FireNet Community
FIRE SAFETY => Fire Risk Assessments => Topic started by: kurnal on December 21, 2016, 09:48:33 PM
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It appears to me that our industry is moving away from fire risk assessment and moving towards a fire safety audit approach in which the premises are measured against various guidance, including sector specific FSO guidance, ADB (even for existing buildings) BS9999 /BS9991 . Where a fire risk assessor finds a variation from the guidance then recommendations are made to bring the premises to current standards rather than assessing the risk. To me this is an audit rather than an assessment.
Am I right?
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I think you are probably are right.
From a personal point of view it was easier to be more pragmatic when I was an IO. I spent 12 months giving Primary Authority advice to companies who were frustrated by code hugging risk assessors who just gave a list of things that were wrong without considering who was at risk. The reasons for this? - scared of litigation.
I vowed that I wouldn't turn into one of these, however it would be easier sometimes.
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I think you are probably are right.
From a personal point of view it was easier to be more pragmatic when I was an IO. I spent 12 months giving Primary Authority advice to companies who were frustrated by code hugging risk assessors who just gave a list of things that were wrong without considering who was at risk. The reasons for this? - scared of litigation.
I vowed that I wouldn't turn into one of these, however it would be easier sometimes.
That is exactly my past. Gamekeeper turned poacher some might say!
I also enjoy the non prescriptive approach that allows a bespoke RA to look at the actual risks presented. I too vowed to keep my flexible approach when I changed hats, but when so many IOs are applying guidance as if it is legislation, in order to keep customers happy and safe from IOs, you have to follow suit
I am now back on paye. My employers trust my judgement and allow me - expect me- to come up with the best solution not the by the book solution
So if audits mean blindly applying standards, you can keep them. I will continue to apply common sense & proportionality that the FSO and other legislation allows for
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You make a very good point kurnal, one that I have been high lighting with Assessors, and clients for years. Proper FS audits are considerably more costly than risk assessments, they take much longer to complete and contain much more detail. They may also focus on a particular aspect of the FS arrangements as opposed to a holistic assessment of the risk. So, while I agree that applying codes isn?t risk assessment, I wouldn?t say that it constitutes an audit either, but it is inappropriate, and Inexperienced, poorly trained Assessors and IOs are equally at fault here.
Frankly, I get concerned when people start finger pointing. In my experience, most people in the profession try to do a good job, but the available academic training to both the public and private sectors is, in the majority of cases mediocre at best, and the practical supervised on the job training and experience that is critical, and which used to be part and parcel of F&RS and Company training schemes has, like most apprenticeships and training schemes, been discontinued or reduced to the point where it is of little or no value. We can?t keep bemoaning standards of competency if there are no suitable training schemes. And sadly, there are unlikely to be any suitable training schemes while the Government keep insisting that no special skills are required to carry out a Fire Fisk Assessment and commercial businesses like the FPA keep selling four and five day courses that supposedly qualify attendees to carry out fire risk assessments.
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Believe you're right K. We are finding that statutory bodies in NI take on fire safety responsibilities, create their own guidance document and enforce its prescriptive measures. This is contradicting the initial consultation document on the FRA process where it specifically stated that one reason for it was to remove the prescriptiveness associated with fire safety guidance.
These statutory bodies undergo a week's FRA course and are let loose with their guidance to enforce measures which would be considered unreasonable and disproportionate by any standard.
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So how would you do a risk assessment without a code for a benchmark?
In practice, you compare the premises (and the way it is used) with a relevant code. where it doesn't meat that code you consider whether its a problem and whether a response is necessary.
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So how would you do a risk assessment without a code for a benchmark?
In practice, you compare the premises (and the way it is used) with a relevant code. where it doesn't meat that code you consider whether its a problem and whether a response is necessary.
I'm only telling you what the consultation doc said WB.
Your second point is the important bit in that the statutory bodies want their code to be applied to the letter, without giving consideration to the risk.
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Agree completely with you wee b.
Furthermore NT, not all statutory bodies want their code to be applied to the letter... same as not all risk assessors are good and not all are bad for that matter.
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WeeB summarises it perfectly and In raising this topic 11 years after the FSO came into force I was interested in what happens when premises do not meet the code - i.e. to whether the evaluation still takes place as he described.
Some former clients who are still in touch and some contributors to various topics gave me a possible misperception. That many assessors will go for a full compliance rather than carrying out the evaluation and using judgement.
There are several potential challenges as identified in responses so far.
1- Fear of personal or corporate criminal liability
2- lack of training or experience
3- fear of having to justify your solution to the TPC body and the consequences if they disagree
4- lack of any formal career pathways and qualifications
I think that in the past contributors to this forum have generally have offered more practical advice than we do now -I put this down to fear of liability but if I am wrong then apologies are due.
I reckon it's time I packed this in as I do feel out of touch with the industry after just 18 months. Age and ill health have got the better of me. If any established members are interested in taking it on please email me or pm me. Thanks everyone
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Yes, I agree with you kurnal, however I would add a fifth issue and that is the lack of responsibility on the part of the inspecting bodies. (Although I will admit responsibility is probably not the best word but I can't think of a better one at the moment.)
Much as I hate to refer to the 'good old days' the situation prior to the FSO required that not only did the enforcing authority have to identify any issues with a premises but it also had to come up with solutions to those issues. These days it would appear that the trend for enforcers is to follow the guidance as if it were law and wash their hands of the problem 'not my job, guv'. We have seen a fair number of posts where this has happened.
In a way it reminds me of a tale referring to WW2 where a person came up with a way to find every U boat in the Atlantic. When asked what it was he said ' simple take away all the water!', when asked how? the reply was 'you have all the scientists, they are cleverer than I am, I just come up with the ideas!'
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Is PAS79 and audit or an assessment? Discuss
davo
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Agree completely with you wee b.
Furthermore NT, not all statutory bodies want their code to be applied to the letter... same as not all risk assessors are good and not all are bad for that matter.
But, as you have said, some do WB.
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There seems to be little assessment of risk and proportionate premises tailored solutions from some quarters and it seems to defeat the point of risk assessment and RP's could probably save millions each year by dumping the use of third party risk assessors and rigidly applying the standards in the guides in in house FRAs as the assessors would only do the same... (Didn't they say the FSO wasn't meant to be a consultant's charter anyway?)
On the other hand you see some places departing to massive extents from the expected standards, with no real justification and yet they are seemingly compliant (or at least not worth the effort of action).
There is a middle ground though and that's what the industry should strive for - proportionate solutions that suit the particular risk that may not always be rigidly to the benchmark, but that still provide adequate life safety.
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Kurnal,
I understand how I'll-health can utterly deflate you, but can I tell you something my friend; I have been a member of this forum for a number of years now. You have no idea just how valuable your advice has been to me. I would like to sincerely thank you for it and I would hope that you will continue to provide your usual well-considered opinions to guys like myself who, unlike you, don't have the confidence honed from years at the coal face. I do hope that you are restored to the best health that is possible. Merry Christmas!
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I'll second that Lyle.
I do hope K you and your family circle have a very happy and peaceful Xmas and New Year and trust we will see you keeping the Forum members in line for many years to come.
NT
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Is PAS79 and audit or an assessment? Discuss
davo
I don't like to say this on a forum that Mr Todd subscribes to but, the author of PAS 79 introduced a "decision tree" (PAS79-2012, p.23) into nationally recognised guidance/standards, for where situations don't comply to current benchmark standards.
This concept was further reinforced in nationally recognised guidance/standards by the author of the Purpose Built Flats guide and, I expect, will be further reinforced by the author of the Specialized Housing guide.
The real question is: are risk assessors and/or Article 26 inspectors competent enough to apply this "decision tree" or are they merely competent to apply the guidance prescriptively?
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The figure mentioned simply tabulates a process that I would expect most fire risk assessors offering their services on a commercial basis to follow. You'd probably sensibly choose to adopt something along the lines shown whether you'd read PAS 79 or not. There are parts of the table that I wouldn't necessarily have put in myself, but that's just a matter or personal opinion (there's always more than one way of skinning a cat).
So... yes, if they're offering their services on a commercial basis, or are tasked as enforcing authorities under Article 26 of the FSO, I would expect them to have the capability to follow the table if they chose to use PAS 79 as the basis of their activities.
Just to be pendantic - a PAS is not a 'standard', not are they necessarily "nationally recognised". They can be considered for conversion into a standard, though, at the end of the initial review period (usually 2 years). Having said this, PAS 79 is well-used within our industry & (in my view) they ought to consider conversion in this case, as it would only help improve rigour and consistency if it achieved the enhanced status of a full British Standard.
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Fishy, Idlefire
perhaps CT could advise who and at what level the new PAS79 is aimed at?
although retired now, I found the older versions from my time where aimed at the educated person rather than professional RAs
davo
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Are fire risk assessors not educated persons? Big Al has still got his leaving certificate of education at Bathmat Lock High School for young gentlefolk dating from 1942. Has it somehow become invalid?