FireNet Community
FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Bill J on September 05, 2005, 02:27:20 PM
-
I know this has been debated till the cows come home, and I have watched with interest both sides.
When Assessing I almost always compile a single line sketch for myself, as often the Fire Certificate Drawings are not available until I get to site, and are the only copy, so clients would not be happy with my clumsy scrawling over them.
2 Questions....
Is there any way in which I can get the drawings before going to site? Electronically or Hard Copies would be Ok. Managing Agents rarely bother to have a copy away from site, and almost never send one to me. Most of the work I complete is in the London area.
What is going to happen to all of this (IMHO) Vital information now that Fire Certificates are no longer being issued, will these drawings become a lost resource.
Thanks in advance.
-
Bill,
I always try to get the drawings copied before I go to site. Most good printing companies such as Prontoprint copy up to AO size.
I also have Autocad / PDF facility, therefore if an electronic version is available I ask for this. I can print just over A3 so this can be useful. Most large companies have facility for this inhouse.
Agree, the need for this to be captured in the FRA is essential as Fire Certs will go. It is also useful if putting together a building emergency file that indicates key isolations / hazards / useful info etc.
Paul
-
Try as I do, I rarely get to see the drawings before I arrive on site, I normally take a photograph of the Site copies, (if there are any), but thats no good for note taking.
I was wondering if there is a way to obtain the existing drawings held by local Fire Authority before going. Also as the majority of buildings have a Fire Cert at present, what is going to happen to the files, when the FA are no longer interested?
I hope some enterprising Individual keeps a copy......now theres a thought.
Bill
-
Some brigades have CAD files of the plans and will send you everything on CD instead of printed copy (same price though!)
However this only works with certificates of recent vintage - some premises have quite old plans that will have been hand draughted & only exist in print.
I always try & get plans even thought the flor layouts are usually wrong as the core stairs & escapes usually are the same 7 it's a useful memory jogger to the building
-
This will give some idea of the thinking behind the RRO with regard to plans. These Q and A have been copied from the Minute so Evidence of one the RRO Committe reports .
Q91 Mr Brown: CFOA and the FBU have both stressed the importance of building plans in preparing risk assessments and thereby providing assistance to fire fighters should the need arise. The proposed Order contains no requirement for plans to be attached to risk assessments and no power for enforcing authorities to provide plans. Why does not the proposed Order require relevant persons to provide building plans alongside their risk assessments?
Phil Hope: The purpose of the risk assessments is to target activity on those areas of buildings and properties most at risk. When the Fire Service does its inspections and looks at those buildings, the responsible person for those buildings has the responsibility to ensure that the building does conform to the fire safety regulations. Upon inspection, the authority does have the ability to check that that is in line with what is safe and to recommend changes if there are breaches. Ultimately, they do have the sanction of taking the responsible person to court if that does not work but we are pretty confident that that interaction between the fire and rescue authority and the owner of the building or the person responsible will create the improvements to ensure that the building is as safe as it needs to be.
Mr Jack: The Order as drafted provides for the provision of reasonable information to the fire authority. If plans exist, CFOA and the FBU would expect to be able to see them and perhaps to mark the location of fire fighting equipment. The Order as drafted would allow them to do that. It allows for obtaining the documents and so forth and for reasonable information to be provided by the responsible person or any other person who appears to have that information within the premises concerned. What the Order would not allow for would be for a fire authority to demand perhaps an architect to be appointed to specially draw up plans just for this purpose. That would seem overly burdensome.
Q92 Mr Brown: It makes sense that that information should be made available. Do you feel, if there was a statutory requirement to provide plans alongside risk assessments, there would be a substantial burden on the relevant persons?
Phil Hope: Yes. We feel, through the consultation, we have made the right judgments.
-
I've been asked for plans by two fire authorities. They can have them with pleasure - so long as they pay a proper fee. There was no further discussion!
-
Regulation 27 (c) of the RRO, Powers of Inspectors states that they may "require the production of...any records (including plans)
...which are required to be kept by virtue of any provision of this Order...
This was a fairly late addition, possibly after the Scrutiny Committees.
BS 5588 Part 12, Management of Fire Safety, also makes it clear that the 'fire safety manual' would need detailed plans showing all fire safety measures including the usual M o E, smoke control, provisions for disabled persons, etc. (Indeed, fully complying with this standard would effectively re-introduce certification to ALL premises via the back door)
My FRS will interpret this as allowing us to require plans in those premises where it would be almost impossible to demonstrate compliance with just a written FRA, for example shopping centres or entertainment complexes.
Ian, your FRA and the management of the relevant premises better be very good if you try that trick with me!
-
Be nice to know what Fire Authority you represent.
-
I agree with Ian. There is no requirement for plans with an FRA, and Mr Jack is right. It would double the costs of an FRA if plans were to be produced. A fire safety manual is a whole different animal from a FRA. The palns bring nothing to the table as far as recording the significant findings of an FRA are concerned.
-
Just to clarify a little more: I do object to fire officers requesting plans when they already have plans on file (and before anyone suggests it - this is very rare indeed - unless they've thinned their files and dumped them!). And also when they are now making their plan tracers/drawers redundant!
Furthermore, to be requesting up to date plans fully marked with all fire equipment (really as per what would have been attempted for a fire cert) is not reasonable for the reasons Colin has stated - and mine ie cost.
Carol (not 'Tom' is it?) you would have difficulty enforcing your requirement I feel, as this is really about making life easy for inspecting officers - rather than ensuring the building's fire precautions and management were reasonable. Have you discussed this with your legal dept?
I knew this problem would arise, however, Chief Fire Officers have not.
The bottom line is that inspecting officers may well now have to spend more time on their inspections - and know what they are doing. Ask anyone who used to inspect buildings with the old s40 Factory Act or s29 OSRA certs!
-
I am sure that Glynn Evans from the FBU raised this with the RRO scrutiny committee. They decided that plans would not be a requirement.
-
We have rather hijacked the initial post but heh...
In auditing/checking/enforcing/inspecting the significant findings of a FRA I still hold that it would be next to impossible, in complex premises for the responsible person to do this without a plan.
I am aware of the school of thought that says FRS should confine themselves to auditing the methodology empolyed to carry out the FRA, (fine system published by Colin via the BSI), but this would not, in my opinion, enable the FSO to fully confirm that the Order is being complied with. If this was the case then we should just require the responsible person to forward a bald statement listing the British Standards complied with and the Third Party Accreditation utilised.
I did not say that plans could be required as a matter of course, just that FRS have the power to require them 'where necessary'...to use that lovely term. 'Where necessary', because the Government cannot bring itself to define, will no doubt be decided in the Courts.
Maybe Andy Jack is being a good civil servant, but he told me that plans could, in certain circumstances, be required.
And Ian, as I am, pretty much the legal advisor, I look forward to letting some crusty Judge decide whether it is an intolerable burden on 'Bluewater' to include plans.
-
We need to distinguish between various things, which are becoming muddled. There is the legislation itself, and there is the FRA, which is just one requirement of the legislation. Then,there is compliance with the Regs and there is inspection/enforcement to confirm compliance. Taking these in turn, there is no specific requirement for an FRA to include a plan. Let the crusty judge decide Carol, because if your fire authority push this (which it is unlikely your senior officers would allow you to do, lets not bull****) there are plenty of us who will be happy to convince him on the subject. It is also nonsense to say that a fire risk assessment cannot be done without a plan. Plans are becoming a luxury, which people carrying out fire risk assessments every day are not afforded the benefit of having available to them. Its time to stop living in the past and yearning for the old fire certs, most of which had drawings that did not reflect the premises as they are anyway. An FRA is not a fire cert. A fire safety manual is another animal entirely, and ideally would have a set of plans. It is NOT the FRA. The illustrious Mr Jack (who I was just musing to myself this morning, will no doubt put on his CV when he moves role about all the fine work he did in reshaping fire safety legislation, but will not mention the mess he has left behind for hands on practitioners) may have been referring to the emergency plan, and not the FRA. It, again, is a different animal and is a requirement of legislation.
Now we turn to enforcement of the legislation. Oh dear oh dear, I am reading more hankering back for the good old days of our old friend the FFO (fascist fire officer) doing a complete and detailed inspection of the building. Oooops, these days are no more. They went out with mains radios and wee men who checked your oil while they filled the car up with fuel. Nostalgic I know, isn't it, but there are very few aggressive and arrogant I/os left any more (OK Messey, I know you keep some that you just cant bear to get rid of), but they went out with the concept of it being his role to sort out the fire precautions in the premises. There will be no, or very few, thorough and detailed inspections. It will be sampling and lots of discussion with management, given the new realisation, which most FRSs are forward looking and signed up to, that inspection and enforcement does not involve looking in every nook and crannie. There will be a lot more coffee drunk by I/Os under the new regime, while they investigate whether management are complying.
-
I shouldn't bite.
I believe I work for an enlightened FRS. I did not say a FRA was a fire certificate, I am always willing to work with the responsible person, (must more productive than forcing people to do things), I am also well aware of all the distinguishing features or FRA, emergency plans, fire safety manuals, etc. I also know what sampling is, the need for better targeting, risk based inspection policies, enforcement management models...have I forgotten anything? We also subscribe, where appropriate to the concept of advice and education rather than inspection and enforcement. Is that modern enough for you?
And please don't patronise me about my wee senior officers keeping me in check!
I think your outlook on fire safety, as practised, is coloured by the fact that you carry out FRA for organisations that have invited you in, are prepared, having paid you for professional advice, to carry out most of what you recommend.
The sort of places I normally visit/inspect still haven't heard of the WP Regs and fire safety is usually bordering on the 'section 10' state. The responsible person, when you can find them, has absolutely no intention of complying with legislation and will do everything to frustrate the FSO. Against this background we attempt to be business friendly, consider their financial woes, devise agreed action plans which are generally ignored and eventually after about two years find they have sold up and we start all over again. Bet you don't have these problems with the "a customer" [Admin Edit].
To return to the law. I have copied out bits of Reg 27.
"...to enter any premises which he has reason to believe it is necessary for him to enter for the purpose mentioned above and to inspect the whole or part of the premises
(c) to require the production of, or where the information is recorded in computerised form,
the furnishing of extracts from, any records (including plans)—
(i) which are required to be kept by virtue of any provision of this Order or regulations..."
I emphasise the 'whole or part of the premises' and regarding plans, we can of course interpret it in two ways...the production of 'something that doesn't already exist or the production of, with a flourish, 'something that does.'
Perhaps the definition of the words 'production of' mean something else north of the border!
Enforcement is easy when organisations are willing to comply.
You are wrong about the cups of tea, we used to get these when we inspected cosy office blocks!
-
Nice balanced view of life. If there are no plans its difficult to require an extract to be furnished. And you know quite well certainly at present your senior officers would not allow yo to go the distance, so keep dreaming about a brave new world, because it is not going to happen. (And the customer [Admin Edit] do have a fire safety manual for every premises in the land.)
-
I've edited the above two posts, please avoid mentioning companies by name, we don't want FireNet getting sued if you libel anyone.
-
Fair comment. I was just responding because the delightful Carol used the name of one of our major clients, knowing that we are their consultants.
-
Sorry Chris.
Delightful is only marginally less annoying than being patted on the head...but then one must not disagree with Colin.
Perhaps you could explain the government's thinking behind the suggested inclusion of the following text in the revisions to ADB
Appendix G:
The following information should be provided...to assist the owner/occupier, etc to meet their statutory duties under the RRO.
Simple buildings
...an as built plan...showing;
escape routes, compartmentation, fire doors, detectors, etc, etc.
Why is the Building division saying this if the intention of the fire Division was to deny the right to require plans. So the cost is already there in this cases.
And yes, I know that it only applies to new build and material alterations but the principle is established.
-
Carol: "..an enlightened FRS." I am very curious now - especially more so when you say that you normally visit places "bordering on S10" - wow! Where on earth could that be?
But perhaps this is becoming all too academic.
Anyway, seems there may be at least a couple of potential 'expert witnesses' here willing to aid someone at the wrong end of one of your 'enforcement notices' regarding the provision of plans.
-
Interesting debate:
I think that we agree that drawings are not in themselves a requirement.
The arguments for them are:
They can help the occupier manage their premises;
Consultants can use them to assess the risk from fire;
The fire service can use them to assist fire fighting.
The main argument against them is their initial cost.
If drawings are produced then they may save money in the long run by saving time. Drawings do not have to be made by architects or consultants.
If drawings are not used to record some of the fire safety measures then they can be described in writing.
In the end it depends on the premises.
-
Marginally less annoying? I am obviously making progress then. There may soon be room for me in the modern FRS at this rate. Anyhow, you have answered your own question. Only for new build. Jolly good idea. New build has all sorts of things that are not necessary in existing unless (oops this may get me into trouble) you are one of those who go around demanding intumescent strips here there and everywhere, or as I came across last week, demanding emergency escape light fittings in hotel en suite bathrooms.
-
not a bad idea is that.If the fitting was maintained it could double up as a shaving light.
-
But would need to be IP rated.
-
Sorry to repeat the point but this debate really depends on what definition of significant findings you are using. I agree with Carol, how can you adequately show the preventitive & protective measures effectively in a complex building without a plan. If you can very well. Fire Certs didn't make plans a statutory requirement but most certs used a plan as it was the easiest option.
I know some of you believe significant findings are defects only. Once again I refer you to the ACOP for MHSW Regs. Mr Todd believes the ACOP will soon not be relevant, once again he is wrong.
The MHSW Regs will still be there and the employer will be told what significant findings are by the ACOP. The responsible person will also have to carry out a FRA to comply with RRO, and some proposed guidance gives a very different definition of significant findings. i.e. defects.
-
My Brigade have already shifted from inspections to 'audits' under WFPL in anticipation of RRO.
We no longer carry out a 'full survey', but we do walk all escape routes and other areas deemed to be 'risk critical'.
The FSO has to make his mind up on his feet in these areas.
I think the comfort blanket of a plan has led to some fire authorities using low grade inspecting officers to 'box tick' on fire safety inspections in order to meet output targets, instead of sending appropriately skilled professional officers who can interact properly with employers.
We look more deeeply at policies and procedures, testing, and training.
We no longer detail on a plan the 17 fire doors wedged open for the 10th year running.
If one door is wedged they have a problem, we identify it, and ask them to deal with it, and follow up.
I think this is the way to go, and will probably work well with companies who manage their precautions professionally.
For the others, at long last we are following the HSE enforcement module, and are serving enforcement notices if required.
And we don't have to amend those pesky plans all the time...my tip ex shares have dropped alarmingly!
-
well go to statinery box
-
But would need to be IP rated.
and you could have a little man shaving instead of running legend.
edit-spelling
-
The fire bits will be removed from the management Regs Phillip, so they will relate only to what they were intended for, namely health and safety, so taking away all your confusion.
-
no confussion on my part Mr Todd but do you really think it will not be confussing for an employer to have one definition of significant findings(ACOP) and a responsible person to have another( Proposed RRO guidance)???
-
No I dont think so at all. There will be a minor decoupling of health and safety and fire safety.
-
Luckily Colin not all agree with you. I have been told by people even more important than you Mr Todd, that they agree the guidance is defective and said it would be amended before publication to align definition of significant findings(Sfs) with ACOP. I will, however, believe that when I see it in print.
Now if that happens and SFs include a record of the preventitive and protective measures, the only effective way of recording these in all but very simple buidings, is by use of a plan.
If significant findings are defined as proposed RRO guidance and CFOA appear to suggest as defects only I agree, no plan would be required. A responsible person may even be able to say I have carried out my risk assessment and there are no significant findings....i.e there are no defects.
CFOAs guidance says that the responsible person should record the SFs and the action taken to deal with them!
-
I still do not see PhilB how you can insist upon a plan. Plans are for the convenience of inspectors - which is not something covered for in legislation. Having seriously looked at providing plans in my FRAs I can tell you it is not at all easy - and certainly expensive!
-
Luckily Phillip, not all agree with you, including Mr Gough, who is more important than you and actually practices not preaches (assuming anyone still goes to Moreton to be preached to).
-
I'll never get invited there again now Colin!
-
You are missing nothing, Ian, and if you were you would be lonely, particularly as you are very bright and forward thinking.
-
Not insist Ian, I just ask how can you effectively record the SFs without a plan.(I know that may be expensive sorry!!!!! and it was never supposed to be easy...although many incompetent assessors think it is and are making a lot of money....hope they have good insurance policies!!!!!).
I repeat it depends on which definition of SFs you chose to accept. A plan is not for the convenience of inspectors!!!!....its a means whereby the responsible person can show due dilligence.
If you can do so without a plan you're home and dry. However I have seen a lot of assessments carried out by so called competent persons and consultants that are a long way from suitable & sufficient.
I look forward to the decisions that can ultimately only be made by a court of law.
Colin I do not preach at anyone, and I can and do practice; and I would dispute the importance of Mr Gough; and as usual you miss the point! Still no doubt you will reply to this so that you may have the last word.
And Mr Todd I can assure you that some very bright and forward thinking people attend and work at Moreton. Unfortunately for you thay do not all agree with your views.
Perhaps you and Mr Gough should read the ACOP, just in case they make those amendments!!!
-
PhilB: your third paragraph - first sentence - says it all. That'll do for me. I'll now duck out of this and let you two carry on!
-
This is the kind of pointless argument that I'm on about. Just concentrate on managing the risk effectively. Unless your plans and fire rpoof they are no use to anybody.
-
Brian
I'm sorry you find the arguement pointless. We are about to see the greatest change in fire safety legislation & it's enforcement since the 70s. Fundamental to that is surely fire risk assessment...and....to assist compliance & enforcement, everyone must agree on what is required to be recorded.
I have never said plans should be a statutory requirement....but how can you effectively record the SFs without one? Mr Todd advocates a glorified checklist....in my humble opinion that is not suitable & sufficient. I think Mr Goughs last post suggested he was happy for the Courts to decide...so am I.
But 'pointless arguement' I think not!
-
You have missed Wee B's point. Try to listen Phillip. I know you never listen to me as a point of principle, but even so try listening to wee b. His point is that no one has ever been saved from a fire by a drawing. Even those lovely fire cert drawings that the poor I/Os drew, which were not to save life but make life simple for later inspecting officers.
-
PS Mr Gough is quite important. He gave us case law on the meaning of the FP Act, plus a shed load of entertainment in the process. Also, he is a rather likeable chap.
-
I do not miss Brians point Collin. I know plans do not save lives but this debate is about effective enforcement that will hopefully maintain standards and save lives. Therefore both enforcers and responsible persons need clear guidance on what should be recorded following a risk assessment. The proposed RRO guidance conflicts with ACOP Collin.
I believe plans are the easiest way Collin, in complex buidings, to record the preventitive & protective measures. As I have said previously Collin, if you can do that without a plan ok.
Collin, I'm sure Ian is a likeable chap and his contribution to this debate has been worthwile, unlike yours Collin as your main aim appears to be throwing insults at a certain training establishment.
Incidently Collin, isn't it anoying when someone constantly refers to you by name but uses too many L's in it???
-
Coomon guys, keep it pollite now.
What I am saying is that I think Inspecting Officers should focus their attentions on what they see when they visit a building.
If their are problems with the building as he finds it then he can ask to see improvements. The responsible person may well produce his FRA and use it to argue that nothing needs doing. This is the time when boring and pedantic arguments about what constitutes an adequate FRA should arise.
If the building looks OK and the responsible person is on the case then leave them alone and move on to the next building. (Leave them a leaflet about FRAs)
By following this approach more buildings will get seen and the world becomes a safer place. Alternatively you can spend all your resources arguing about the paperwork on an otherwise perfectly acceptable building.
-
I agree totally Brian. The risk assessment is the responsible persons tool for complying with the regulations. Enforcing authorities should only need to refer to it if they find a problem.
But surely the guidance for enforcers and responsible persons should be consistent. It worries me that different individuals have different opinions of what constitutes a suitable and sufficient assessment. There will be times when that arguement crops up.
I would have hoped that any guidance issued for RRO would allign with guidance for risk assessment issued by HSE but proposed guidance does not. Hopefully it will be amended.
-
If it changes, it may well be to align HSE with ODPM!.
HSE are concerned that the CDM regs and other stuff they have done in the last couple of years has created a lot of paperwork with very little improvement in safety.
-
Well Brian if definition of significant findings changes to that in draft guidance i.e. deficiencies only it will be a sorry day.
Mr Responsible person can say I have carried out my assessment and there are no significant findings.
I believe a record of the preventitive & protective measures is a SF as are management procedures for implementing and maintaining those measures.
Might involve a lot of paperwork I know..but necessary I believe.
-
Herein lies the Problem.
You ask a group of well educated experts for some assistance, a serious query, and very quickly you find your question ignored and a personal bickering session between uninterested parties commences.
Thanks.
I have another query, an important one, one which is related to Fire Safety, the response to which will assist in developing the route which a number of people take when considering the safety of many people, including members of the public and quite possibly disabled persons in escape situations...........................
-
lets hear it then bill
-
Bill
I apologise if you feel your enquiry was ignored, I don't think it was....it developed into a useful and important discussion.