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FIRE SAFETY => Fire Risk Assessments => Topic started by: dino on June 01, 2014, 09:22:14 AM
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I am looking for some guidance in relation to a project I am working on and would appreciate the views of the members on this forum.
The fire Service carry out Operational intelligence (OI) gathering on premises which they regard as a risk to fire crews. These used to be called Operational Risk Assessments (ORA?s) but we now call them OI.
This information is carried on appliances either as a printed copy or electronically and is to be used by fire crews attending any incident at the premises.
My question is, do these OI?s constitute a Fire Risk Assessment and would the fire Service be at fault if the information was not satisfactory?
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Assuming you are in England or Wales Dino, your OIs do not have any status under the Regulatory Reform (Fire Safety)Order 2005. There is no duty imposed on the Fire Service under the Fire Safety Order to carry out risk assessments, your role is to enforce this Legislation.
However your Employer (fire service) has a duty of Care to their employees and others under the HASAWA and these constitute risk assessments supporting that duty of care. This is in addition to their duties to gather information under the Fire and Rescue Services Act 2004 sections 7,8 and 9. Therefore your OIs are risk assessments but come under the HASAWA, the Management Regs and the Fire and Rescue Services Act.In this regard the fire service has a duty to ensure that such information is adequate and fit for purpose.
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Thanks Kurnal
My point is that the information we have in my opinion is not suitable and sufficient and contravenes the HASAWA, management of safety regs 1999, and the Provision and use of work equipment regs but no one seems to be really bothered about it.
the other problem is that it concerns BA guidelines and this just compounds the apathy.
In my service we are expected to go into a building if it is on fire and get the crews to assess if they can tie off guidelines.
My argument is that we have already carried out an inspection of the premises so if it was a suitable and sufficient assessment, we should know if we can use guidelines or not.
the other issue is that we have actually written on the OI to consider guidelines without assessing if they can be secured properly- this again calls the OI into question in my opinion.
I also feel that getting a BA crew to enter a building to see if there are sufficient securing points is not a safe system of work, especially when we should have done this at the OI stage.
Based on these points above, do you think the assessment would be deemed as suitable and sufficient?
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Impossible to say Dino. It could be argued that the recommendation to consider guidelines is another way of saying there is potential for fire fighters to get lost and so affects the dynamic risk assessment at the time - ie there has to be a very compelling reason to commit crews?
Personally I am amazed that the industry as a whole has not come up with a better way to ensure firefighters can navigate their way safely in and out of buildings with all the technlogy available these days- cameras, direction finding, portable beacons, telemetry- there must be a better way that does not tie you up in knots.
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It would be good if people could detach themselves from the whole guideline issue and just look at the risk assessment process.
My whole argument is based around the fact that we have went into a building to gather information for fire crews and we have done an assessment to see if there are disorientation hazards or complex layouts within the building.
in some cases there are these hazards and a recognised control measure is a guideline. For a fire service to put on an assessment for the OIC to consider guidelines when the assessment has not checked if they can be secured properly could mean that the assessment could be challenged as not being suitable and sufficient.
why would we not check during the OI if they can be secured but expect fire crews to then check in an emergency situation which will almost certainly involve smoke. heat and probably a risk to life.
Would this be classed as a safe system of work?
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Given the working duration of a BA set these days is laying guidelines a safe system of work? It certainly isn't an efficient one!
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I see what you mean Dino and yes you are right that if a guideline is a recommended risk control measure then it must be used in accordance with the safe system of work. The SSOW requires it to be tied off to keep it off the ground. If someone has assessed a premises and recommended it as a suitable risk control measure without checking it is indeed suitable the clearly the assessment is not adequate.
on the other hand is it realistic to expect tie off points to be specially installed for use in case of fire? Who would do this, to what spec and who would pay?
It all points to the fact that a guideline is at best a useless piece of tat and at worse a danger to all who rely on them and they should have no place in a modern technical fire service .
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Given the working duration of a BA set these days is laying guidelines a safe system of work? It certainly isn't an efficient one!
In some situations Golden yes. In some they can be a hinderance but I put that down to training and lack of faith in the equipment. I do remember looking at an illuminated guideline. Can quite remember if it was tied off of ground laid.
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IMHO, the OI isn't a risk assessment but it provides some of the info you need to make one.
The other factors will be what the fire is like, what the people are doing etc. you wouldn't bother if it was a wastepaper bin on fire, but you might if you had zero visibility.
I would have thought that "consider guidelines" means "this place is a bit fiddly and guidelines might help. you put this in the OI unless you think the first is true and the second is possible.
This kind of stuuf does get looked at after firefighting fatalities and FRSs are often criticised. Of course, its hard to to these things up-fron and easy to criticise after the event.
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I agree with wee brian OIs cannot be risk assessments even only on the logic that every fire is different and is a dynamic process. The conditions and circumstances that were evident when the first attendance arrived may very well have changed by the time supporting appliances arrive.
Secondly buildings are designed following the requirements of the Approved Documents or BS9999 et al or probably more accurately what the architect thinks are the requirements of these documents mixed with what can I get away with and a fire won't happen and if it does it is years after I designed the place and I am out of it. So things like tie off points are not mentioned in either of the sets of documents and therefore will not get put in. On a similar line I have been involved with places where rooms have been designed for disabled people following building regulations but no thought has been given as to how to get the people out of the building in the event of a fire.
I am afraid that the issue raised is a symptom of a culture of avoiding risk as opposed to managing risk, which has been brought on by various court cases most notably the prosecution in Warwickshire.
Surely the job of the OI is to provide information to assist the OiC not tell them their job. Hence the comments that this is a large complex building should alert the OiC to the idea that if there is a lot of smoke and it is necessary to send teams in then guidelines are probably a very good idea. It should also raise the question of whether it is a good idea to send teams in in the first place.
The problem would be that if the OI is fully comprehensive to cover all eventualities it will be so big that it is impossible to digest in the time available. Somewhat similar to the old joke of a 10 month waiting period for a pregnancy test!
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Thanks for the comments but I am just looking at this from the way in which we can protect the fire service and how we can actually say that we carried out a suitable and sufficient assessment of the risk to fire crews.
My initial proposal would be to firstly assess if guidelines may be required, and secondly assess if we can secure them properly.
If we cannot use them properly, would it be suitable and sufficient to put on the OI that guidelines cannot be used as we cannot secure them properly?
Would this assessment absolve the service if anything happened?
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Would this assessment absolve the service if anything happened?
Only a Judge would decide that, but sadly only after a tragedy had taken place.
The fire service would be in a very sticky situation if it decided to commit crews to a building knowing that the equipment could not be safely used. You would put the initial OIC in a very difficult position and the initial judgement by the first attendance absolutely critical. But that's how its always been I suppose.
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Would this assessment absolve the service if anything happened?
Only a Judge would decide that, but sadly only after a tragedy had taken place.
The fire service would be in a very sticky situation if it decided to commit crews to a building knowing that the equipment could not be safely used. You would put the initial OIC in a very difficult position and the initial judgement by the first attendance absolutely critical. But that's how its always been I suppose.
But could the service then say as they have done a suitable and sufficient risk assessment and know that they cannot safely use guidelines, and this is logged in the OI- therefore we would not use them in that building?
I personally think this is a better method than leaving the service exposed by using the equipment when they have not assessed if it can be used safely.
And in reality, why would we leave it up to the OIC of the incident- surely them knowing they can secure them or not would have an effect on their DRA.
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Thanks for the comments but I am just looking at this from the way in which we can protect the fire service and how we can actually say that we carried out a suitable and sufficient assessment of the risk to fire crews.
My initial proposal would be to firstly assess if guidelines may be required, and secondly assess if we can secure them properly.
If we cannot use them properly, would it be suitable and sufficient to put on the OI that guidelines cannot be used as we cannot secure them properly?
Would this assessment absolve the service if anything happened?
Surely the (dynamic) risk assessment is carried out by the officer in charge on arrival, this will be based on all the information at hand including the site specific info that has been gathered on any prior visits. This information only gives basic stuff like best access, water supplies, processes, numbers of people likely to be present, location of utilities and other considerations, ours gives links to other information that may be used as part of the analytical risk assessment carried out after 20 mins. Ours normally comprise of 2 sides of A4, this can be easily scanned on the way to incidents via data terminals.
What I would say is the title for these documents is risk information not risk assessment - semantics you might say.
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My initial proposal would be to firstly assess if guidelines may be required, and secondly assess if we can secure them properly.
My initial reaction to this is that buildings where guidelines can be secured properly are few and far between. Then what do you do? Tell the occupier they need to fit points to secure guidelines or turn up to a job 'sorry mate we can't go in'?
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Surely, if you dont know what the fire is like then you can't do a proper assessment of the risk.
If you end up with a "requirement" for guidelines for all fires in that building then what do you do if there's a small bin fire in the managers office? You'll look pretty silly with your bit of string with all the staff watching you, when all you need is an extinguisher.
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Dinnertime Dave
I totally agree that the decision to use guidelines will be based on the DRA but my point is that the info we have on the premises is not suitable and sufficient and if challenged, may leave the service at risk.
I am sure a lot of fire services will be the same with regards to this and it is not until things go wrong that it is really challenged.
I had hoped to suggest measures to help protect the service and the only thing I can think of is that if we do an assessment and find there is no way of securing guidelines, we log this on the OI and under no circumstances do we consider using them at an incident.
This takes the choice away from the initial OIC and proves we have robustly assessed the risks to fire crews.
The only issue with this proposal is that if we mark on the OI that guidelines will not be used- do we have to tell the owner of the premises?
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This takes the choice away from the initial OIC and proves we have robustly assessed the risks to fire crews.
I don't think you can do this. The initial OIC will make a decision on the situation as they see it and the resources at their disposal and will act accordingly. What would your OI assessment say? You must not use guidelines in these premises or you must not commit BA teams to a fire in these premises?
What if its persons reported and there appears to be a realistic chance of saving them?
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This takes the choice away from the initial OIC and proves we have robustly assessed the risks to fire crews.
I don't think you can do this. The initial OIC will make a decision on the situation as they see it and the resources at their disposal and will act accordingly. What would your OI assessment say? You must not use guidelines in these premises or you must not commit BA teams to a fire in these premises?
What if its persons reported and there appears to be a realistic chance of saving them?
A fire service should carry out a suitable and sufficient assessment to see if they can use guidelines in a premise if they have to.
To say on an OI to consider guidelines when you have not assessed if you can use them properly leaves the service exposed in my opinion.
The HASAWA section 2, Management of Health and Safety regs 1999 and PUWER all have parts which could be used against services if they ask crews to consider guidelines without a proper assessment.
In my opinion, the way we do it now leaves the services at risk but if we do a robust assessment, realise that we cannot secure guidelines properly and then put this on the OI, I personally feel that we would be protecting the fire services, and more importantly, the fire crews, should an incident happen.
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Surely, if you dont know what the fire is like then you can't do a proper assessment of the risk.
If you end up with a "requirement" for guidelines for all fires in that building then what do you do if there's a small bin fire in the managers office? You'll look pretty silly with your bit of string with all the staff watching you, when all you need is an extinguisher.
Hi Brian
The assessments I am talking about is usually in the medium to high risk premises where fire crews have carried out an assessment which we call Operational Intelligence or OI. They have identified a disorientation potential or a complex layout in a fire situation and a control measure for this is to consider guidelines.
whilst I agree that you shouldn't have to put on the OI "guidelines required", what I would like to know on the OI is that if you are considering using guidelines, you should know if you can secure them properly.
Incidentally, I have seen an OI where it specifically states that guidelines will be required and goes on to confirm that there are sufficient tie off points.
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Dino it's a pity you never met Billy who used to post regularly on this forum. You and he have a lot in common. The fact is that there is much merit in what you say and the risk of firefighters becoming disorientated and lost in a building is one that must rightly be considered. Do you have a solution in mind? Can the scenario you describe be rectified? Are you suggesting that there should be legal powers to enforce the retrospective installation of tie off points in existing buildings and that potential disorientation of firefighters should be a consideration under the Building Regulations in England and Wales or the Scottish Tech Standards?
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It is surprising that arguably the single most dangerous situation faced by firefighters is smoke for all its risks and yet there has been little technology developed to address this. I seem to remember thermal cameras built into visors being looked at. Did this lead to anything?
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Dino it's a pity you never met Billy who used to post regularly on this forum. You and he have a lot in common. The fact is that there is much merit in what you say and the risk of firefighters becoming disorientated and lost in a building is one that must rightly be considered. Do you have a solution in mind? Can the scenario you describe be rectified? Are you suggesting that there should be legal powers to enforce the retrospective installation of tie off points in existing buildings and that potential disorientation of firefighters should be a consideration under the Building Regulations in England and Wales or the Scottish Tech Standards?
Well since you ask Kurnal- I do have a plan but it involves the fire services firstly doing a suitable and sufficient risk assessment and if they think they need guidelines, they will record this on the OI form.
If there are sufficient tie off points than all is well and these will be marked on the OI form.
If not, then they must tell the owner or occupier of the premises that we have assessed the risk to fire crews and we cannot use a guideline.
The Guideline is a recognised control measure to reduce the risk of disorientation within complex layouts in a fire situation.
Now here is the contentious issue- The fire Scotland act, section 53 (2) (a) states that ?Each employer shall?
(a) carry out an assessment of the workplace for the purpose of identifying any risks to the safety of the employer's employees in respect of harm caused by fire in the workplace;?
The million dollar question is- Under section (a) above, is the owner complying with the act if we tell them we can?t use our equipment that we need to use in a fire within his premises?
Would the fire service not being able to use this equipment constitute ?risks to the safety of the employer's employees in respect of harm caused by fire in the workplace;??
I also have a solution as well but would like people?s views on the proposals above.
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Dino it's a pity you never met Billy who used to post regularly on this forum. You and he have a lot in common. The fact is that there is much merit in what you say and the risk of firefighters becoming disorientated and lost in a building is one that must rightly be considered. Do you have a solution in mind? Can the scenario you describe be rectified? Are you suggesting that there should be legal powers to enforce the retrospective installation of tie off points in existing buildings and that potential disorientation of firefighters should be a consideration under the Building Regulations in England and Wales or the Scottish Tech Standards?
Well since you ask Kurnal- I do have a plan but it involves the fire services firstly doing a suitable and sufficient risk assessment and if they think they need guidelines, they will record this on the OI form.
If there are sufficient tie off points than all is well and these will be marked on the OI form.
If not, then they must tell the owner or occupier of the premises that we have assessed the risk to fire crews and we cannot use a guideline.
The Guideline is a recognised control measure to reduce the risk of disorientation within complex layouts in a fire situation.
Now here is the contentious issue- The fire Scotland act, section 53 (2) (a) states that ?Each employer shall?
(a) carry out an assessment of the workplace for the purpose of identifying any risks to the safety of the employer's employees in respect of harm caused by fire in the workplace;?
The million dollar question is- Under section (a) above, is the owner complying with the act if we tell them we can?t use our equipment that we need to use in a fire within his premises?
Would the fire service not being able to use this equipment constitute ?risks to the safety of the employer's employees in respect of harm caused by fire in the workplace;??
I also have a solution as well but would like people?s views on the proposals above.
Does disapplication for firefighting purposes apply in Scotland?
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It is surprising that arguably the single most dangerous situation faced by firefighters is smoke for all its risks and yet there has been little technology developed to address this. I seem to remember thermal cameras built into visors being looked at. Did this lead to anything?
You mention thermal imaging, this technology has come on leaps and bounds since it was first introduced but don't forget Positive pressure ventilation, this can be very successful in the right hands.
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The point that needs clarification is the status of the OI, is it just information provided for the OiC to assist them in carrying out the dynamic risk assessments at an incident or is it considered to be a risk assessment in itself?
If it is the former then IMHO it should record that it is a large and complex building and guidelines may be required. It is then up to the officers and crews at the incident to decide whether to use guidelines and if it is safe to do so. Bear in mind that under the H&S legislation there is a duty for the employees to look after their own safety. Under this the BA crews going in to lay guidelines are fully entitled to withdraw if they believe they cannot safely lay the guideline following their training. They can do this as they have responsibility for their own safety and also their responsibility for the safety of others.
If the OI is to be a risk assessment then forget about two sides of A4 you are looking at a book for some buildings, not only that but you are also looking at crews being on site for a long time completing the risk assessment.
About tie off points for guidelines the answer is simple: the crews laying the guidelines should be equipped with a percussion hammer fire bolts into the wall and then attach the guideline to the bolts, simples!
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The point that needs clarification is the status of the OI, is it just information provided for the OiC to assist them in carrying out the dynamic risk assessments at an incident or is it considered to be a risk assessment in itself?
If it is the former then IMHO it should record that it is a large and complex building and guidelines may be required. It is then up to the officers and crews at the incident to decide whether to use guidelines and if it is safe to do so. Bear in mind that under the H&S legislation there is a duty for the employees to look after their own safety. Under this the BA crews going in to lay guidelines are fully entitled to withdraw if they believe they cannot safely lay the guideline following their training. They can do this as they have responsibility for their own safety and also their responsibility for the safety of others.
If the OI is to be a risk assessment then forget about two sides of A4 you are looking at a book for some buildings, not only that but you are also looking at crews being on site for a long time completing the risk assessment.
About tie off points for guidelines the answer is simple: the crews laying the guidelines should be equipped with a percussion hammer fire bolts into the wall and then attach the guideline to the bolts, simples!
What about sky hooks?
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The point that needs clarification is the status of the OI, is it just information provided for the OiC to assist them in carrying out the dynamic risk assessments at an incident or is it considered to be a risk assessment in itself?
If it is the former then IMHO it should record that it is a large and complex building and guidelines may be required. It is then up to the officers and crews at the incident to decide whether to use guidelines and if it is safe to do so. Bear in mind that under the H&S legislation there is a duty for the employees to look after their own safety. Under this the BA crews going in to lay guidelines are fully entitled to withdraw if they believe they cannot safely lay the guideline following their training. They can do this as they have responsibility for their own safety and also their responsibility for the safety of others.
If the OI is to be a risk assessment then forget about two sides of A4 you are looking at a book for some buildings, not only that but you are also looking at crews being on site for a long time completing the risk assessment.
About tie off points for guidelines the answer is simple: the crews laying the guidelines should be equipped with a percussion hammer fire bolts into the wall and then attach the guideline to the bolts, simples!
Hi Mike
My whole point is that the BA teams should already know if we can use guidelines safely as if the OI is suitable and sufficient, it should have been already included in the OI which was done in normal office hours and with clear vision and not in a fire situation.
The DRA should therefore say whether it is safe to put crews into the building and not whether it is safe to use guidelines, as again, this should already be known.
As for percussion hammer bolts to be used by BA teams to secure a guideline, did GMC not try this and decided not to progress it?
With reference to the PUWER regs, the equipment must be suitable for use in the premises and conditions it is used- I cannot imagine a percussion hammer passing a risk assessment for being suitable for use in almost zero visibility.
As said previously, I have a solution and have already trialled it with operational fire crews who have said it is a great improvement in what they currently do.
And the one thing I have always admired about operational fire crews is their honesty where equipment is concerned- if my proposals were crap I would have heard it by now (only using different words but it would mean roughly the same as crap).
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I remember years ago we had a fire captain come over from the States on a visit to the fire station and we showed him with some pride how we would search a large open area with guide and branch lines doing a block search.
He watched with interest and then commented........"you mean you follow a piece of string into a burning building?" :)
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Dino I have heard you mention your solution a couple of years ago but you have never shared any more details with us.
We are interested, please give us a summary of what it is, what it does and how it is used. I fully recognise that you want to preserve some secrecy over your idea but currently it seems to be getting nowhere without publicity and wider support. You wont get it off the ground unless you create some demand.
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Dino I have heard you mention your solution a couple of years ago but you have never shared any more details with us.
We are interested, please give us a summary of what it is, what it does and how it is used. I fully recognise that you want to preserve some secrecy over your idea but currently it seems to be getting nowhere without publicity and wider support. You wont get it off the ground unless you create some demand.
Hi Kurnal
I totally agree with your comments and feel that this does need wider support or at least exposed to a wider audience for scrutiny and assessment.
Firefighters hate using guidelines because they have absolutely no faith in them and they don't work in their present form.
Any training venues we used for guideline training firstly had to be fitted with handles so we could actually secure the guidelines onto (if only we had this luxury at incidents)!
I carried out tests with the new design and the handles we fitted and got the following results.
Firstly, using handles to tie off the guideline
On average, crews use approximately 1.5 metres of line to tie off a guideline to a suitable object in a building.
It took them an average of 1 minute to locate a securing point and tie each knot.
During the trial, we had 10 securing points within the premises.
This meant that we used 25% of the line to secure it within the building to be searched.
It also meant that almost 25% of cylinder contents was used up whilst the crews were securing the Guideline instead of
searching off it.
We then tried the new design and got the following results
The crews used 20 cm of line to tie off each knot using the new design.
It took an average of 10 seconds to secure the line using the new design.
This meant that we only used 3% of the line to secure it within the building to be searched
The results also showed that a maximum of 3.5% of cylinder contents was used up whilst crews were securing the Guideline.
One of the most surprising results was that to get to the same point within the building, the crews using the new design used
50% less air than the previous crews.
Both crews were comparable in age and fitness and the crews who were securing the line in the conventional method stated that
they felt that was more stressful and may have contributed to them using more air.
Another factor in using less air to get to the same point was that they would have got there almost 7 minutes quicker.
I will put the details up later but I have got work to do just now.
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Dino
OI from site visits must form part of the Risk Assessment.
It may identify additional measures for FF safety.
A dynamic RA can be made on site based on what is in the OI and what is gleaned from site when there is a real fire
Dynamic RAs cannot be made on the hoof
davo
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Dino
OI from site visits must form part of the Risk Assessment.
It may identify additional measures for FF safety.
A dynamic RA can be made on site based on what is in the OI and what is gleaned from site when there is a real fire
Dynamic RAs cannot be made on the hoof
davo
Hi Davo
I agree 100% with all your comments but why would you put on an OI to consider Guidelines when you have not done an assessment within the same OI of whether you can use them properly.
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Dino
OI from site visits must form part of the Risk Assessment.
It may identify additional measures for FF safety.
A dynamic RA can be made on site based on what is in the OI and what is gleaned from site when there is a real fire
Dynamic RAs cannot be made on the hoof
davo
Hi Davo
I agree 100% with all your comments but why would you put on an OI to consider Guidelines when you have not done an assessment within the same OI of whether you can use them properly.
Perfect stuff guys where you have oodles of FT stations but, in general, not practical. How do you apply this to a PT situation? There is barely enough time for drill night training and whatever else they have to do.
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Dino what will you do if you cannot use them properly, ban there use in that building? I believe in the resourcefulness of firefighters they can usually find a way even if it is not perfect and what do you do if person are reported. Before you demonise guide lines or the lack of tie off points please research the fire in RAF Neatishead, Norfolk, 1966.
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Dino what will you do if you cannot use them properly, ban there use in that building? I believe in the resourcefulness of firefighters they can usually find a way even if it is not perfect and what do you do if person are reported. Before you demonise guide lines or the lack of tie off points please research the fire in RAF Neatishead, Norfolk, 1966.
Hi Tom
you asked what I would do if I cannot use them properly in a building and in my opinion, I would actually ban them for the following reasons and I would reiterate that this is based purely on Firefighter safety and protecting the Fire Services.
Most buildings we would consider using Guidelines in have already been visited by Fire Crews who have carried out an OI on the premises and some of these OI's actually say that we should consider Guidelines.
This leaves some services liable in my opinion under Section 2 of the HASAWA, the Management of Safety regs 1999 and also the PUWER regs.
I agree with you 100% that Firefighters are extremely practical and resourceful and could possibly secure it in some sort of fashion that may be of benefit. But in most cases they cannot secure them properly and my point is- why should they, when we already know the issues.
Searching these buildings is difficult enough and I do not know any Firefighter who has faith in using Guidelines so to ask them to be resourceful in a life threatening situation when we could make it safer for them is something I believe we do not have to do.
I am not demonising Guidelines but only wish that we start using them properly and for the benefit of the Fire Crews.
You mention the incident at RAF Neatishead and I am aware that some RAF bases similar to this one have pre-laid guidelines permanently fitted throughout the premises- I wonder of this was as a result of the incident you mentioned?
If so, it shows that other organisations believe that guidelines used in the right way and secured properly are of benefit to the people in their buildings.
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Dino If you decide a premises may need guidelines but because of the lack of tie off points, guidelines are banned and you get a persons reported to those premises do you enter without guidelines or take no action other than adopt a defensive role?
On 6 February 1966 at 1245 hours a fire broke out at a secret underground radar station at RAF Neatishead in Norfolk. It burned for 9 days. No personal lines - Team members got separated and lost, this lead to the death of 3 firemen. No main or branch guide lines - In the case of the former, the distance between the main entrance to the incident and the fire was some 500 yards. The hose being used as a guide line was so long and snaked under pressure that it was difficult and sometimes impossible to follow. As a result of the snaking travel distances were increased dramatically.
Following the lessons learnt at RAF Neatishead, the Central Fire Brigades Advisory Council issued FIRE SERVICE CIRCULAR 46/1969 in December 1969 following extensive trials by brigades. The Circular dealt with both the specifications and operational procedures for the use of guidelines, personal lines and branch lines. To provide more information, a number of diagrams of equipment were attached as an appendix
From an eyewitness "I've only seen black & white photos, they show an inkling of the real horror of what it must have been like for the firemen. We went in to the PBX room (1st right on the gallery above the main stairwell) and saw the blood-encrusted handprints of the fireman who died in there" I understand this was as a result of trying to find his way out of the room.
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Hi Tom
To be brutally honest, if I have done a suitable and sufficient risk assessment that indicates a complex layout and disorientation hazard to fire crews and I know there are no securing points for Guidelines, why would I send crews into this building with a guideline?
As mentioned earlier, I believe this action would go against numerous Health and Safety legislation and leave the fire service liable.
But if I know the risks and hazards and put on the OI that guidelines have not to be used I believe the services are still liable!
This is because I believe that if we know that we cannot use our equipment, we must make the owners or occupiers aware of this?
Could you imagine going to court and trying to justify that you never used guidelines because you couldn't secure them, only for the owner to say that you never told them of the issues, and if you did, they would have fitted them! The service would still be liable in my opinion?
This whole concept is not about turning up to a building that you have never inspected before but relates to buildings that crews have been in on numerous occasions and know full well the risks and hazards, and more importantly, have carried out an OI to lessen the risks to fire crews.
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Dino I have heard you mention your solution a couple of years ago but you have never shared any more details with us.
We are interested, please give us a summary of what it is, what it does and how it is used. I fully recognise that you want to preserve some secrecy over your idea but currently it seems to be getting nowhere without publicity and wider support. You wont get it off the ground unless you create some demand.
Hi Kurnal
I was busy earlier in the week and forgot to reply to your request above!
Everyone should be aware that there is a variety of signage throughout most modern buildings and this signage is generally accepted as being necessary within the premises.
The signage varies from Fire and Health and Safety signs to general direction signs and a lot of buildings now have asset management tags fitted on most doors and even on the door frames.
The proposal is to use these existing signs and adapt them to secure guidelines onto.
This would involve the sign instead of being fitted directly onto the wall, it would be fitted on a plate which would be the same size and shape as the sign.
This would be fitted using spacers between the wall and the plate to create a gap of about 4mm.
The guideline would simply be wrapped round the sign and secured with a half hitch knot. The 4mm gap creates an interference fit with the guideline and helps lock it in place.
Most of these existing signs are already located where they would be required such as near doors and exits and if you consider most door frames are around 12mm thick, the guideline plates would protrude less than the frames.
So the hope is that fire Services will do a suitable risk assessment and inform owners that they might need to use guidelines but cannot secure them properly.
The owner then has the choice to fit these signs or not and the fire service will record in their OI whether they can use guidelines safely in the premises- (subject to any DRA).
This from the outset has been driven by firefighter Safety and it is hoped that services will see this as an improvement on what we currently do.
I hope I have explained the concept sufficiently for people to comment on it but if you have any views or opinions on these proposals, they would be welcome.
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Do away with guidelines as existing.
Unless there is saveable life or property the likeliness is defensive tactics would be employed. By the time sufficient resources are available to commit with guidelines, (particularly bearing in mind how all Fire Services are being cut back minimum riders at best), it's highly unlikely there will be saveable life, the property will just be written off.
The problems and issues clearly demonstrated by the posts regarding this matter far out weigh the benefits; besides to be honest how often are they now used in anger!
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What would you do if you attended a person reported in a premises that had a complex layout and disorientation hazard to fire crews and you know there is a limited securing points for Guidelines (I have never attended a premises where there is no securing points). Leave the possible victims to their own devices or go in with or without a guideline?
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What would you do if you attended a person reported in a premises that had a complex layout and disorientation hazard to fire crews and you know there is a limited securing points for Guidelines (I have never attended a premises where there is no securing points). Leave the possible victims to their own devices or go in with or without a guideline?
Hi Tom
the exact scenario you have given above is what most fire services do at this point in time and the horrible decision that the OIC has to take!
Most officers will not use them because of the lack of faith in them by the crews and we need to have an awareness of the amount of firefighter deaths we have had in large buildings.
A poorly laid guideline in my opinion is more dangerous than no guideline at all, but the point I am making is relating to the majority of buildings where we have carried out a risk assessment with regards to the safety of crews.
We have deemed there is a disorientation hazard and on occasions told the OIC to consider guidelines- without assessing if they can be used.
So basically, you are asking if I would use a guideline in a building where I knew I could not secure it as per laid down procedures?
If I made a decision to use a guideline under these circumstances, in my opinion, I would be contravening the following legislation:
HASAWA section 2 (a)- Using a guideline without proper securing points is not a safe system of work
HASAWA section 2 (c) firefighters have not had sufficient instruction information and training on how to lay a guideline when there are no securing points.
Management of Health and Safety regulations 1999- it could be argued that we have not carried out a suitable and sufficient risk assessment with regards to the risks to the health and safety of our employees.
Provision and use of work equipment regs 1998, section 2 states: In selecting work equipment, every employer shall have regard to the working conditions and to the risks to the health and safety of persons which exist in the premises or undertaking in which that work equipment is to be used and any additional risk posed by the use of that work equipment.
So I think I could justify not using a guideline and if you want to play devils advocate, it could be argued that with my research into this subject, I would have guilty knowledge if I used one without ensuring the premises had been assessed as being suitable.
But if I was OIC at an incident, I would send crews in without a guideline and at greater risk to themselves to try and save, saveable lives or property.
And I would be praying to God that this incident never went to a FAI or my crews never got injured in a building when they weren't using a guideline when it said on the OI to consider guidelines.
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Do away with guidelines as existing.
Unless there is saveable life or property the likeliness is defensive tactics would be employed. By the time sufficient resources are available to commit with guidelines, (particularly bearing in mind how all Fire Services are being cut back minimum riders at best), it's highly unlikely there will be saveable life, the property will just be written off.
The problems and issues clearly demonstrated by the posts regarding this matter far out weigh the benefits; besides to be honest how often are they now used in anger!
Hi Bruce89
Your views and opinions are based on the premise that guidelines cannot be used safely and I totally understand that point of view.
but I have done tests where crews could secure the guideline in under 10 seconds and used 50% less air to get to the same point within a building.
The guideline was also laid tightly, at waist height and was easy to follow and search off.
And until we do get rid of them, do you not think we should be doing everything we can to make them as safe as possible?
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Very much a case of dammed if you do and dammed if you don't.
If you don't send the crews in to rescue someone on the grounds of H&S involving guidelines you will get the headlines 'Firefighters refuse to rescue victim on grounds of Health and Safety'.
If you send a crew in without guidelines and they get lost and die 'Haven't the Fire Brigade learnt anything from Neatishead and Smithfield Market?'
Guidelines are a solution, all be it not a very good solution but until someone comes up with something better, they work. They have drawbacks and the only way to reduce the drawbacks is constant practice laying and following guidelines in zero visibility conditions.
Your idea of tie off points seems a reasonable solution however persuading businesses to fit them is a totally different issue.
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Dino thanks for sharing your idea with us and I agree your idea has merit- but it will not take off without national recognition and impetus through national guidance such as ADB / Tech standards and criteria for its use. Biggest obstacle is who will pay?
New builds are unlikely to require your system if compliant with ADB unless adopted as part of a fire engineered solution and existing buildings in England there is no legal basis for retro fitting. Insurers may see it as a good idea and take it on board?
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And until we do get rid of them, do you not think we should be doing everything we can to make them as safe as possible?
Yes Dino I do.
However the fact remains ICS was nothing like it is now and I reiterate with all the cuts resulting in fewer appliances and bums on seats, by the time sufficient resources are in attendance it's highly likely there would no longer be saveable life. It would be interesting to send a FINDS message and see nationally how often guidelines have been used to successfully save life in the past 12 months.
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And until we do get rid of them, do you not think we should be doing everything we can to make them as safe as possible?
Yes Dino I do.
However the fact remains ICS was nothing like it is now and I reiterate with all the cuts resulting in fewer appliances and bums on seats, by the time sufficient resources are in attendance it's highly likely there would no longer be saveable life. It would be interesting to send a FINDS message and see nationally how often guidelines have been used to successfully save life in the past 12 months.
Hi Bruce89
I know of incidents where the fire was going for over an hour and they still got people out alive so to put a time limit on when there is saveable life is very difficult and even more problematic if you have to do it in a court of law!
you mention saveable life but this is also about Firefighter safety and changing the culture with regards to guidelines. so instead of them being a piece of equipment that most have no faith in, they become something that gives fire services a better chance of saving lives and also preserving the lives of crews.
We seem to have forgot that guidelines are there to make it safer for fire crews and should be classed as a control measure in certain situations to reduce the risk to crews. That is their primary function and to use them to rescue someone and save their life is a bonus IMO.
The FINDS message you mention would probably have more significance if you asked how many OIC's put crews into fires in large buildings with complex layouts in the past 12 months without guidelines because they had no faith in their use?
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Dino thanks for sharing your idea with us and I agree your idea has merit- but it will not take off without national recognition and impetus through national guidance such as ADB / Tech standards and criteria for its use. Biggest obstacle is who will pay?
New builds are unlikely to require your system if compliant with ADB unless adopted as part of a fire engineered solution and existing buildings in England there is no legal basis for retro fitting. Insurers may see it as a good idea and take it on board?
My hope for this to progress was to use existing legislation and this would require the Fire Services to look at the way they carry out their risk assessments for the safety of fire crews.
I hope that we are in agreement that the current method of recording the fact that guidelines may be required without assessing if you can actually secure them is flawed and will leave fire services open to challenge with regards to numerous health and safety legislation?
For fire services to cover themselves, they must assess if guidelines are required and also if they can be secured properly, and this information must be available to the OIC if an incident arises.
Now if there are insufficient securing points, I believe the fire services should tell the owner and give them the opportunity to take remedial action.
At this point, if the owner does not provide securing points, my argument is that he is not complying with the
Fire Safety Act 2005, 53 Duties of employers to employees, where section (1) states: Each employer shall ensure, so far as is reasonably practicable, the safety of the employer's employees in respect of harm caused by fire in the workplace.
Now if the fire services have carried out a robust assessment and have concluded that they cannot use guidelines safely within that building, they are within their rights IMO to record this and to let the owners /occupiers know this as well.
At this point, when the owner/ occupier is made aware that we cannot use equipment to fight fire and possibly rescue people, should a fire occur, are they complying with (1) above?
kurnal, you mentioned insurers and the insurance companies may be key to this for the following reasons:
These companies, like most businesses, are driven by making money for their shareholders and all claims will be challenged and scrutinised to ensure the policy holders were complying with the policy and other related legislation.
If they can prove that the owners did not comply in any way, or that the fire services were not complying with legislation, they will use this to reduce any claim.
It could be reasonable for fire service tell an owner that they cannot use their equipment safely and will therefore not use it unless the owner fits securing points.
I would not like to be an owner of a premises in a court of law trying to justify why they never fitted securing points.
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Dino forgive me if I have misunderstood your point and sorry to be pedantic but it is really important to use and quote the correct and appropriate legislation.
The Regulatory Reform (Fire Safety) Order 2005 covers general fire safety in England and Wales.
In Scotland, requirements on general fire safety are covered in Part 3 of the Fire (Scotland) Act 2005, supported by the Fire Safety (Scotland) Regulations 2006.
Theres also separate legislation covering Northern Ireland.
The point is that the Legislation is very different in Scotland to that in England and fire fighter safety is covered differently. I think you may be based in Scotland.
You can download the E&W legislation here:- http://www.legislation.gov.uk/uksi/2005/1541/pdfs/uksi_20051541_en.pdf
See in particular the definition of relevant persons on page 6 and article 38 - maintenance of measures provided for protection of fire fighters. The duty is to maintain any facilities equipment and devices that have been provided under other legislation - but there are no duties to install anything for use by fire fighters under the Fire Safety Order 2005.
The Scottish Legislation can be downloaded here:-
http://www.legislation.gov.uk/asp/2005/5/pdfs/asp_20050005_en.pdf
See in particular Section 59 on page 28 - referring to the power of the Scottish Ministers to make regulations for the protection of firefighters.
Lets take the discussion on from there.
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Thanks for your clarification Kurnal- I thought we jocks just took the legislation and added words like "aye, ken and whit" but now you have put me right :)
The point I was trying to make is that if we cannot use our equipment such as guidelines within premises, the relevant persons could be at greater risk.
I am aware that fire service personnel are not classed as relevant persons under Scottish, English and Welsh legislation.
I have previously quoted the Scottish legislation but under the Regulatory Reform (Fire Safety) Order 2005 in England and Wales,Risk assessment
9.?(1) The responsible person must make a suitable and sufficient assessment of the risks to
which relevant persons are exposed for the purpose of identifying the general fire precautions he
needs to take to comply with the requirements and prohibitions imposed on him by or under this
Order.
My question here is- should the responsible person take into account the risk assessment carried out by the fire service?
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In E & W the fire safety legislation requires the RP to conduct a FRA and consider the general fire precautions which are detail in article 4.
In Scotland the fire safety legislation requires the duty holder to conduct a FRA and consider the fire safety measures as are necessary, as detailed in schedule 2.
Which doesn't include fire service personal and why should he consider the ORA unless he has a legal requirement to do so, dino I think you are grasping at straws.
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The point I was trying to make is that if we cannot use our equipment such as guidelines within premises, the relevant persons could be at greater risk.
Sorry dino, that one phrase sums up what is wrong with your argument. If the Resposible Person is reliant up fire service intervention to reduce the risk to relevant persons to an acceptable level then the buildings fire strategy is flawed.
Whilst I have no problem in the fire service documenting in site specific information any information you want, you can't expect fire risk assessors to be familiar with operational procedures and incorporate them into the building.
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Thought I would throw this in to the pot.
http://www.irishtimes.com/news/crime-and-law/courts/council-criticised-in-bray-firefighters-inquest-verdict-1.1790117
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NT I'm not sure that scenario is relevant to gathering information about the specific premises or the use of guidelines but more about pre-determined operational plans and the associated training. The factory unit was derelict with no need to use guidelines as it was very small - from what I've seen the issues leading to these tragic circumstances came well before the crews attended the fire and the unfortunate set of events that followed were as a consequence of these failings. As an IC I was always loathe to commit crews to a derelict premises (although there is always the possibility of vagrants or children inside) and this fire could have been brought under control from outside before committing crews. I think there is a difference between the 'normal' building and the exceptional risks when undertaking information gathering visits - for example I always insisted on crews visiting those premises that needed pre-planning rather than, for example, a garage or workshop where you would expect cylinders or flammable liquids to be stored.
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In E & W the fire safety legislation requires the RP to conduct a FRA and consider the general fire precautions which are detail in article 4.
In Scotland the fire safety legislation requires the duty holder to conduct a FRA and consider the fire safety measures as are necessary, as detailed in schedule 2.
Which doesn't include fire service personal and why should he consider the ORA unless he has a legal requirement to do so, dino I think you are grasping at straws.
Thanks for the comments Tom
I do agree that my trying to link current legislation to help strengthen the case to fit securing points might be grasping at straws and maybe I should be looking at other legislation or approach it from a different angle.
What I hope I have agreement on is that the current recording of risk information on premises that some fire services use is not suitable and sufficient and could be challenged.
To make it suitable and sufficient, fire services should assess if they may need guidelines and also assess if they can use them safely.
In my opinion, I believe that fire services should tell the responsible person if fire crews cannot use guidelines safely and the responsible person will have the choice of fitting securing points or not.
And there may be no legal requirement for the responsible person to fit them but i believe that this risk assessment by fire services would help protect fire crews at incidents and also the service as a whole with regards to any claims against them.
Your comments and opinions on this topic are greatly appreciated.
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NT I'm not sure that scenario is relevant to gathering information about the specific premises or the use of guidelines but more about pre-determined operational plans and the associated training. The factory unit was derelict with no need to use guidelines as it was very small - from what I've seen the issues leading to these tragic circumstances came well before the crews attended the fire and the unfortunate set of events that followed were as a consequence of these failings. As an IC I was always loathe to commit crews to a derelict premises (although there is always the possibility of vagrants or children inside) and this fire could have been brought under control from outside before committing crews. I think there is a difference between the 'normal' building and the exceptional risks when undertaking information gathering visits - for example I always insisted on crews visiting those premises that needed pre-planning rather than, for example, a garage or workshop where you would expect cylinders or flammable liquids to be stored.
Yes I know. Just thought I would throw it in as I said.
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Hi guys
I really appreciate all your comments and I am looking for legislation to help get this design into buildings to improve firefighter safety and help them to save saveable buildings and save lives.
I believe Fire Services should be looking at implementing some of the systems I mentioned to protect themselves from litigation and comply with statutory legislation such as HASAWA, PUWER, and Management of Health and Safety regs.
I do agree that I am grasping at straws with the English Fire Safety legislation but feel that the Scottish regs may be able to be used to strengthen this argument.
Fire (Scotland ) Act 2005
FIRE SAFETY
CHAPTER 1
FIRE SAFETY DUTIES
Duties
53 Duties of employers to employees
(1) Each employer shall ensure, so far as is reasonably practicable, the safety of the employer's employees in respect of harm caused by fire in the workplace.
(2) Each employer shall?
(a) carry out an assessment of the workplace for the purpose of identifying any risks to the safety of the employer's employees in respect of harm caused by fire in the workplace;
The question I am asking is under the above legislation, if we tell an employer that we cannot safely use guidelines in their building in the event of a fire- do they need to take it into account during their assessment in respect of harm to their employees in respect of harm caused by fire in the workplace?
I would have thought that if we cannot use our equipment that we may need to help us extinguish the fire and possibly save lives, this would constitute a risk to the employers employees?
Your views and opinions on this would be most welcome.
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My view would be that this is irrelevant to the use of guidelines. The whole thrust of the Fire Safety Legislation is that the employees and relevant persons can be safely evacuated in the event of fire without the intervention of the fire service. Therefore if the fire risk assessment states that guideline securing points are required to assist the fire service to rescue our people it immediately admits that the Responsible Person has failed to carry out his duties to take reasonable fire precautions.
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My view would be that this is irrelevant to the use of guidelines. The whole thrust of the Fire Safety Legislation is that the employees and relevant persons can be safely evacuated in the event of fire without the intervention of the fire service. Therefore if the fire risk assessment states that guideline securing points are required to assist the fire service to rescue our people it immediately admits that the Responsible Person has failed to carry out his duties to take reasonable fire precautions.
Hi Mike
I do understand your point about the relevant persons being safely evacuated without the intervention of the Fire Service but I still feel that any assessment of the workplace for the purpose of identifying any risks to the safety of the employer's employees in respect of harm caused by fire in the workplace should take into account the fact that we cannot use our equipment properly and have told the owners this.
whether this falls under 53 (2) (a) of the act or not, I still feel that services should be making the owners aware and let them make the choice.
My aim firstly is to try and get the Fire Services to protect themselves and more importantly. their crews in relation Operational Intelligence in complex buildings.
If I can get the Services to consider these proposals, the arguments about who may or may not be liable should an incident occur can be taken up by people who are far better at it than myself. :)
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Whilst I appreciated your feelings on the matter, this issue does not come under the RRO or its offshoots, there is no mention of guideline tie off points in Building Regulations or the Technical Handbook etc. Also in the legislation that preceded the RRO etc. where the Fire Brigade provided Fire Certificates with plans for the fire precautions required in a premises there was similarly no reference to the fire brigades using guidelines.
Another aspect to consider is that the philosophy behind the RRO etc. is that the person who was competent to carry out a risk assessment did not have to be ex fire service and you really have to be an experienced operational firefighter to understand the issues involved in laying guidelines. I will stick my head above the parapet and say, not only are fire risk assessors not all experienced fire fighters but, these days, neither are the inspecting officers from the fire brigades.
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I understand where the thoughts of ex firefighters doing FRAs would be with regards to trying to help ffs deal with a fire as safely as possible but I agree that tie off points have nothing to do with an Assessment. Neither does a requirement to leave all the lights on at night or keep final exit doors open for use by the fire service.
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The way I see it is as follows and I do agree I may be biased here so feel free to correct me.
1. if the fire service do an OI of a complex building and they put on the OI to consider guidelines- they should also assess if the guidelines can be secured properly.
2. if they cannot be secured properly, we have a duty to tell the owner that we cannot use our equipment safely.
3. If we cannot use our equipment safely and we have told the owner that we cannot use our equipment safely- does this affect the owners risk assessment in relation to risks to the safety of the employer's employees in respect of harm caused by fire in the workplace?
4. whilst I agree that the fire service should not be part of any risk assessment- does the guilty knowledge that we cannot use our equipment safely increase the risk to the employees.?
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The way I see it is as follows and I do agree I may be biased here so feel free to correct me.
1. if the fire service do an OI of a complex building and they put on the OI to consider guidelines- they should also assess if the guidelines can be secured properly.
2. if they cannot be secured properly, we have a duty to tell the owner that we cannot use our equipment safely.
3. If we cannot use our equipment safely and we have told the owner that we cannot use our equipment safely- does this affect the owners risk assessment in relation to risks to the safety of the employer's employees in respect of harm caused by fire in the workplace?
4. whilst I agree that the fire service should not be part of any risk assessment- does the guilty knowledge that we cannot use our equipment safely increase the risk to the employees.?
Does this take FFs out of Dino's Point 3.
Disapplication of certain provisions
7.
(4) The requirements of articles 8 to 23, or of any regulations made under article 24, do not have effect to the extent that they would prevent any of the following from carrying out their duties?
(a)any member of the armed forces of the Crown or of any visiting force;
(b)any constable or any member of a police force not being a constable;
(c)any member of any emergency service.
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I think you have to look at it from a different point of view.
Would anybody consider the following acceptable?
Employees working in this area are safe because the Responsible Person has installed tie off points so that the fire brigade can use guidelines to go and evacuate them through the thick smoke when the building catches fire!
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I think you have to look at it from a different point of view.
Would anybody consider the following acceptable?
Employees working in this area are safe because the Responsible Person has installed tie off points so that the fire brigade can use guidelines to go and evacuate them through the thick smoke when the building catches fire!
Hi Mike
I do agree with your analogy but are the employees at greater risk because the fire service has deemed that we cannot use our equipment safely and may not be able to safely go through thick smoke when the building catches fire?
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No, because the employees should have evacuated the building before the fire brigade arrives.
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If that was always the case then we wouldn't need firefighters to enter the building
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No, because the employees should have evacuated the building before the fire brigade arrives.
Hi Mike
I am not disagreeing with you but another analogy is the fact that some buildings need access to all sides for fire appliances.
If the owner is carrying out work that prevents this access- does this affect the owners risk assessment in relation to risks to the safety of the employer's employees in respect of harm caused by fire in the workplace and should they include this in their risk assessment?
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Dino
That is covered in the order:
Section 9
(3) Any such assessment must be reviewed by the responsible person regularly so as to keep it
up to date and particularly if?
(a) there is reason to suspect that it is no longer valid; or
(b) there has been a significant change in the matters to which it relates including when the
premises, special, technical and organisational measures, or organisation of the work
undergo significant changes, extensions, or conversions,
and where changes to an assessment are required as a result of any such review, the responsible
person must make them.
The major question would be do the proposed work affect the people inside the premises either from an increased risk of fire or their ability to evacuate in the event of a fire?
Wee Brian notice I used the word 'should'.
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Dino
That is covered in the order:
Section 9
(3) Any such assessment must be reviewed by the responsible person regularly so as to keep it
up to date and particularly if?
(a) there is reason to suspect that it is no longer valid; or
(b) there has been a significant change in the matters to which it relates including when the
premises, special, technical and organisational measures, or organisation of the work
undergo significant changes, extensions, or conversions,
and where changes to an assessment are required as a result of any such review, the responsible
person must make them.
The major question would be do the proposed work affect the people inside the premises either from an increased risk of fire or their ability to evacuate in the event of a fire?
Wee Brian notice I used the word 'should'.
Hi Mike
Here is the definition of 'special, technical and organisational measures' from the Fire Safety (Scotland) regulations 2006
?special, technical or organisational measures? means those measures required to be taken or
observed in any workplace in connection with the carrying on of any work process, where
those measures?
(a) are designed to prevent or reduce the likelihood of fire arising from such a work process
or reduce its intensity; and
(b) are required to be taken or observed to ensure compliance with any requirement of the
relevant statutory provisions within the meaning given by section 53(1) of the Health and
Safety at Work etc. Act 1974(a) and those measures include?
(i) technical means of supervision;
(ii) connecting devices;
(iii) control and protection systems;
(iv) engineering controls and solutions;
(v) equipment;
(vi) materials;
(vii) protective systems; and
(viii) warning and other communications systems;
So the question is- could the fitting of securing signs to allow fire crews to carry out their job be considered as "special, technical or organisational measures"?
I already concede that I am biased so I would welcome the views and opinions of more knowledgeable and impartial people.
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Look at the definition of special, technical or organizational measures.
(a) are designed to prevent or reduce the likelihood of fire arising from such a work process
or reduce its intensity;
Can you argue that tie off points would achieve this? bear the principle of both the RRO and the Fire Safety Scotland Regs is to prevent fire breaking out in the first place and enable people to escape from the fire.
(b) are required to be taken or observed to ensure compliance with any requirement of the
relevant statutory provisions within the meaning given by section 53(1) of the Health and
Safety at Work etc. Act 1974(a) and those measures include?
The duties under HSAWA apply to employees and other persons resorting to the premises, in general the emergency services are not classified as persons resorting.
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Hello - no these would not constitue a fire risk asessment as they are only to judge risks for attening fire personenel ona fire call. The building will still require a FRA.
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Hello - no these would not constitue a fire risk asessment as they are only to judge risks for attening fire personenel ona fire call. The building will still require a FRA.
Hi Fire Monkey
I agree with your comment but the information we have on fire appliances will constitute a risk assessment for fire crews under the Management of Health and Safety Regs 1999.
What i cannot get my head around is I believe that almost all fire services are breaching the 1974 HASAWA in relation to BA guidelines as:-
1. None that I know of have a safe system of work.
To have a procedure where you have Operational intelligence stating you should consider guidelines but not assess if you can use them safely would fail to be classed as a safe system of work.
Getting a BA team to assess in a fire situation if there are suitable securing points when crews have already done an O I on the premises and failed to do a suitable and sufficient assessment would also not be classed as a safe system of work.
2. None that I know have sufficient procedures for Instruction, information, training and supervision in relating to BA Guidelines.
Instructing crews to assess the suitability of guidelines in relation to securing points, during a fire situation when the O I crews did not assess this would bring the instructions into question.
Again, to have information stating to consider guidelines and not have assessed if you can use them would bring the information into question.
To have to fit tie off handles in training facilities as everyone knows you cannot use guidelines safely if they are not properly secured makes any training totally unrealistic to what you would find in premises where we would use Guidelines for real!
These two points above are where most Fire Services contravene the HASAWA and I believe the HSE would find it relatively easy to prove non-compliance in relation to almost every fire service in the UK should an incident arise at a complicated or large premises and the HSE had to carry out an investigation.
I would be grateful if anyone could add their opinion to these comments as I thought that fire services would wish to comply with legislation, especially some who have already experienced, and are still experiencing the consequences of non-compliance.
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Sorry to go on about this again guys but sometimes I think I am being too simplistic in relation to this subject and there must be more to it.
I spoke to a Senior Officer about 4 areas of legislation where I feel we don't comply with, namely the HASAWA sections referring to the procedure being suitable and sufficient, and sufficient instruction, information, training and supervision, as well as the Management of Health and Safety regs 1999 and the PUWER regs.
I was really surprised when he responded by stating that there are loads of areas where we don't comply with statutory legislation!
So am I being too simplistic by thinking that if we don't comply with statutory legislation and anything goes wrong, this non compliance will be used against the Fire Service?
And based on the information posted previously on this thread, do other people agree that some Fire Services may not be complying with the legislation mentioned above?