide and it says that the only facilities off a protected stairway should be sanitary accommodation or wash rooms, a lift well, a reception desk or enquiry office at ground level...I probably read that wrong!!
Thanks for the Lacors tip
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Mushy, look at it this way. A shaft running through the building from top to bottom and the openings in it are doors that lead from the accommodation to the stairs. In a commercial office type building with 1 staircase the accommodation can not deliver straight to the stairs apart from the uppermost floor, it will need 2 door protection which in most cases will be a lobby. In sleeping accommodatio, hotels/hostels etc this is still the case although the room doors should be fire doors entering a protected area which could be a protected corridor and then only one door to the staircase will be required. ( the door to the bedroom providing the 2nd door protection)
In your domestic property most people would accept that the room doors leading on to the stairs would need no added protection at the uppermost level and probably not at the lower level either as space is normally at a premium. ( I have no idea of the size of this property). In addition at ground level you may have additional methods of escape to a garden area which hopefully goes to a place of safety through patio doors and kitchen doors.
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Thanks jokar...which means then in this 4 bed 2 storey guest house you are not allowed to come out of your room and into a corridor that leads direct to a staircase unless that staircase has a Fr door at the head...thereby being two door protected
Also looking at BR guidance...a commercial office type situation can have a single stair of two floors without two door protection...but that digresses...thanks again
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No, the upper floors do not have to have 2 door protection and it would be most unusual to find 2 door protection in a 2 storey building.
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sorry mate I thought you meant what you said below was for this guest house...ie 2 door protection..one from bedroom and the other to the staircas
"In sleeping accommodatio, hotels/hostels etc this is still the case although the room doors should be fire doors entering a protected area which could be a protected corridor and then only one door to the staircase will be required. ( the door to the bedroom providing the 2nd door protection)"
so they can come out of their bedroom that has a fire door and walk to the staircase that is open to the corridor....and walk down the stairs and out of the exit...as long as all the rooms leading to the staircase at ground floor are fire doors
I'll go and lie down
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Civvy, please do not think I am attacking you on a personal basis. You are the brave one from a FRS that puts his head above the water and staes what is going on. However, I reserve the right to disagree with some of the statements that you make as you do with me.
I never took it as a personal attack Jokar. If there was a tone to my post that suggested I was on the defensive then I apologise. I don't actually agree with half of what I actually put (re: Why should we vary by even 1m etc) I was just making a point. :) I am all for solutions on a risk assessed basis. If something is not needed to keep people safe then it is simply not needed.
Hey what are the fire service giving? Its not their place to "give" anything.
As an RP its MY job to manage the risk and MY job to decide what is reasonable. Its the fire services job to police this and stop me from doing anything silly and bring me to book if I digress.
Indeed Kurnal. The type of RP/premises I talk about in these instances are the type where you as an RP had done little or nothing, the premises is rather dangerous, and it needs bringing up to a standard. The first thing I should be doing as an enforcer is seeing what guidance issued by the secretary of state says. and possibly suggesting that to the RP via advice accompanying the enforcement notice.
In this instance, why should I put my neck on the line by lowering standards when it is not my responsiblity? I am going to leave the bare minimum to 'good management and housekeeping etc' as the RP has already proved to me that they are possibly not capable of managing a premises safely.
As soon as we are looking at enforcement our advice given puts us in a position similar to a consultant. If there was a problem and we got it wrong the RP's defence would be "This is what the fire service told me to do". My only reasonable defense there is "This is what the guidance suggests". It takes a fair amount of experience and competence to veer from the guidance, some people are not confident enough to do it, some are possibly not competent enough.
I think where we often get off on a wrong foot here is that when we (The FRS) talk about enforcing standards other people imagine us coming into THEIR premises or somewhere they have already assessed and making them alter the standards to suit the guidance. This would not be the case unless it was truly warranted due to some error.
I might have said this before. but ideally what we should do is simply enforce the risk assessment. Give 1 month for completion and then (providing it is suitable and sufficient) enforce what the risk assessment says is necessary.
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Indeed Kurnal. The type of RP/premises I talk about in these instances are the type where you as an RP had done little or nothing, the premises is rather dangerous, and it needs bringing up to a standard. The first thing I should be doing as an enforcer is seeing what guidance issued by the secretary of state says. and possibly suggesting that to the RP via advice accompanying the enforcement notice.
In this instance, why should I put my neck on the line by lowering standards when it is not my responsiblity? I am going to leave the bare minimum to 'good management and housekeeping etc' as the RP has already proved to me that they are possibly not capable of managing a premises safely.
I might have said this before. but ideally what we should do is simply enforce the risk assessment. Give 1 .
As usual Civvy we huff and puff and end up agreeing with each other. ;)
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[It is worthy of note that there is an anomoly between the coverage of an LD2 system described in BS5839 pt6 and the coverage noted in the CLG guide. LD2 in 5839 says detection in escape routes ONLY (so none in rooms off)
Not quite, In BS 5839-6 Clause 8 "Categories of System" LD2 is described thus:-
a system incorporating detectors in ALL circulation spaces that form part of the escape routes from the dwelling, AND in all rooms or areas that present a high fire risk to occupants.( then refering you to Clause 4 on fire risk assessments) For example Clause 8.1.2, an LD2 might have detectors only in the circulation areas of the dwelling,the living room, and the kitchen, other areas might be left without detecor coverage.
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If I can show that for my premises and activities that everyone can get out safely without being exposed to risk of injury - the time available for safe evacuation exceeds the time it will take for the tenability limits to be reached then as far as I am concerned the guides and travel distances can go in the bin.
Hi Prof Kurnal, am I reading this bit rightly or wrongly, it seems to me that its back to front the bit about
"the time available for safe evacuation exceeds the time it will take for the tenability limits to be reached" ??? do you not mean "the time taken for tenability to be reached must exceed the time taken for safe evacuation???, or is that what you are actually saying, (and I've got it all wrong)
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No right you surely are. To Yoda my sentence sense would make but every one else surely will be mystified.
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With a LD2 grade D is there a need for call points?
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According to the BS:
Generally, the incorporation of manual call points in the fire detection and fire alarm system will only be
necessary in certain dwellings that warrant the provision of a Grade A or Grade B system. Manual call
points can, however, readily be incorporated within a Grade C system. Grades D, E and F systems normally
have no facility for incorporation of manual call points, nor are manual call points necessary in the types of
dwelling for which these Grades of system are suitable.
Basically no, not on a grade D, although I have seen them on grade D systems.
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Thanks CivvyFSO.....it's appreciated
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Has anybody got a copy yet of the new FPA guide to Fire Risk Management in Hotels and Guesthouses, and does it offer sensible solutions, ie could we recommend it to our friends in the trade?
Its only 15 quid
davo
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Has anybody got a copy yet of the new FPA guide to Fire Risk Management in Hotels and Guesthouses, and does it offer sensible solutions, ie could we recommend it to our friends in the trade?
Its only 15 quid
davo
Davo
If you lend me the 15 quid I will buy it and tell you.
The fire safety order guidance is comprehensive and at 147 pages approx is a step too far for most hoteliers.Add to this the guidance on persons with special needs. The RRO guidance document also still refers to the old HO FP Act guide to management as a useful document.
IMO theres probably not much new info that could be put in but the older guidance may be hard to get hold of.
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Can anyone please tell me why a linen cupboard has to be half hour fire resistant and kept locked shut?
This particular one is apparently in this guest house on the stair landing
If there is nothing in there but linen on shelves...is it going to spontaneously combust?
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First reason is that 44% of all fires are caused by arson. ( old figures from 2003 but all I had to hand)
Remember the concept of a "Protected Route"- we stop counting travel distances in a protected route, there are important limits on travel distance elsewhere. If we need a protected route we must ensure that it is a sterile place free of fire risk, with wall and ceiling linings controlled. If you are looking at a small building and can meet the travel distances from rooms direct to final exits you could afford to be a little more relaxed. But always remember - a fire in a room threatens the occupant in the room and their imediate neighbours. A fire in a staircase threatens everybody on the upper floors. Risk = Liklihood x consequence.
Finally lets not forget that the Rosepark fire started in electrical equipment within a linen cupboard.
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Thanks Kurnal
I understand the theory and believe me I also understand arson...however if an arsonist was going to set a fire he/she would leave the door open anyway...so being a fire door wouldn't make any difference...this particular cupboard is used purely for linen with no electrical equipment.
I can fully understand the concept of occupied rooms or rooms which could have an ignition source such as electrical cupboard being fire doors...that to me is a given...but if it's just linen?
It just seems in assessing the fire risk there are still some parts of it that wont budge
Thanks again for the replies to this thread
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Can anyone please tell me why a linen cupboard has to be half hour fire resistant and kept locked shut?
This particular one is apparently in this guest house on the stair landing
If there is nothing in there but linen on shelves...is it going to spontaneously combust?
It has been known and documented. Linen freshly out of a dryer, nice and warm and dry. It only takes a combination of this heat/dryness/residue from cleaning fluids/oils etc and you can have a problem. It is a reasonably well known scenario in the dry cleaning trade.
If you want some idea of how it happens, the next time you have a load of hot towels come out of a dryer, quickly fold them and stack them on top of each other, put your hand in the middle of the pile, then press the pile down. (And don't blame me if it hurts.)
If it was opening into another room that wasn't anyones escape route then I wouldn't be too concerned, but the example you give where it opens into a stair then it would be quite clear that it should be required as Kurnal points out.
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http://news.bbc.co.uk/1/hi/scotland/3463401.stm
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No Mushy I think you are right. Consider the circumstances of the case, is it the only route out of the building or are there alternatives, are the doors a good fit and there is no danger of lighted materials being pushed past any gaps in the door, size, ignition sources, laundry procedures as civvy points out , if you have done all this and recorded your reasoning and decision in the risk assessment then job is done and your decision is valid.
One problem with a forum is none of us but you can see the whole picture so we err on the side of caution.
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Ok on the say so of the FSO she is going ahead with the fire alarm system, emergency lighting on escape routes and fire doors to the four bedrooms and stairway...the fire risk assessor goes in on Monday... probably as the work is being done!
Seeing that the two owners live on the ground floor and there are no other staff and they know their own house...what training will need to be done...probably how to use the fire extinguishers? Do they have to do a full evacuation of guest every so often?
Has the owners safety got to be taken into account under the RRO?....ie she says that their bedroom is next to the kitchen that doesn't have a fire door on their side of the accommodation
She told me yesterday that there are no disabled people as guest because the bedroom layout on the first floor and the stairway is not suitable....is this against the DDA...ie does she have to adapt her guest house to cater for disabled under the DDA?
I know all this will all be flagged up on Monday but just wondered on your opinions :)
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So many questions, far too much time on my hands...
Training: They should familiarise themselves with the contents of the risk assessment. Just reading through it properly might shed some light on things they might not have understood. (provided it is done to a reasonable standard) As far as actual training goes, in this sort of instance I would suggest having good procedures in place, so they know exactly what they will do if there is a fire. i.e. Raise alarm, phone 999, attempt to help guests out if required, location of assembly point)
Extinguisher familiarisation always helps, hands on training is clearly better, I am sure you could help them with that one.
If they have guests that are willing to take part in a drill then they might aswell take advantage of that, otherwise I am sure that discussing what they will do between themselves would suffice. RRO does say that drills should be done, but this could be quite informal in this instance. (A couple of "fire action" notices dotted about are a constant reminder to them what should be done, in fact stick one on the back of the toilet door, you have a captive audience. ;))
What we really need to avoid is the pandemonium that tends to happen when something like a fire happens and people do not know what to do.
The owners safety does have to be taken into account under the RRO. Their private part of the building should be classed as domestic, however they ARE relevant persons and that means they still need protecting from a fire in the rest of the building. (which the new alarm system should do quite adequately provided they have sounders in their part)
If we can class their bedroom and the kitchen as domestic then the kitchen door scenario isn't as bad as it might sound. Look at any studio apartment, you are sleeping in the same room as the kitchen. Provided they do not have to travel through or past the kitchen to escape this could be easily covered by grade D smoke detection in the escape route. (If it is truly domestic then we can't require anything, but they should really have some form of detection for their own sake)
As far as DDA goes, you/they are expected to make 'reasonable adjustments' to accommodate disabled persons.
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THE FRS has also a duty as a public authority under DED to inform people if they are not in complinace with DDA.
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Thanks for taking the time to answer Civvy...promise no more questions....
I'll let her know about the DDA requirements...spoke to her last night and there is no room downstairs for a bedroom to accommodate a wheelchair bound person so unsure how she can conform to make reasonable adjustments
yes you are right...after 25 years operational I might be able show them how to use an extinguisher :)
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Mushy, be careful disability is not just about wheelchair users, the definition includes physical and mental impairment. In the case of the nice fire alarm system the people are having installed beacons may have to be a part of that RA scenario. Those with hand impairments may have difficulty in opening some doors so the detail in BS8300 as reagrds door opemning pressures needs to be ensured. Too many thouights, too many ways to be caught out.
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Can anyone explain to me how a FB can approve a 28 bedroom hotel in essex that has NO fire doors on bedrooms and HDs only
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Can anyone explain to me how a FB can approve a 28 bedroom hotel in essex that has NO fire doors on bedrooms and HDs only
Contact essex fire and rescue service and ask them about the circumstances of the case im sure you will find that there is more to it than what you have said
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Can anyone explain to me how a FB can approve a 28 bedroom hotel in essex that has NO fire doors on bedrooms and HDs only
Contact essex fire and rescue service and ask them about the circumstances of the case im sure you will find that there is more to it than what you have said
What you hinting at Izan?
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Can anyone explain to me how a FB can approve a 28 bedroom hotel in essex that has NO fire doors on bedrooms and HDs only
Contact essex fire and rescue service and ask them about the circumstances of the case im sure you will find that there is more to it than what you have said
What you hinting at Izan?
I'm hinting that each case is different there may very well be a situation that has arisen where there could be a solution to why there are "no fire doors on bedrooms and HDs only" and these GFP have been applied to this premises based on the findings of the FRA. But unfortunately Davidhr thinks that if one can do it so can everyone but the GFP needed for each premises may be different. SO ask Essex FRS and ask what is so differnet about this premises.
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I know it's difficult to get a mental picture of this place and I'm not too much help as I've never been there... but this is how it has been described to me last night in the pub!.... there are 4 bedrooms 2 situated at the top of the staircase (within it) and two within a communal area on the first floor just off the staircase. All bedrooms are having fire doors fitted
When you come out of these latter two bedrooms there is this a communal area than leads directly to what will be a protected staircase that leads directly to outside...
The communal area has two leather chairs, a fabric bench seat type thing, an oak coffee table and some magazines to read and that's it...the ceiling is wooden strips placed directly on to the original plasterboard ceiling
All fabrics are current BS standard
A LD2 grade D alarm system will be installed
Now the Fire Officers notice has apparently quoted a passage out of the sleeping guide
"All corridors serving sleeping areas should be protected routes with 30 minutes fire resistance."
Is the communal area classed as a corridor because it leads to the protected stairway and if so does it have to be cleared?
The TD is within the limits to the protected stairway
Does the wooden ceiling need a flame retardant coating?
I know I know I said no more questions..:)
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Contact essex fire and rescue service and ask them about the circumstances of the case im sure you will find that there is more to it than what you have said
What you hinting at Izan?
I'm hinting that each case is different there may very well be a situation that has arisen where there could be a solution to why there are "no fire doors on bedrooms and HDs only" and these GFP have been applied to this premises based on the findings of the FRA. But unfortunately Davidhr thinks that if one can do it so can everyone but the GFP needed for each premises may be different. SO ask Essex FRS and ask what is so differnet about this premises.
Absoultely correct Izan
DavidHr to put it in context - it's rather like me walking into your guest House and asking " Why are you charging £30 per night when the Guest House down the road is only charging £25?" Well there are probably several valid reasons why.
Likewise you will find that there will be several valid reasons why different fire precautions have been accepted at the other guest house you refer to.
It does not infer or imply however that those precautions are acceptable across the board. Furthermore in the example you mention there may be additional factors that were required as compensatory features.
Its very difficult for us on the forum to summise why that particular hotel in Essex has been accepted with theprecautions you describe. Without knowing the full facts or seeing the premises we would simply be guessing. I appreciate David you are only asking legitimate questions, want a level playing field and are trying to understand fire safety a bit more.
The best thing to do would be to contact Essex Fire and Rescue Service and see if they will give you any information.
Risk assessment means that there will never be total consistency. The business sector did not want prescription and must accept therefore that each building will be assessed individually and will require individual solutions .
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Of course it mat be that the FRA was told by the trading arm of Essex FRS and therefore the IO did not want to challenge it.
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It may or it may not...
But we don't know the findings of the FRA, Jokar... how do we know they aren't acceptable?
I'm not by the way advocating or defending brigades who set up a trading arm selling fire risk assessments. Personally I don't think that is right.
But even still, we don't know the full facts about that individual case and as "IzanFSO" points out just because certain GFPs have been accepted in one individual building doesn't mean to say they will be acceptable elsewhere.
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I quite agree, ther are many engineered solution premises out there that do not meet the norm of fire safety. However, you have a business person who can not understand why apples and pears are different when an FRS are telling him that they are. All relies on a good FRA but even when RP's have one some FRS staff say "who cares" you will do what I want. Obviously not in the case of Essex who have taken a different line, whatever this premises are.
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I suppose my last two questions were two too much :)
cheers anyhow your help has been appreciated.... so no more questions on this soddin guest house
oh apart from what's the procedure and timescale for testing a LD2 D automatic detection system with no call points :D
gets coat
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I know it's difficult to get a mental picture of this place and I'm not too much help as I've never been there... but this is how it has been described to me last night in the pub!.... there are 4 bedrooms 2 situated at the top of the staircase (within it) and two within a communal area on the first floor just off the staircase. All bedrooms are having fire doors fitted
When you come out of these latter two bedrooms there is this a communal area than leads directly to what will be a protected staircase that leads directly to outside...
The communal area has two leather chairs, a fabric bench seat type thing, an oak coffee table and some magazines to read and that's it...the ceiling is wooden strips placed directly on to the original plasterboard ceiling
All fabrics are current BS standard
A LD2 grade D alarm system will be installed
Now the Fire Officers notice has apparently quoted a passage out of the sleeping guide
"All corridors serving sleeping areas should be protected routes with 30 minutes fire resistance."
Is the communal area classed as a corridor because it leads to the protected stairway and if so does it have to be cleared?
The TD is within the limits to the protected stairway
Does the wooden ceiling need a flame retardant coating?
I know I know I said no more questions..:)
They got lost in the thread Mushy.
You need to decide whether the common area is a protected corridor and therefore part of the exit route in stage 2, or a room - in which case your bedrooms are inner rooms and then we have a problem. If its a protected corridor it should be sterile and have surface finishes to class O in the ideal world.
Your risk assessment will have to recognise the weaknesses and incorporate measures to reduce the level of risk as far as is reasonably practicable - in the most extreme this could mean removing the ceiling lining and keeping the area sterile, or minimising the combustible materials, eliminating ignition sources and leaving the ceiling as it is. We would all have different views on what may be reasonably practicable.
Testing and maintenance- educate the user to test the system weekly by operating all devices. If the building is unoccupied for a period, test the system on return.
Clean the detectors periodically in accordance with the manufacturers instructions. (usually an annual hoovering but more frequently in dusty conditions)
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what's the procedure and timescale for testing a LD2 D automatic detection system with no call points
Hi Mushy
The BS recommends for systems other than Grade A, that the user carries out weekly tests by operating all alarm sounders, this may be accomplished by using the test button.
For Grade D systems, where deposits of dust or dirt are likely to accumulate before detectors are cleaned or changed at frequencies recommended by the supplier, more frequent cleaning or replacement should be carried out.
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Thank you Kurnal and Ricardo
She has since told me that the fire authority are a bit uppety about this communal room...mainly because of a bookcase in the corner that is used for guest to read while in there ( the books not the bookcase :) )
She has now bought the sleeping guide! ....and is saying that an access room can be allowed as long as it has smoke detection..which it will have....she is also saying that this is not a corridor but a room
Oh the joys of being an ex firefighter :(
I'm not sure what the chap who is carrying out the FRA is saying...maybe she should just go along with him!!
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She has now bought the sleeping guide! ....and is saying that an access room can be allowed as long as it has smoke detection..which it will have....she is also saying that this is not a corridor but a room
Yes the guide does say that and it is wide open to interpretation. I believe it was intended to cover some existing hotel suites where the access room is in the control of the person in the inner bedroom, it is still most undesirable but it does not say that.
So we cant criticise someone for taking the guidance on its face value. Or can we?
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She has now bought the sleeping guide! ....and is saying that an access room can be allowed as long as it has smoke detection..which it will have....she is also saying that this is not a corridor but a room
Yes the guide does say that and it is wide open to interpretation. I believe it was intended to cover some existing hotel suites where the access room is in the control of the person in the inner bedroom, it is still most undesirable but it does not say that.
So we cant criticise someone for taking the guidance on its face value. Or can we?
Think this point was discussed in the past. The definition of a corridor.
Can a corridor be a long narrow room? Can a room be a short wide corridor?
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Thanks all
news just in...
Although the Notice stated that 'all corrodors serving sleeping accomodation should be a protected route with 30 minutes fire resistance'...a straight pull from the guide...
the fire risk assessor is saying that he is going to put in his FRA that this is not a corridor but an access room with minimal contents and therefore his assessment is that he considers it acceptable
as I've said there are two leather chairs, a coffee table a chaise longue and two bookcases and there will be auto detection
We'll see which way this one goes
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Just a mut point, I have just returned from Austria and stayed in a typical tirolean hotel. The doors to the rooms were pine panelled with no s&s or s/c devices. The staircases were not fitted with doors and whilst detection and warning were mentioned I ailed to spot any of this. EEL and 1996 signs were about. The point is, did I feel unsafe in this environment with a full smoking hotel, made me cough and choke too much, and open kitchen /lounge through all the floors of the hotel.
Forgetting the legislation for a minute, the assessment of risk was much different with a much higher fire hazard rating and a much higher fuel load than a traditioanl B&B, guest house or hotel in England and Wales which are assessed as a much higher risk.
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Did you feel unsafe jokar?
The latest on this guest house is that the assessor and fire officer met and the outcome is that with the minimum of furniture and auto detection in the communal room it is allowed to stay as a communal room complete with bookcases.
The assessor classified the risk as high as it stands but says that with all the alarms and fire doors etc this will go down to a medium/normal
when you assessors are doing a FRA is the high/medium/ low (or whichever way it's classified) the risk of a fire starting or the risk to people should a fire start....or both?
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No, I did not feel unsafe at all. Assessors should be doing both which when you come down to it the, in my humble opinion, overprovision mentioned in this post, may not be abpout fire hazard and fire risk but property protection which is quite different.
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jokar
sorry mate I'm unsure what you mean
are you saying the need for LD2 Grade D and fire doors to bedrooms and the single staircase in the guest house that I'm talking about is over provision?
Probably got you wrong...tis been a long day
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Grade D LD2 is great. Whether or not proper fire doors are required in the situation you have is debatable. However, the FRS and the assessor have agreed that they are and there you have it. The whole thing with fire risk assessment is about assessing the fire hazards, the ignition sources, the o2 and the fuel loading and then assessing the risks of a fire occurring against the risk to people from the probability of this event. When you decide that their is a probability then you require some control measures in place to protect the people. If you have no smoking, electrics tested and good housekeeping then I am unsure of what the other ignition sources are there, O2 is that in the atmosphere and the fuel loading is what it is. The assessment then is the probability of exception and the control measures you need for that event.
This is the difficult part for lots of us; what measures are required in smaller type premises?
Early detection and warning so that people can escape before a conflagration. Enough protection for the escape route to enable people to leave once detection and warning have taken place, that may have been the existing doors in they were a good fit, and some level of lighting to see your way out, which may have been normal lighting.
My picture of what you have may be different to othersof course and the solutions different as well. The very easy bit for FRS and Assessors is the fall back to guidance as prescription and make sure that each premises fits that.
As a by the by, CLG are to issue a new guide for small B&B's, I wonder what will be in that?
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Jokar
when is this new guide coming out?
I spoke to the lady who owns the guest house on the phone tonight and wrote a few things down that she said
The guest house has 4 bedrooms...2 in the staircase enclosure itself on a half landing and two more within a communal room on the first floor. There is also a storeroom/immersion heater and bathroom on the stair landing.
On the ground floor off the staircase is the owners lounge on one side and guest dining room with kitchen on the other side...they also have a bedroom next to the kitchen
she told me that she had spoke to at least 60 other guest house owners recently and they are all appalled at the level of fire safety insisted by the fire authority and within the FRA...although she says they haven't been 'collared' by the fire authority yet or had a FRA done.
she is about to spend £5000...this may be a slight exaggeration I don't know....on an LD2 D system (detector in each bedroom, staircase and rooms off the staircase and kitchen...total of 9 x detectors) 8 x fire doors, 3 x emergency light units 2 x fire exit signs and 1x fire extinguisher
If this new guide states that the fire safety should be less I'm sure she may take court action
I found your theory on a small B&B fire safety standard interesting...the only ignition source at the moment are electrical equipment, cooking (grill) and the possibility of arson
she has bought a sleeping guide and she said she thinks that the FA notice and FRA was done with page 97 and figure 49 in mind
This new guide will be very interesting!!
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Get her to speak to the B&B Association as they are pushing Ken Knight to deal with this.
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The new guide has been produced and is currently with key stakeholders- eg fire brigades for consultation. I would suggest that she holds fire and asks for an extension to the notice - ask them to extend till the guidance is issued + 4 weeks- or for advance sighting of the guidance as the brigade or region have a draft copy. That surely is reasonable .
Look it isnt surprising that the fire service notice looks like figure 49- thats the official national guidance. If your landlady has previously done nothing to manage the level of fire risk for herself then who can criticise the brigade for applying the guidance? Thats what its for. The RRO says that its for the Responsible Person to manage the fire risk and to take suitable and sufficient general fire precautions to reduce the risk ALARP. If she has done nothing then she is asking for a prescriptive response. If on the other hand she had carried out a risk assessment then the fire service would be obliged to consider its strengths and weaknesses.
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Well what do you know jokar
The FA have just rang my friend to let her know that they will relax the need for any fire doors as long as the fire alarm is installed. They must have read your post! :)
Either that or maybe this new draft guide is the reason behind it
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Well what do you know jokar
The FA have just rang my friend to let her know that they will relax the need for any fire doors as long as the fire alarm is installed. They must have read your post! :)
Either that or maybe this new draft guide is the reason behind it
What catagory of FA system Mushy?
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Just seems to be common sense and completed with due regard to the fire hazards and fire risks. Mind you if others in similar circumstances get a competent person to undertake a proper FRA for them perhps the FRS may not come down so heavily. Unfortunately, the legislation is there and all have to be part fo it.
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What catagory of FA system Mushy?
Its an LD2 Grade D
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Get her to speak to the B&B Association as they are pushing Ken Knight to deal with this.
Any more on this Jokar?
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No, I have not seen a copy as yet. I am sure that the B&B Association will announce it with trumpets blazing.
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No, I have not seen a copy as yet. I am sure that the B&B Association will announce it with trumpets blazing.
Sure will. I can just imagine they won't want to miss the opportunity.
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Have a read of this, a briefing note to the Fire Minister from the B&B Association.
Impact of Inconsistent and Disproportionate Implementation
of the RRFSO on the Tourism Accommodation Sector
BRIEFING NOTE
To: Parmjit Dhanda MP, Fire Safety Minister
17 July 2008
We (David Weston, Chief Executive, Bed & Breakfast Association, Andy Woodward, Chief Executive, Farm Stay UK, Martin Sach, Chief Executive, English Association of Self-Catering Operators and Bernard Brindley, Vice Chairman, British Institute of Innkeeping) represented accommodation owners at a meeting on 1st July at DCLG (at which Pam Bunston represented DCMS), which gave feedback on a new, more user-friendly leaflet for small accommodation providers about their responsibilities under the Regulatory Reform (Fire Safety) Order 2005 (“RRFSO”).
We support the new leaflet, but feel that the main issue which needs addressing by DCLG is guidance to Fire and Rescue Authorities, not to accommodation providers (where DCLG’s own research showed 86% awareness already of the need to do a fire risk assessment).
The large number of representations we have received from small accommodation providers make it clear to us that:
• There is very wide inconsistency between different fire departments in their approach to accommodation owners; for instance, for the smallest "domestic" properties some fire departments are happy with hand torches and some "demand" commercial-type emergency lighting systems (this is just one small example amongst many we could quote)
• Some fire departments are adopting a very prescriptive approach, against the express intentions of the RRFSO
• Some fire departments seem to be "enforcing the guide", which has no legal status, rather than recognising that the owner has fulfilled his responsibilities by carrying out his own "suitable and sufficient" Fire Risk Assessment (FRA) and (only if they have 5 or more employees) to record their FRA, and then in the light of their FRA to make appropriate fire safety arrangements
• There is often no recognition that many of the premises concerned are primarily domestic premises
• There is all too often little heed taken of the RRFSO's emphasis on proportionality, ie low compliance burden for the smallest domestic and semi-domestic premises
It is important to remember that the Government intended the RRFSO as a deregulatory measure, bringing in a new self-assessment regime to replace the old "Fire Certificate" regime. It is expressly not intended to place onerous new burdens on businesses or render whole categories of small businesses economically unviable. The Order states that "the Secretary of State is of the opinion that this Order does not remove any necessary protection or prevent any person from continuing to excercise any right or freedom which he might reasonably expect to continue to excercise".
Unlike the old (1971) regime, it is not prescriptive - ie the new regulations do not oblige any owner to put in any specific fire precautions. Rather, they oblige every owner to carry out their own "suitable and sufficient" Fire Risk Assessment (FRA), and (if they have 5 or more employees) to record their FRA, and then in the light of their FRA to make appropriate fire safety arrangements, having regard to the size and the nature of their business.
The RRFSO is very specifically intended to be proportionate, ie to fully take into account the size and nature of each business; it requires owners to take "such general fire precautions as may be reasonably required in the circumstances of the case" (Part 2, Section 8.1.b). These (fire safety) arrangements must be "appropriate, having regard to the size of [the owner's] undertaking and the nature of its activities" (Part 2, Section 11.1). The words "so far as is reasonably practicable" appear three times in section 12, as does "appropriate to the nature of the activity or operation".
In section 13 (Fire-fighting and fire detection), the Order requires the owner to provide fire-fighting equipment "to the extent that it is appropriate" - and this is further clarified as "having regard to the dimensions of the premises, the equipment contained on the premises, the physical and chemical properties of the substances likely to be present and the maximum number of persons who may be present at any one time" (in the small B&Bs not previously subject to the 1971 requirements, for instance, the number present will be between one and six people, apart from the family whose domestic premises these are).
In the light of all the evidence since October 2006, it is clear that DCLG need to give strong and clear guidance on all this to fire departments, to ensure that the RRFSO's key principles of deregulation, lighter burden, and proportionality are followed, and that householders are treated consistently across the country.
There is a real urgency about this, as hundreds of tourist accommodation providers are closing or about to close as a direct result of the way the RRFSO is currently being implemented. We know that the Minister of Tourism is very concerned about the resultant effect on tourism, which threatens to undermine key parts of the Government’s tourism strategy (including the Olympic tourism legacy). This impact departs widely from the proportionate, self-assessment based, risk-based regime expressly laid out within the RRFSO.
We agree with Tourism South East's view (in Daniel Humphreys' letter to DCLG of 27 June) that:
"we believe that whilst this guidance [to accommodation owners] is a welcome addition to the information already available, it should be considered as a second priority for the DCLG. It is far more important to deal with the inconsistent approach being pursued by the different Fire and Rescue Authorities which is already having a detrimental effect on the tourism industry in some locations of the South East of England."
Norfolk Tourism also agree with our view; Martin Hickey of Norfolk Tourism, in his letter to Louise Upton of DCLG of 16th June, stated:
"we feel the purpose behind your circular of May 19th and the draft booklet is misplaced. What is needed from your Department is guidance to the Fire Services as to the degree of flexibility they can show towards small B&B's in the type and extent of fire detection and prevention measures required. The technical details are more than amply covered by the 147 page guidance document headed 'Fire Safety Risk Assessment - Sleeping accommodation'."
VisitBritain have advised us they are "keen we take a co-ordinated approach to the issue of differences in interpretation of the [RRFSO]" and have stated publicly that:
"VisitBritain (VB) is very much aware of all the difficulties being experienced by operators who were previously not covered by fire certificates...We are very concerned about the way in which some businesses are being dealt with."
Louise Upton of DCLG has said “I recognise your concerns over perceptions of disproportionate enforcement by some fire safety officers, and the adverse impact this is having on some within the sector… CFOA [Chief Fire Officers Association] also recognise the issues that your e-mail raises”. She has advised us that:
“I can assure you we certainly don't underestimate the concerns around business viability and motivation following the introduction of the Order, and the adverse impact that the approach being taken by some fire safety officers is having on the [tourism] industry. We are considering, with CFOA and others, a range of means to address this and will keep the sector informed of progress in due course.”
However, we are concerned that what may be being discussed will fall short of what is clearly needed: strong and clear guidance from the Secretary of State for CLG to Fire & Rescue Authorities on the proportional and consistent enforcement of the RRFSO.
We call on you as Fire Minister to ask your Secretary of State, Hazel Blears, to issue such clear guidance without delay.
We are very happy to take a constructive part in the formulation of the guidance, if appropriate, but it does not need to be highly sector-specific. The guidance should address the issue of compliance burdens on all micro-organisations not within the ambit of previous legislation, especially those whose operations benefit the UK’s export income, provide indirect employment and reduce Britain’s balance of payments deficit.
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Have a read of this, a briefing note to the Fire Minister from the B&B Association.
Impact of Inconsistent and Disproportionate Implementation
of the RRFSO on the Tourism Accommodation Sector
BRIEFING NOTE
To: Parmjit Dhanda MP, Fire Safety Minister
17 July 2008
We (David Weston, Chief Executive, Bed & Breakfast Association, Andy Woodward, Chief Executive, Farm Stay UK, Martin Sach, Chief Executive, English Association of Self-Catering Operators and Bernard Brindley, Vice Chairman, British Institute of Innkeeping) represented accommodation owners at a meeting on 1st July at DCLG (at which Pam Bunston represented DCMS), which gave feedback on a new, more user-friendly leaflet for small accommodation providers about their responsibilities under the Regulatory Reform (Fire Safety) Order 2005 (“RRFSO”).
We support the new leaflet, but feel that the main issue which needs addressing by DCLG is guidance to Fire and Rescue Authorities, not to accommodation providers (where DCLG’s own research showed 86% awareness already of the need to do a fire risk assessment).
The large number of representations we have received from small accommodation providers make it clear to us that:
• There is very wide inconsistency between different fire departments in their approach to accommodation owners; for instance, for the smallest "domestic" properties some fire departments are happy with hand torches and some "demand" commercial-type emergency lighting systems (this is just one small example amongst many we could quote)
• Some fire departments are adopting a very prescriptive approach, against the express intentions of the RRFSO
• Some fire departments seem to be "enforcing the guide", which has no legal status, rather than recognising that the owner has fulfilled his responsibilities by carrying out his own "suitable and sufficient" Fire Risk Assessment (FRA) and (only if they have 5 or more employees) to record their FRA, and then in the light of their FRA to make appropriate fire safety arrangements
• There is often no recognition that many of the premises concerned are primarily domestic premises
• There is all too often little heed taken of the RRFSO's emphasis on proportionality, ie low compliance burden for the smallest domestic and semi-domestic premises
It is important to remember that the Government intended the RRFSO as a deregulatory measure, bringing in a new self-assessment regime to replace the old "Fire Certificate" regime. It is expressly not intended to place onerous new burdens on businesses or render whole categories of small businesses economically unviable. The Order states that "the Secretary of State is of the opinion that this Order does not remove any necessary protection or prevent any person from continuing to excercise any right or freedom which he might reasonably expect to continue to excercise".
Unlike the old (1971) regime, it is not prescriptive - ie the new regulations do not oblige any owner to put in any specific fire precautions. Rather, they oblige every owner to carry out their own "suitable and sufficient" Fire Risk Assessment (FRA), and (if they have 5 or more employees) to record their FRA, and then in the light of their FRA to make appropriate fire safety arrangements, having regard to the size and the nature of their business.
The RRFSO is very specifically intended to be proportionate, ie to fully take into account the size and nature of each business; it requires owners to take "such general fire precautions as may be reasonably required in the circumstances of the case" (Part 2, Section 8.1.b). These (fire safety) arrangements must be "appropriate, having regard to the size of [the owner's] undertaking and the nature of its activities" (Part 2, Section 11.1). The words "so far as is reasonably practicable" appear three times in section 12, as does "appropriate to the nature of the activity or operation".
In section 13 (Fire-fighting and fire detection), the Order requires the owner to provide fire-fighting equipment "to the extent that it is appropriate" - and this is further clarified as "having regard to the dimensions of the premises, the equipment contained on the premises, the physical and chemical properties of the substances likely to be present and the maximum number of persons who may be present at any one time" (in the small B&Bs not previously subject to the 1971 requirements, for instance, the number present will be between one and six people, apart from the family whose domestic premises these are).
In the light of all the evidence since October 2006, it is clear that DCLG need to give strong and clear guidance on all this to fire departments, to ensure that the RRFSO's key principles of deregulation, lighter burden, and proportionality are followed, and that householders are treated consistently across the country.
There is a real urgency about this, as hundreds of tourist accommodation providers are closing or about to close as a direct result of the way the RRFSO is currently being implemented. We know that the Minister of Tourism is very concerned about the resultant effect on tourism, which threatens to undermine key parts of the Government’s tourism strategy (including the Olympic tourism legacy). This impact departs widely from the proportionate, self-assessment based, risk-based regime expressly laid out within the RRFSO.
We agree with Tourism South East's view (in Daniel Humphreys' letter to DCLG of 27 June) that:
"we believe that whilst this guidance [to accommodation owners] is a welcome addition to the information already available, it should be considered as a second priority for the DCLG. It is far more important to deal with the inconsistent approach being pursued by the different Fire and Rescue Authorities which is already having a detrimental effect on the tourism industry in some locations of the South East of England."
Norfolk Tourism also agree with our view; Martin Hickey of Norfolk Tourism, in his letter to Louise Upton of DCLG of 16th June, stated:
"we feel the purpose behind your circular of May 19th and the draft booklet is misplaced. What is needed from your Department is guidance to the Fire Services as to the degree of flexibility they can show towards small B&B's in the type and extent of fire detection and prevention measures required. The technical details are more than amply covered by the 147 page guidance document headed 'Fire Safety Risk Assessment - Sleeping accommodation'."
VisitBritain have advised us they are "keen we take a co-ordinated approach to the issue of differences in interpretation of the [RRFSO]" and have stated publicly that:
"VisitBritain (VB) is very much aware of all the difficulties being experienced by operators who were previously not covered by fire certificates...We are very concerned about the way in which some businesses are being dealt with."
Louise Upton of DCLG has said “I recognise your concerns over perceptions of disproportionate enforcement by some fire safety officers, and the adverse impact this is having on some within the sector… CFOA [Chief Fire Officers Association] also recognise the issues that your e-mail raises”. She has advised us that:
“I can assure you we certainly don't underestimate the concerns around business viability and motivation following the introduction of the Order, and the adverse impact that the approach being taken by some fire safety officers is having on the [tourism] industry. We are considering, with CFOA and others, a range of means to address this and will keep the sector informed of progress in due course.”
However, we are concerned that what may be being discussed will fall short of what is clearly needed: strong and clear guidance from the Secretary of State for CLG to Fire & Rescue Authorities on the proportional and consistent enforcement of the RRFSO.
We call on you as Fire Minister to ask your Secretary of State, Hazel Blears, to issue such clear guidance without delay.
We are very happy to take a constructive part in the formulation of the guidance, if appropriate, but it does not need to be highly sector-specific. The guidance should address the issue of compliance burdens on all micro-organisations not within the ambit of previous legislation, especially those whose operations benefit the UK’s export income, provide indirect employment and reduce Britain’s balance of payments deficit.
"Unlike the old (1971) regime, it is not prescriptive - ie the new regulations do not oblige any owner to put in any specific fire precautions."
No because they should already have been put in under H&S at Work Act. (Self Employed), and I think they are missing the point about a FRA.
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I am not saying that they are correct and they should have done something, ignorance is no excuse and they have the safety of the clients to consider above everything else. However, some of the words in the Note ring true about prescription, analysis of risk, proportionality, disproportionte enforcement and burdens on business. Something that struck me was, are FRS insistent on a written FRA for small business, were the law does not state this. many hotels are licensed as are some B&B's but apart from that, where has that come from. Unfortunately, not many appeals are launched and Courts tend to go with the Uniforms as that is the norm.
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Parmjit Dhanda has just been sacked!
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Parmjit Dhanda has just been sacked!
You mean theeeeeeeeeeeeeeeeeee Parmjit Dhanda?
Who's Parmjit Dhanda then? The MP type?
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http://news.bbc.co.uk/1/hi/england/gloucestershire/7654073.stm
Gloucester MP Parmjit Dhanda said he was "disappointed" to lose his junior ministerial post in Gordon Brown's government reshuffle.
He was appointed as Parliamentary Under Secretary of State at the Department for Communities and Local Government on 29 June 2007.
The role has gone to Tooting Labour MP Sadiq Khan in the reshuffle.
Mr Dhanda said his demotion would give him the chance to concentrate on constituency matters.
"Of course it was a disappointment, but ministerial jobs come and go," he said on his website.
"It's been a real honour to serve my country as an education minister and then as a CLG (Communities and Local Government) minister covering the fire service and community cohesion issues.
"I am now looking forward to having more time for bread and butter causes in Gloucester.
"It was for this reason that I decided to turn down the prime minister's offer (of a non-ministerial post) and return full-time to the backbenches."
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http://news.bbc.co.uk/1/hi/england/gloucestershire/7654073.stm
Gloucester MP Parmjit Dhanda said he was "disappointed" to lose his junior ministerial post in Gordon Brown's government reshuffle.
He was appointed as Parliamentary Under Secretary of State at the Department for Communities and Local Government on 29 June 2007.
The role has gone to Tooting Labour MP Sadiq Khan in the reshuffle.
Mr Dhanda said his demotion would give him the chance to concentrate on constituency matters.
"Of course it was a disappointment, but ministerial jobs come and go," he said on his website.
"It's been a real honour to serve my country as an education minister and then as a CLG (Communities and Local Government) minister covering the fire service and community cohesion issues.
"I am now looking forward to having more time for bread and butter causes in Gloucester.
"It was for this reason that I decided to turn down the prime minister's offer (of a non-ministerial post) and return full-time to the backbenches."
You mean he was useless as Parliamentary Under Secretary of State at the Department for Communities and Local Government covering the fire service and community cohesion issues.
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a new, more user-friendly leaflet for small accommodation providers about their responsibilities under the Regulatory Reform (Fire Safety) Order 2005 (“RRFSO”).
We support the new leaflet.
Anyone know if this leaflet is available to browse on the internet?
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Still draft.
This is the text from the leaflet.
Fire safety for smaller B&B’s, self-catering holiday and similar accommodation
This section is intended to provide the operators of very small bed and breakfast and self catering accommodation, farms, bunkhouses and similar establishments with simple and straightforward guidance on what fire safety precautions may be necessary to make your premises safe and comply with the law.
Because of large variations in age, construction and layout of this type of accommodation any advice must be applied with common sense. What may be appropriate in a modern self catering apartment may not be sufficient in a three hundred year old coaching house. If you specifically market to people with disabilities you may have to do more. – Fire Safety Risk Assessment - Means of Escape for Disabled People – available for free download at www.communities.gov.uk provides valuable advice.
If your premises are comparable with an average sized family home, the precautions necessary will generally be simpler than those required for people sleeping in larger premises with more complex layouts.
The following advice is not suitable for larger accommodation. There is no absolute definition of what is a large bed & breakfast establishment. If your premises are significantly larger than an average family home or include long, unusual or complex escape routes, e.g. more than 12m, to the final exit door then you will probably need more sophisticated fire safety arrangements.
For such premises you should consult HM Government guide – Fire Safety Risk Assessment – Sleeping Accommodation – available for free download via www.communities.gov.uk
After working through steps one, two and the first part of step three of your fire risk assessment you should have removed all obvious hazards and reduced the risk considerably.
The next thing you should think of is, “how will a fire be detected and how will the people in my premises be alerted”?
Automatic Fire Detection and Alarm systems
Bed and Breakfast or self-catering holiday lets of up to two storeys and occasionally premises comprising of three storeys, but still of a size comparable with an average family home, are likely to require an automatic fire detection system (designed specifically for dwellings rather than businesses) based on interconnected mains powered smoke alarms (with a battery back-up), with detectors sited in the staircase and corridors and rooms that open onto these routes including all bedrooms. (Technically this is referred to as a Grade D LD2 system as described in British Standard 5839 Part 6).
In the very smallest accommodation of no more than two storeys, with two or three guest bedrooms and short travel distances to open air, a system of interconnected (or radio interlinked) detectors with a ten year battery life, may be adequate. It will probably be best if you use a heat detector in any kitchen. (Technically this is referred to as a Grade F LD2 system as described in British Standard 5839 Part 6). Grade F systems can be self-installed and are therefore relatively inexpensive.
As with all systems regular testing to ensure they are functioning and can be heard within each bedroom will be necessary. They must be loud enough to wake a sleeping person. There are also similar systems available to include vibration units and flashing lights for people with hearing difficulty.
Larger premises will usually require a more sophisticated system with a control panel and manual call points. (Technically this is referred to Grade L2 as described in British Standard 5839 Part 1).
Once a small fire has been detected you should think about “how it could be put out and therefore save others in the premises?”
Fire Fighting Equipment
In small bed and breakfast accommodation and similar premises one extinguisher on each floor, hung on a bracket in the stairs and a fire blanket in the kitchen should be adequate.
Suitable multi purpose extinguishers can be brought from large retail outlets. They are guaranteed for five years and should only require the gauge checking to make sure the ‘stored pressure’ has not leaked. Make sure the instructions are clear and there is a warning to people not to tackle anything other than a very small fire.
“How will people get out of the premises?”
You should never underestimate the danger of a fire in small premises. Nearly all the people who die in fires in this country are trapped in domestic type premises.
Protection of Escape Routes
Escape routes include rooms, corridors and stairs that have to be passed through to escape from a building. Where rooms have doors which open onto escape routes the likelihood of safe escape is reduced when a door is left open. Even when there are fire detectors in all rooms, people may still not get an early enough warning to make a safe escape if doors are left open. It is important that doors will hold back fire and smoke long enough to give time for escape. For very small premises any reasonably solid timber door that fits well into its frame is likely to be sufficient. Cheap internal “hollow egg-box” type doors are not adequate. Self-closing devices can be a good way of ensuring doors are closed but may be considered undesirable if they impact on the appearance and normal use of the building. If overhead self-closing devices are not suitable then ‘in-frame closers or rising-butt hinges may be acceptable. If the doors and walls to the stairs and corridors are substantial construction and do not have any glazed panels then they will probably be adequate. You should pay particular attention to the kitchen doors. You should include instructions to your guests to ensure all doors are closed at night alongside other fire safety information provided.
Final exit doors, such as the front or back door should always be easy to unlock and must not need a key to unlock from the inside. A simple Yale-type latch or thumb turn is usually sufficient.
Can people see to safely leave the premises?
Lighting of escape routes
Normal lighting switches should be easy to find. If a fire knocks out the normal internal lighting would any borrowed lighting from nearby street lamps be enough? If not, in small bed and breakfast accommodation and similar premises, rechargeable torches, prominently mounted with a sign indicating their purpose is likely to be enough.
Larger premises will require more sophisticated emergency lighting systems.
Signs
Signs are only required where they are needed. In very small premises the escape route and the front door will be obvious, even to newly arrived people. The need for emergency exit or directional signs should be minimal. If there is a special escape route which is not in normal use, then signs should be used to indicate this.
Evacuation plan and instructions
In the event of your fire alarm operating during sleeping hours, people will evacuate more quickly if they have received clear instructions at the beginning of their stay. A simple plan and instructions on the back of the bedroom door may help. A welcome pack can contain further advice. They should be instructed to leave the building immediately by the usual exit route (e.g. stairs and front door). The fire and rescue service can then be called from outside the premises.
All safety equipment should be regularly tested and it is good practise to keep a written record of testing and the reasons behind the outcome of the risk assessment process.
For smaller premises you should not need to employ a professional fire consultant. If you do, you should ask for references from other similar premises before making your decision.
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Still draft.
This is the text from the leaflet.
Fire safety for smaller B&B’s, self-catering holiday and similar accommodation
This section is intended to provide the operators of very small bed and breakfast and self catering accommodation, farms, bunkhouses and similar establishments with simple and straightforward guidance on what fire safety precautions may be necessary to make your premises safe and comply with the law.
Because of large variations in age, construction and layout of this type of accommodation any advice must be applied with common sense. What may be appropriate in a modern self catering apartment may not be sufficient in a three hundred year old coaching house. If you specifically market to people with disabilities you may have to do more. – Fire Safety Risk Assessment - Means of Escape for Disabled People – available for free download at www.communities.gov.uk provides valuable advice.
If your premises are comparable with an average sized family home, the precautions necessary will generally be simpler than those required for people sleeping in larger premises with more complex layouts.
The following advice is not suitable for larger accommodation. There is no absolute definition of what is a large bed & breakfast establishment. If your premises are significantly larger than an average family home or include long, unusual or complex escape routes, e.g. more than 12m, to the final exit door then you will probably need more sophisticated fire safety arrangements.
For such premises you should consult HM Government guide – Fire Safety Risk Assessment – Sleeping Accommodation – available for free download via www.communities.gov.uk
After working through steps one, two and the first part of step three of your fire risk assessment you should have removed all obvious hazards and reduced the risk considerably.
The next thing you should think of is, “how will a fire be detected and how will the people in my premises be alerted”?
Automatic Fire Detection and Alarm systems
Bed and Breakfast or self-catering holiday lets of up to two storeys and occasionally premises comprising of three storeys, but still of a size comparable with an average family home, are likely to require an automatic fire detection system (designed specifically for dwellings rather than businesses) based on interconnected mains powered smoke alarms (with a battery back-up), with detectors sited in the staircase and corridors and rooms that open onto these routes including all bedrooms. (Technically this is referred to as a Grade D LD2 system as described in British Standard 5839 Part 6).
In the very smallest accommodation of no more than two storeys, with two or three guest bedrooms and short travel distances to open air, a system of interconnected (or radio interlinked) detectors with a ten year battery life, may be adequate. It will probably be best if you use a heat detector in any kitchen. (Technically this is referred to as a Grade F LD2 system as described in British Standard 5839 Part 6). Grade F systems can be self-installed and are therefore relatively inexpensive.
As with all systems regular testing to ensure they are functioning and can be heard within each bedroom will be necessary. They must be loud enough to wake a sleeping person. There are also similar systems available to include vibration units and flashing lights for people with hearing difficulty.
Larger premises will usually require a more sophisticated system with a control panel and manual call points. (Technically this is referred to Grade L2 as described in British Standard 5839 Part 1).
Once a small fire has been detected you should think about “how it could be put out and therefore save others in the premises?”
Fire Fighting Equipment
In small bed and breakfast accommodation and similar premises one extinguisher on each floor, hung on a bracket in the stairs and a fire blanket in the kitchen should be adequate.
Suitable multi purpose extinguishers can be brought from large retail outlets. They are guaranteed for five years and should only require the gauge checking to make sure the ‘stored pressure’ has not leaked. Make sure the instructions are clear and there is a warning to people not to tackle anything other than a very small fire.
“How will people get out of the premises?”
You should never underestimate the danger of a fire in small premises. Nearly all the people who die in fires in this country are trapped in domestic type premises.
Protection of Escape Routes
Escape routes include rooms, corridors and stairs that have to be passed through to escape from a building. Where rooms have doors which open onto escape routes the likelihood of safe escape is reduced when a door is left open. Even when there are fire detectors in all rooms, people may still not get an early enough warning to make a safe escape if doors are left open. It is important that doors will hold back fire and smoke long enough to give time for escape. For very small premises any reasonably solid timber door that fits well into its frame is likely to be sufficient. Cheap internal “hollow egg-box” type doors are not adequate. Self-closing devices can be a good way of ensuring doors are closed but may be considered undesirable if they impact on the appearance and normal use of the building. If overhead self-closing devices are not suitable then ‘in-frame closers or rising-butt hinges may be acceptable. If the doors and walls to the stairs and corridors are substantial construction and do not have any glazed panels then they will probably be adequate. You should pay particular attention to the kitchen doors. You should include instructions to your guests to ensure all doors are closed at night alongside other fire safety information provided.
Final exit doors, such as the front or back door should always be easy to unlock and must not need a key to unlock from the inside. A simple Yale-type latch or thumb turn is usually sufficient.
Can people see to safely leave the premises?
Lighting of escape routes
Normal lighting switches should be easy to find. If a fire knocks out the normal internal lighting would any borrowed lighting from nearby street lamps be enough? If not, in small bed and breakfast accommodation and similar premises, rechargeable torches, prominently mounted with a sign indicating their purpose is likely to be enough.
Larger premises will require more sophisticated emergency lighting systems.
Signs
Signs are only required where they are needed. In very small premises the escape route and the front door will be obvious, even to newly arrived people. The need for emergency exit or directional signs should be minimal. If there is a special escape route which is not in normal use, then signs should be used to indicate this.
Evacuation plan and instructions
In the event of your fire alarm operating during sleeping hours, people will evacuate more quickly if they have received clear instructions at the beginning of their stay. A simple plan and instructions on the back of the bedroom door may help. A welcome pack can contain further advice. They should be instructed to leave the building immediately by the usual exit route (e.g. stairs and front door). The fire and rescue service can then be called from outside the premises.
All safety equipment should be regularly tested and it is good practise to keep a written record of testing and the reasons behind the outcome of the risk assessment process.
For smaller premises you should not need to employ a professional fire consultant. If you do, you should ask for references from other similar premises before making your decision.
Appears fairly sensible really. However, there could be many disputes over what is a smaller, very small, very smallest, small, average size, large and larger premises.
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Thanks FSO
It certainly all looks very reasonable, practical and not financially overbearing measures for the B & B, etc owners to consider to me. Lets hope that common sense is the winner and that all parties can work together to achieve a common goal, a "reasonably practicable" "risk proportionate" fire safe enviroment for the service users. Can you get a leaflet and send it up north of the border, so that the Scots can join in with this great idea.
Should I assume that this is not just an English problem??
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What a total mess this whole Fire Regs is getting in. Why oh why did the regs have to be changed.
Its what makes Britain the basket case it is today. A complete lack and total of common sense.
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What a total mess this whole Fire Regs is getting in. Why oh why did the regs have to be changed.
Its what makes Britain the basket case it is today. A complete lack and total of common sense.
Yes lets go back to fire certs for some buildings, risk assesments for others, licenses for some, bugger all for many.
Thing with common sense is - that it aint very common.
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What is commom sense about making totally unqualified people legally responsible RP's
I don't care what you all say. IT IS TOTAL NONSENSE
Its like HIPS, Speed cameras, Immigration, Outlandish welfare payments, Licensing controls. Health & Safety excesses.................. etc etc etc etc etc etc etc and more ets's
Great Britain 2008. Jobsworth heaven.
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What a total mess this whole Fire Regs is getting in. Why oh why did the regs have to be changed.
Its what makes Britain the basket case it is today. A complete lack and total of common sense.
The fire regs changed to place the burden on those who are creating the risk - you and those like you. Its intention is for you to take ownership of the risk and so control it. The politicians want you, as the risk owner, to pay the cost of reducing any risk to peoples safety, and not the taxpayer. The F&R Services will then ensure that you, the risk owner, control it properly. This is nothing new, it is just more targeted.
The standards required to control the risk didn't change that much. They have been around for years. It's just that many employers outside the enforcement net ignored them.
I trust the new draft guidance for B&Bs, if it is implimented, pleases you? It does seem a little more sensible as most would agree.
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I don't care what you all say. IT IS TOTAL NONSENSE
A well reasoned argument.
However, since IIRC you appeared on this forum with a moan about what a fire service required of you to comply with the legislation, and it seems that you would rather have the old legislation back, think about it like this:
If you were to apply for a fire certificate now, you would simply HAVE to do what we say, or you don't get the certificate. And you also HAVE to keep it like we say or you could get prosecuted.
It seems to me that you don't want to be responsible for your premises, but you also don't like Authorities telling you what to do.
I shall email the CLG immediately with a suggestion of a new "Regulatory Reform (The fire service are fully responsible, but they can't actually ask for anything) Order 2009"
I fully apologise if a hint of sarcasm is evident in this posting.
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What is commom sense about making totally unqualified people legally responsible RP's
I don't care what you all say. IT IS TOTAL NONSENSE
If the RP feels that they are not competant to carry out the FRA, they should get advice or use someone who is. The RP should have been ensuring that means of escape and the safety of employees / guests/ residents were covered by their H&S assessment if not in possession of a fire certificate. If they had been doing this, the introduction of the RR(FS)O wouldn't be much more than recording their findings on a separate form.
The problem is that businesses who weren't previously doing this now find themselves in the situation where they can face large fines and bad publicity if they don't comply; and they are using various excuses and 'slagging' off the order to vent their anger to protest about spending money to ensure the safety of the very people they are responsible for.
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Reading all the comments on this forum it seems that the situation is that the RP has no choice but to use an advisor.
In an earlier posting I bulked about my local fire brigade requesting smoke seals on my forty hotel bedroom doors.
I got lots of (I though good) advise from you folk and composed a response to the local senior fire officer who visited my premises.
My response consisited of about 6 or 7 postings (obviously without mentioning authors or this site) (Remember I am a hotelier NOT a fireman so I am frantically looking for help anywhere I can get it)
Guess what. He totally rubished your comments and advice in each and every case ????????????????????
So going back to the RP (who has the legal responsibily..yes) getting advise from outside sources. Whose to tell that advise will be accepted by the local FO. (and in any case is relevant)
I simple do not agree with the concept of an RP as it stants at the moment
I mean do you want Richard Branson to fly the plane just because he owns the business and caused the risk ?????????????
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I mean do you want Richard Branson to fly the plane just because he owns the business and caused the risk ?????????????
No, course i don't. But i do want Richard Branson to ensure he has correctly qualified pilots and servicable aircraft to fly me.
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and that smokescreen is my entire point. I aint qualified but I am the legally responsible RP
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No Davidrh, just like you, Richard Branson will ultimately be the RP for Virgin. I'm sure he isn't qualified in any of the businesses he runs but as they are his companies. He employees the staff who run them and that will leave him responsible. (i'm sure in this case though, the buck would stop long before it reaches him.)
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Again smokescree you have hit the nail on the head.
The buck stops with me.
and I (to repeat) am not qualified
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Your probably not qualified to run a business either like most Hotel owners (and 95% of entrepeneurs) but that didn't stop you trying and getting one off the ground.
Apply that same tenacity and thinking you apply to making profit as you do to saving lives.
For me that sums up this whole thing for every business out there.
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Again smokescree you have hit the nail on the head.
The buck stops with me.
and I (to repeat) am not qualified
Davidrh. Are you qualified in accountancy? Just one of those thing needed to operate a successful hotel business. How do you manage to struggle through such a thing or do you get a qualified person to do it for you?
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Again smokescree you have hit the nail on the head.
The buck stops with me.
and I (to repeat) am not qualified
Unfortunately for you then Davidrh you will have to fork out some cash and get someone competant to undertake a FRA for you. Ask other hoteliers who they used, get opinions and if the they and the fire brigade were happy with the assessment as it is likely you will have to trust the action plan that is put forward to you, as like you said, you aren't qualified.
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How do I know whose competant. How do I know the local FO will agree with the FA.
How do I deal with people who such as London Fire Brigade
Page 23, todays Jon Gaunt column in The Sun (Cig heil to fire twerps)
I rest my case people
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How do I know whose competant. How do I know the local FO will agree with the FA.
How do I deal with people who such as London Fire Brigade
Page 23, todays Jon Gaunt column in The Sun (Cig heil to fire twerps)
I rest my case people
Couldn't quite get that lot.
How can you tell your accountant is competant? He is probably qualified but can still be incompetant.
If you use a competant assessor you should have no probs with the local FO.
Don't quite get the Cig Heil bit so can't comment.
Have a nice rest.
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as far as I can see this is today's John Guant column: -
quite what the reasoning is from Davidrh is obscure,
"UNLIKE most members of the Cabinet, I have lived in the real world and been bankrupt. Nobody helped me so why the hell must I and every other taxpayer have to bail out the bankers? I still remember the humiliation of standing in the dole queue behind a drug dealer who I used to chuck out of my nightclub. I remember the pain of having my home repossessed. How the banks sold it at a knockdown price then chased me for the shortfall. I remember what it was like to rent a hovel in Coventry with our new baby and how the child benefit cheque was a godsend.
My only crime was that I tried to do something positive and create jobs in Coventry but failed. Like thousands of others in the last recession I had the balls to give it a go and, because of some bad luck but mostly my mistakes, I lost the lot. I say all this not to be self-pitying but to contrast my failure with that of the bankers. I and thousands of others paid a heavy price for our failure. It was years before I could get another mortgage, credit, or dream of a future. But do you think the twit (with an A) who ran Northern Rock has been selling copies of the Big Issue down the Bigg Market in Newcastle? Has he hell! He’s been spending the summer playing cricket and living in his multi-million-pound home. Do you think sacked Royal Bank of Scotland bosses will be queuing for the dole? Fat chance. They will be living the high life on their copper-bottomed pensions or the dosh they’ve salted away. Is anyone going to carry the can for dropping us all in the proverbial? Not if the behaviour of Barclays’ bosses is anything to go by. They are on a binge in Italy while we mugs pick up the pieces. Bankers have been stuffing their pockets as quickly as they quaffed the champers and snorted the Colombian marching powder. Now we are bailing them out and our so-called democratic Government haven’t even debated it in Parliament. Our unelected Prime Minister, the most unpopular leader since Pol Pot (he’s certainly taken us back to year zero!) is now promoting himself as the only bloke who can sort out the mess. But hold on, as Chancellor for ten years, shouldn’t he have kept his one good eye on the banks? He constantly said there wouldn’t be a return to boom and bust. Now, although this is a world crisis, it is one time when the invisible man can’t hide from his part in it. Why the hell have Gordon Brown and his puppet Chancellor, Alistair Darling, dithered? Why wasn’t Parliament recalled last week?I accept that this taxpayers’ bailout of the banks is the only answer. But it is too little, too late. We have been failed as much by the politicians as by the fat cats in the City. The latest interest rate cut is great but only if passed on to small businesses and mortgage holders and not salted away by banks. The Federation of Small Businesses are warning other banks may follow Barclays’ lead by increasing overdraft rates for small firms, which would have the direct result of sending businesses to the wall. We are lending failing banks our cash yet they have the cheek to put up our overdraft charges if we dare to borrow back our own money. Why hasn’t The Bottler banned bankers’ bonuses and made a firm promise that their sky-high earnings will never be allowed again? It hurt me when I went bust but at least that was my fault and I paid the price. I don’t see why you and I should pay the price for the actions of the City and the Government."
oh and I think the words are actually 'Sieg Heil' which some people still find offensive
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I do believe it's a fact that the Sun is written to a standard comparable to a 12 year olds reading level.
To ever cite anything written in that "Newspaper" is to invite ridicule.
It is tabloidist dogma.
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How can you tell your accountant is competant?
A good indication is the size of your tax bill !!
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I do believe it's a fact that the Sun is written to a standard comparable to a 12 year olds reading level.
I feel this is an insult to 12 year olds.
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"My only crime was that I tried to do something positive and create jobs in Coventry but failed."
Thats where John went wrong. He should have started a business to make money. He may have to employ people to do that but first and foremost any sensible person should always try to earn money without having to give any away in wages. Sometimes it works but sometimes you can't avoid it. Ask any business man if he would like to run his business without having to employ any staff? He would jump at the chance if he thought it was possible.
As for John thinking he has a moral obligation to provide employment? Sucker.
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I do believe it's a fact that the Sun is written to a standard comparable to a 12 year olds reading level.
To ever cite anything written in that "Newspaper" is to invite ridicule.
It is tabloidist dogma.
And what does it have to do with 'fire twerps or the LFB'? Is there more to this article?
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Maybe there are different articles in different areas.
The one i was talking about was regarding London Fire Brigade.
On the left top of the page
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Davidrh
Did you happen to mention where you got the advice?
I just wonder if your guy has got a hidden agenda.
Certainly his common sense is hidden!
These guys have hundreds nay thousands of years in. Its rare they are at polar opposites. The only way to get one opinion is to hire one RA.
davo
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Reading all the comments on this forum it seems that the situation is that the RP has no choice but to use an advisor.
In an earlier posting I bulked about my local fire brigade requesting smoke seals on my forty hotel bedroom doors.
I got lots of (I though good) advise from you folk and composed a response to the local senior fire officer who visited my premises.
My response consisited of about 6 or 7 postings (obviously without mentioning authors or this site) (Remember I am a hotelier NOT a fireman so I am frantically looking for help anywhere I can get it)
Guess what. He totally rubished your comments and advice in each and every case ????????????????????
So going back to the RP (who has the legal responsibily..yes) getting advise from outside sources. Whose to tell that advise will be accepted by the local FO. (and in any case is relevant)
I simple do not agree with the concept of an RP as it stants at the moment
I mean do you want Richard Branson to fly the plane just because he owns the business and caused the risk ?????????????
Davidrh
i have been away from the forum for a number of weeks and i just cannnot beleive that this is thead is still going and evryeryone seems to give you the same advice but for some reason you dont want to take it.
If you are not competent GET SOMONE WHO IS!!!! dont give an inspecting officer a load of comments off a web site and and expect them to say that it is a suitable and sufficient assessment of the risks in your premises.
when you provide the IO with a suitable and sufficent assessment of the risk and i list of significant findings they will discuss your findings with you.
If you get a COMPETENT fire risk assessor to do it for you get that person to meet the IO to discuss the outcomes of the document and agree a way forward.
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Just had a very nice few days in a 6 storey Paris hotel.
Just a few interesting comparisons:
No fire or smoke seals on doors
No self closers on bedroom doors even in a dead end corridor
No fire detectors in rooms or in the staircases - only the corridors had smoke detection
No exit signs bigger than 25mm high
Arrows used by themselves to indicate the direction of exit. Use of up and down arrows on exit and directional signs is a total mess just like over here.
Before you get too excited David about different standards across the EU I must point oiut there are many UK hotels that dont meet our current guide standards- but I would be interested to hear from anyone who is familiar with the French standards to make comparisons.
Some good ideas over there-
The maintained emergency lighting used high intensity LEDs for the maintained lighting - not seen these before in the UK.
In some entertainment venues (no not those places Davo- I was too mean to pay £100 or so just to look at someone elses missus) the illuminated emergency exit signs flashed on and off from the time the doors opened until the start of the performance- very irritating but a made a very significant impact.
Every public venue had clearly displayed intervention and evacuation plans at main entrances and storey exits.
Vivre les sapeurs pompiers!
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......The maintained emergency lighting used high intensity LEDs for the maintained lighting - not seen these before in the UK.......
Plenty of versions available in U.K., Prof.
p.s. Love your new avatar! Pity it isn't wearing crocodile skin boots!
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No fire or smoke seals on doors
No self closers on bedroom doors even in a dead end corridor
No fire detectors in rooms or in the staircases - only the corridors had smoke detection
No exit signs bigger than 25mm high
Arrows used by themselves to indicate the direction of exit. Use of up and down arrows on exit and directional signs is a total mess just like over here.
Are you advising Davo the average B&B operator in the UK should consider bring their premises up to this standard Kurnal?
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Just as a point of intrest, leading on from Kurnal's earlier post above.
Ive just come back from my hols in Menorca. I've been to the island many times before, but was amazed this time around at how many safety upgrades haven taken place in the hotels, bars, restaurants and shops (in terms of both fire safety and general health and safety)
I was suprised to find our apartment block had AFD to L2 standard, an emergency lighting system whose coverage seemed near as damn it to BS 5266 (it too had high intensity LEDs by the way).
The fire action notices were pretty good, exit signs were generally in all the right places, protected routes were just that, magnetic hold open devices were used wherever possible in corridors instead of the Menocian door wedge, cupboards were kept lock shut etc etc.
No strips or seals on the fire doors mind you.
European Directives must be having an affect - improved safety seems to be rolling out in atleast some parts of the EU.
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MR you could well be right, we're just back off an American owned / operated cruise ship which flogs around the Mediterranean for the summer and the interesting thing was the application of Euro type colouring and pictograms on the safety signage (including the fire safety signs) instead of the usual red US variety. Maybe they like the green signs better or maybe their is some sort of compliance / conformity issue at work in European waters. Nice to see improving standards all the same.
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This wanton moaning about the RRO is a bit old hat frankly. Get over it. It's here, it's not going anywhere and if it makes some of the hotel death traps any safer then it has to be a good thing.
Read the guides, go to a free seminar (there are tons) and have a go at writing your own assessment using you probably, once prevelant common sense.
Like it or not, intumescent strips and smoke seals are the best thing to be installed into your hotel and you should be making a conserted effort to progressively upgrade the safety in your hotel. A risk assessment may be able to justify a prolonged period to get the work done, but no assessor would suggest there is no requirement to upgrade the place eventually.
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David
I do sympathise with your situation, however I'm afraid "That's Life" as they say. You are in charge of your business, and therefore you must take responsibility for it. (Which I'm sure you do, Im just giving you the legal viewpoint rather than making a personal judgement about you)
It's time to put the issue to bed. The members on this forum can't change the law, they are not policy makers,
Many people have given you good advice. Why not put that advice into practice and try to action some of the suggestions made. And if you have problems during a particular stage or step come back to us for further advice.
Risk assessment is not rocket science and the government guides out there do explain the basic principles of fire risk assessment and fire safety. Have you read them? If not give it a go.
If you dont feel confident to undertake a fire risk assessment or manage your fire precautions, you will need to employ a competent person to do it for you, such as fire safety consultant or fire risk assessor. There is no way round that I'm afraid.
Your local fire safety department / centre will give you further advice on how to select a competent assessor / consultant.
Davidrh I'm can appreciate why this is all very frustrating for you, Im sure there are millions of other things you have got to worry about, Im sure that you could do without having to pay for someone to look at your fire precautions for you. But once you grab the bull by the horns it won't take a great deal of time (or money if done properly) to sort out.
The whole idea of self regulation is for you as a Responsible Person to get to grips with the issue of fire safety. Not only does it avoid prescription which the corporate world wanted to get away from but it also creates opportunity for people like you to educate themselves about fire safety and why it is needed.
If you don't want prescription but do want self regulation then you have to accept that you can't effectively self assess or self regulate something that you don't understand. With the greatest of respect its evident you don't fully understand. And I don't expect you to, what Im trying to point out is your lack of knowledge is contributing to your frustrations.
Read the guides do a little bit of homework and Im sure you will see that your fire safety responsibilities are not as bad or as costly as you first thought they would be. You don't need to become a fire safety expert, you just need a general appreciation of what is required and why.
The only alternative would be to revert to a prescriptive approach where fire authorities hit you over the head with a guide book telling you that you MUST do this, that you MUST do that etc etc. As we know this is not what businesses want.
So it can only be one way or the other.
Now be off with you and I dont want to see you post on this thread until you have completed a fire risk assessment yourself. Seriously try it yourself first - give it fair chance - and I bet you won't find it that daunting.
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MR
That holiday of yours has certainly chilled you out.
davo
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MR
your post absolutely says it all, especially the last paragraph.
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Done that MR (all of it) and got the tea shirt.
I still say its a nonsense.
and I, for one, am much more nervous about staying in hotels around the country knowing that untrained RP's are in charge...and I don't believe anyone else is if they told the truth
New government soon. Any bets on a law change on Fire Regs as well as fox hunting
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Hi David
Why is it nonsense?.
As a B&B owner you have always had a duty of care towards your guests in various pieces of legislation (not just fire safety).
I do appreciate your argument, but its a burden that any business owner has to bare, from Mr Bloggs who owns the corner shop right up to Richard Branson of Virgin
Are you asking for the return of a prescriptive approach?
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(Cig heil to fire twerps)
I rest my case people
Have only just seen this comment. David, if ever you have to dial treble 9 for the Fire Brigade (or other services) think about yr comment. The FRS do an unbelievable job, sometimes in the most horrible and stressful conditions! The reason why Fire Officers and the people on here give the advice they do is they dont really want to be pulling your customers out during or after a fire.
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Davidrh wrote:
(Cig heil to fire twerps)
I rest my case people
Sounds like the episode of Fawlty Towers , and I rest my case.
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I dont seek to side with Davidrh and I share to some extent his frustrations in terms of how things are enforced in the UK. Not only fire safety - try dealing with social services or the health trusts or CSCI and try cutting through the misinformation, illogical rules, ill informed staff applying their own rules and interpretations and get some common sense - its enough to drive you round the bend. And his experience with fire seems to be similar to my experience in these other arenas.
The reason for this posting is just to put his comment (Cig Hiel) in perspective. I too saw that newspaper story and it was an unfortunate play on words by a gutter press journalist in a rag not worth the paper it was printed on. The story was about the policy of the London brigade in offering free home risk assessments trying to balance their duty of care for their staff whose work involves visiting persons in their own homes where they may encounter smokers. The policy is to ask persons not to smoke one hour before the visit or during the visit. The stupid journalist used this as an excuse to try and ridicule the brigade. Hence the Cig hell- cig hiel. You cant smoke in your own home.
He obviously ignored the common sense response that these people are working in peoples homes for the full working day and so without such a policy could be exposed to second hand smoke for their full working life.
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Thanks Kurnal, this diatribe was not in the Scottish version of the Sun. It's a very unfortunate play on words and but that doesn't concern journalists when seeking a 'hook' for their headline.
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The jungle drums are saying that there is some movement afoot and further guidance in respect of the smaller B&B and specifically addressing proportionality is to be issued by the govt very soon ..................................(though it may be a case of send three and fourpence................)
Kurnal, anyone, any more news on this matter as yet
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You all might be interested in the comments section http://www.firesafetysense.com/yourcomments.htm
"As holders of an old Fire Certificate, not licensed and not employing 5 or more persons, plus we can prove a paperwork trail of alarm testing and extinguisher inspection, why should we have to write it down on more paperwork? Writing it down does not prove a thing: never has, never will. "
"The reasons for creating the new regulations were purely and simply and mainly:
1. To relieve the government and its departments of any responsibility.
2. To create more work for the service industries and consequently more tax income for the government. "
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"A brief example of the overkill regs. I am being forced to comply with:
A couple of years ago I had Dorguards put on all 4 fire doors. ( Automatic door closers which respond to the fire alarms ).
They cost me over £500.00 to install. I am now told to remove them because if there was a fire and for some reason the alarms did not go off then the fire doors would not close. i have tested those fire alarms every week for the last 22 years and they have never failed yet.They are serviced every 6 months and checked weekly because I legally have to. My nice guest house is now dull and boring. I cannot leave the door to the bar or dining room open nor to the TV lounge. I don't have a reception desk area any more because all ideas to make it smoke and fire proof have met with dissaproval by the fire officer. So I am now conducting Reception and billing over my Bar. Is this what the Legislation is suppose to do? The fire officer I am dealing with at the moment is the FIRE OFFICER FROM HELL. He is everything your campaign is trying to change."
As a risk assessor would you allow dorguard?
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"A brief example of the overkill regs. I am being forced to comply with:
A couple of years ago I had Dorguards put on all 4 fire doors. ( Automatic door closers which respond to the fire alarms ).
They cost me over £500.00 to install. I am now told to remove them because if there was a fire and for some reason the alarms did not go off then the fire doors would not close. i have tested those fire alarms every week for the last 22 years and they have never failed yet.They are serviced every 6 months and checked weekly because I legally have to. My nice guest house is now dull and boring. I cannot leave the door to the bar or dining room open nor to the TV lounge. I don't have a reception desk area any more because all ideas to make it smoke and fire proof have met with dissaproval by the fire officer. So I am now conducting Reception and billing over my Bar. Is this what the Legislation is suppose to do? The fire officer I am dealing with at the moment is the FIRE OFFICER FROM HELL. He is everything your campaign is trying to change."
As a risk assessor would you allow dorguard?
Do you have an proper automatic detection system installed?
The problem with Dorguards is that some people tend to use them to hold open kitchen doors. Kitchens are normally fitted with heat detectors which, of course, cannot detect smoke. You can then have a corridor or stairway full of smoke from the litchen and no alarm sounding.
What precisely are your circumstances?
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nearlythere...
I haven't really got any circumstances...I was asking because of the complaint from the person in the quote that I pulled from the link
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Hi Mushy
I would much rather see a dorgard than a wedge. I actually think they are excellent in the right situation and subject to a test in situ before fitting.
If you cant deal with the underlying problem causing the door to be wedged open they are a cheap and effective alternative. I would much rather see swing free door closers or magnets as the circumstances permit ( due to durability and maintenance and battery replacement) but the dorgard fits the bill.
(The deafgard is also a useful bit of kit.)
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You all might be interested in the comments section http://www.firesafetysense.com/yourcomments.htm
Hi Piglet
Thanks for letting us know about this site.
If you have any contacts on this website please remind them that we are here and happy to contribute a little balance to the debate if we can.
It seems very one sided. If all they want is a good moan then it fits the bill. Some of their case histories dont let the truth stand in the way of a good story.
If on the other hand they are interested in trying to understand the whys and wherefores and then having explored and clarified their concerns to discuss them with people on the other side of the industry, who could even take their concerns forward into other arenas then we could do that either through this forum or by allowing us to join theirs.
I recently wrote to a National neswpaper to complain against the one sided slant to their story that totally misrepresented the facts. They published my letter but completely turned it round into praise for their standards of journalism. Swines.
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Mushy, dorguard have a BS and are a Class B device in BS 7273 part 4 and are therefore allowable. Nearlythere's comment has to be taken into account of course and both FRS and RAers should allow them.
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Category B are not regarded as suitable for all applications, such as staircases in sleeping risks.
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Category B are not regarded as suitable for all applications, such as staircases in sleeping risks.
Due to the acceptable lower dB levels in stairwells I assume?
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Thanks all
Category B are not regarded as suitable for all applications, such as staircases in sleeping risks.
This hotel that I stayed in the other weekend had a Dorgard keeping the fire door open at the head of it's accommodation staircase that was open on the ground floor but protecting the bedroom corridor on the first floor (alternative protected stairway at the other end)
The hotel had a very recently installed L2 system
Can you show me where this info can be found that says it's not acceptable Colin
Thanks
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BS 7273 part 4, the tables in the back of the document assess Dorguard as a Category B stabdard.
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Sorry jokar I haven't got that document...is Colin right then (how could I doubt him) my friends hotel shouldn't have dorguard on the stairs?
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Dorgard claims they are a category "C" http://www.dorgard.com/pdf/BS_7273-4_facts.pdf also in http://www.dorgard.com/DorgardLegislationAndFAQs.asp last papagraph.
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As always.
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not sure why they say c. it is actually b, which is better than c
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I hate to disagree with Mr Todd but Dorgard is cat C, System X (Previously known as Dorgard X) is Cat B
Dorgard = Stand alone acoustic
System X = Radio Activated /Acoustic
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I hate to argue with anyone, but Cat C involves other CIE, which is why it is lowest reliability and so has the greatest limitations. I am fascinated as to what other CIE an acoustically linked device goes through, because if you are right Piglet, the BS that actually defines the cats is wrong.