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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Tom Sutton on February 24, 2006, 07:41:46 PM
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I believe we should have a national standard on how a fire risk assessment should be recorded consequently I contacted ODPM and this was the response.(I was asking for another guide)
Eleven 'guides' will be sufficient; All the 'guides' will have templates to assist you in recording your fire risk assessments; they will be uniform right across the guides to prevent any confusion. The new fire legislation will become law and non compliance will incur penalties or imprisonment.
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Does this really mean that, at last, we will have official government guidance on the format and content of a fire risk assessment?
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Whats wrong with using PAS79?
If you want a standard format to record, here it is, and I imagine in a court of law it would stand up pretty well.
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PAS79 has been discussed to some length on a previous topic but if the ODPM recommends that it should be the standard so be it. What I would like to see a recommended national standard so we are all sing from the same hymn sheet.
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If PAS79 was the national standard would this not be the same as people having to use Pilkinton K Glass to achieve the required U Values in domestic premises
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If PAS79 was the national standard would this not be the same as people having to use Pilkinton K Glass to achieve the required U Values in domestic premises
Your post confuses me. What do you mean?
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Chris, if they make PAS79 'The' national standard it was not the government who wrote the standard, therefore the company selling the standard (BSI) would have sole wrights to the only approved standard in the country which has to be purchased for £100.
Like making Edwards butchers at the end of my street the only approved sausage sellers :)
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Sorry folks but I cant believe this thread.
At long last we have moved away from a prescriptive approach to Fire Safety- and now having taken this step forwards some of you want to step back to a prescriptive standard for risk assessment?
The Management Regulations and soon the Fire Safety Order set out the definitions for a suitable and sufficient risk assessment.
Can't we leave it at that?
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Sorry folks but I cant believe this thread.
At long last we have moved away from a prescriptive approach to Fire Safety- and now having taken this step forwards some of you want to step back to a prescriptive standard for risk assessment?
The Management Regulations and soon the Fire Safety Order set out the definitions for a suitable and sufficient risk assessment.
Can't we leave it at that?
That would be nice!
But I would personally like to see something on the grounds of what should be included in a suitable and sufficient fra to stop any confusion / arguments (similar to what was shown in the fra course notes provided recently by Mr Todd)
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Like making Edwards butchers at the end of my street the only approved sausage sellers :)
If Edwards were internationally renowned for writing specifications regarding sausage manufacture, if they did not make sausages, if they had a royal charter for this purpose, if they have a published fair trading policy, a compliance committee and manager, if they undertook wide public consultation involving industry experts, if they were independently accredited, if they had laboratories, over 2000 employees, over 100 years experience, if the whole reason for their existence was to improve the quality of life of the public, if they did this and no one else did, then I would begin to consider your argument that the BSi is comparable to a butchers shop.
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Sorry folks but I cant believe this thread.
At long last we have moved away from a prescriptive approach to Fire Safety- and now having taken this step forwards some of you want to step back to a prescriptive standard for risk assessment?
It is not a prescriptive approach to Fire Safety it is trying to achieve national recommendations how to record the results if a fire risk assessment.
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I don’t think you understood my post Chris; the EU set this legislation not Bsi, therefore it should be the governments job to provide an approved specification. If PAS79 were used, this would give BSI a monopoly as being the only approved fra template.
Also, as they are not a profit making organisation, ploughing that much revenue generated back in to the company would be difficult.
Also, Edwards / bsi don’t just specify, they sell sausages / standards
p.s. I think the bsi do a great job (read their work every day :))
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I don’t think you understood my post Chris; the EU set this legislation not Bsi, therefore it should be the governments job to provide an approved specification. If PAS79 were used, this would give BSI a monopoly as being the only approved fra template.
Also, as they are not a profit making organisation, ploughing that much revenue generated back in to the company would be difficult.
Also, Edwards / bsi don’t just specify, they sell sausages / standards
p.s. I think the bsi do a great job (read their work every day :))
Your comparison us unfair. BSi do not sell fire alarm systems, fire safety risk assessing, concrete or any other item that they write specifications for. But you are right, I do not understand your post.
The HSE produce the only approved guidance on Health and Safety Matters
The Environment Agency advise us on flood prevention
The NICEIC approve electrical contractors
Only CORGI approved gas technicians can work on gas systems
Only UKAS approve third party inspection programs
Are all these organisations nasty monopolies? I don't think so, they are just the UK's experts in that type of thing.
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Some 'official' guidance on the format and content of FRAs would be useful along the lines of HSE guidance in the realms of health and safety at work - which, whilst not being prescriptive, does prove useful in letting you know what is expected by the enforcing authority.
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not even worth answering that 1
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Ken- to quote your post
"which, whilst not being prescriptive, does prove useful in letting you know what is expected by the enforcing authority".
There were as many different interpretations of the the old prescriptive guides as there were Fire Brigades, let alone formats for fire certificates, exemption certificates??? etc. Why should this be any different?
The new order and the old management regs are perfectly clear on what constitutes a suitable and sufficient risk assessment. The guidance makes the process crystal clear. As long as the assessment meets the criteria and the significant findings are expressed what difference does the format make? And what is wrong with letting the court decide?
Theres no prescribed format for a manual handling, coshh, working at heights, workplace, display screen regs etc etc risk assessment, the guidance sets out the matters to be considered and leaves the choice how it will be recorded to the assessor. Why should fire be any different?
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BSI produce some excellent documents for guidance; that, I believe, most readers of this forum will agree. I personally think their decision to climb into bed wth a well known fire consulltant was misguided, but that of course is my opinion only.
Prescriptive fire safety is a thing of the past as are prescriptive ways of achieving the goals. PAS79 may be adequate if used by competent assessors, there are however many other frameworks, templates, etc that are much better.
Unfortunately, the two most important terms with regards risk assessment are not defined in the RRFSO. i.e. suitable & sufficient & significant findings. PAS79 does not clarify the issues and Mr Todd has made it clear on previous posts that he interprets those terms differently to many others. It is apparent that some contibuters to this post are aware that ACOP to MHSWR provides excellent definitions that are soon to be watered down in the new guidance!
When RRFSO comes into force the poor old man on the street will have to comply with the new Order and the HASAW Act, both require significant findings to be recorded but that term is soon to be confused by the new guidance documents.
National guidance to assist consistency of enforcement would be helpfull but PAS79 is not the answer.
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not even worth answering that 1
That's your choice, but I think when you compared the BSi to a butchers shop, it would be myself that would have had a stronger case to suggest that a comment was not worth answering.
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Am I being a bit dense here but isn't risk assessment about the outcomes - not the method by which they were arrived at. If an enforcing authority uses PAS79 to provide a benchmark to validate a submission, it does not matter a jot what method the assessor used as long as the outcomes are similar and all the bases are covered. Remember ERICPD and persons at particular risk and you've jusy about got it covered
By the same token, any fire risk assessment should be completed or audited by a competent person. There is no fool proof method yet devised. If there were there would be alot of consultants unable to pay for their daughter's school fees wouldn't there.
From my experience most risk assessments are either "Suitable and Sufficient" or bl**dy rubbish with very few in any type of grey area. Those that are bad are usually due to the competence of the assessor rather than the method used
Therefore gents no matter which side of the statutory fence you sit, let your outcomes do your talking. At the end of the day the enforcing authority is only empowered to see the significant findings anyway.
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Reg, how do you define significant findings? some will have you believe they are defects only.
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PhilB
Is that a leading question?!?!?
IMHO a significant finding includes anything that affects the suitability and sufficiency of a risk assessment, both deficiencies and positives. For an auditor to fully appreciate the risk assessment, the building and the way they work together they must be able to have a holistic view of them.
As with any audit process there must be a standard by which the risk assessment can be judged, be it a RRFSO guide ADB, 5588 or any other guide appropriate for the use. That in itself can be a significant finding. Any deviations form the "norm" for that particular use should be recorded particularly if a positive feature is being used as a compensating feature for a deficiency. It is as important to get a handle on the thought processes as the risk assessment itself. The only time that there may be a problem is where there is a clear deviation from the norm where either it has not been recorded or a rational for it not being an issue is given.
In my experience this usually occures with the simplistic tick box questionaire that purports to be a risk assessment being completed by, in good faith, an non practitioner of the dark arts. Simplistic questions as "does the premises have a fire alarm yes or no are a nonsense without an understanding of what level of detection should be there.
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Why not stick with the guidance given in ACOP to MHSWR i.e The significant findings should include:
i)a record of the preventitive and protective measures in place to control the risks
ii)what further action, if any, needs to be taken to reduce risk sufficiently
iii)proof that a suitable and sufficient assessment has been made.
In many cases, employers will also need to record sufficient detail of the assessment itself, so they can demonstrate (i.e. to an inspector) that they have carried out a suitable and sufficient assessment.
Also many people think that only significant finding need to be recorded, that is not the case. Under existing and proposed fire safety law there is also a requirement to record measures taken for the effective planning, organsiation, control, monitoring and review of the preventitive & protective measures.
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It's something like the ACoP and Guidance to the MHSW Regs plus an enforcement authority- backed example RA format that I am still hoping for.
In the H&S world, when companies offer their expensive RA computer based programs with complicated mathematical calculations you can refer to the HSE's '5 Steps to RA' format and assess risks as high, medium or low - thereby removing the shroud of mystery and magic and producing readily understood documentation. If management are going to act upon and maintain control measures, they need to understand what they are, how they operate and what they are there for.
In my book, defects should be remedied (with temporary risk controls until done) and it's essentially the remaining inherent risks of operating the undertaking that need to be adequately recorded and controlled.
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Phil
Were we not saying the same thing different ways?
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Nearly Reg. I agree totally that tick box RA's are useless as they do not show due process, i.e conclusions with reasoning. What concerns me regarding the new guides is the array of wierd definitions for significant findings.
It would have been nice to have 'suitable & sufficient' & 'significant findings' defined in the new Order but they're not and this I think will lead to confusion.
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I have been using the principle of PAS 79 now for some months. The original document is too restrictive however with some tweaking i am certain that it can work.
My main criticism is that it has been ok if the number of points identified is limited. Anything else then completing it becomes a headache.
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I think that these definitions will become tested and refined over time as we become more familiar with and use the guides. Lets face it most of us have not seen anything but drafts although we are reassured that the final version should not be toooooo different!!!!!!
As for causing headaches - is that not the reason why fire risk assessments should be completed by competent professional people? If it were easy, anyone could do it.
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But Reg
The ODPM appear to be taking the line that anybody can do it and that there will be no additional burden on industry as a result of the RRO.
At least that seems the hard sell approach given on the seminar circuit and the senior officers and ABE people sitting on the panel and who know better dont appear to want to rock the PR boat.
Well that was the impression I got.
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And of course we believe everything that the government says don't we?
Sorry - was the impression you got: was that anyone could do it or no-one wants to rock the boat?
RRFSO
Safety assistance
18.—(1) The responsible person must appoint one or more competent persons to assist him in undertaking the preventive and protective measures.
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As for causing headaches - is that not the reason why fire risk assessments should be completed by competent professional people? If it were easy, anyone could do it.
I aree with you Reg but all the guidance that I have read follows Kurnal's understanding. "The ODPM appear to be taking the line that anybody can do it and that there will be no additional burden on industry as a result of the RRO."
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Absolutely TW, I fully agree with Kurnal's summation. And JP and team know exactly what goes on out in the real world, and they have never been mistaken, and the RRFSO will be enacted on the 1st of April 2006. oh no they were mistaken about that weren't they. Oh and they listen and take on the views of professionals in the field.
As for no additional burden - there should be no additional burden as a result of the RRFSO as the business community should have been doing FRA since 1999, 1997, 1974???????????
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The Government approach when the MHSW Regs were being introduced (1992) and required risk assessment and a competent person was much the same - but there was some guidance from the HSE. The result might be summarised as a mixture of some good RAs, some poor, some over-complicated, many late, many non-existent and a lot of unread paperwork in files.
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You are right Ken but I thought there may be a difference this time.
My memory of the history of the management regs, and especially the low key launch of the fire precautions workplace regs in 97 and then again in 99 was that the government was being directed by europe to do something and did so fairly reluctantly, feeling that what we had was ok and not really wanting to change things. The HSE (HSC) as an independent body were able to apply a much more positive direction though. and apply a broad base of leadership through all HSC members- government reps, CBI, Unions etc .
This time the change is mainly directed from within, though there is some rationalisation to aid compliance with the EU directive. So I thought the Govt might drive things forward with a little more impetus. But it appears this is not to be the case and as the enforcement will be by the fire authorities, puppets of the ODPM, there will be no independent champion to influence and improve standards.
So I think the RRO will be another damp squib and whilst we anoraks may argue long and hard about risk assessment formats, the meaning of significant hazards, suitable and sufficient etc we may as well save our breath because the launch and enforcement is going to be very low key.
I predict that without robust enforcement of the new order ( and I see few signs of this anywhere) current standards will decline for 5 years until insurance companies and civil claims take effect.
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Kurnal
Whilst I totally agree with majority your post, one point I must take issue with is "fire authorities, puppets of the ODPM" I hardly think so. Constrained, restricted, agravated, frustrated etc etc maybe - but puppet no.
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Reg
I speak in terms of a collective leadership, certainly not referring to any individual or tier of management within any authority. I am only too familiar with the constraints, aggravations and frustrations felt by many. But I suggest that on past record the collective leadership of the fire authorities will either collude with the softly softly approach or choose to remain silent rather than voice its opposition to its paymaster.
And that is how I read the message coming from the current round of RRO seminars.
From speaking to colleagues I do not appear to be alone in forming this view.
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I have certainly got the impression from ODPM that they expect FRSs to do plenty of 'informing and educating' and use enforcement as a last resort.
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From a personal point of view I would advocate "inform and educate, audit and enforce when necessary, prosecute as a last resort. Is that out of step with other authorities?
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From a personal point of view I would advocate "inform and educate, audit and enforce when necessary, prosecute as a last resort. Is that out of step with other authorities?
No Reg, but I presume that is what some people mean by 'softly, softly'
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Big A
I have nothing but support for fire authorities in taking the "inform and educate, audit and enforce when necessary, prosecute as a last resort" line in enforcement- that is how it should be and is entirely in accordance with the enforcement concordat and enforcement management model.
The softly softly approach I am objecting to is over the launch of the new order. In my opinion the launch of the new order should be high profile because statistics show that about 60% of employers have still not implemented the 97 Regs - after 9 years.
So unless they give the launch a bit of a push this time then in another 9 years around 40% of existing employers and 60% of other responsible persons will still not have implemented it, and probably around 300 persons will have died in fires as a result ( figures all by projection of current statistics) .
The launch is an opportunity to make an impact on commercial fire safety. The change is happening- why not make the most of the opportunity to educate and improve standards. TV, newspaper, targeted advertising, all would help.
The current round of seminars appear to take a very softly softly approach, attract the converted and then give the impression that the whole risk assessment process is so simple you could give the office junior the guidance document and they would have no problems with it.
In summary its so simple that its taken the great, the good and the ODPM around 3 years to produce the guidance and its still not even ready in draft.
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I attended a seminar given by the BRE at the Firex south exhibition. It was said there that from June there shall be TV, Radio and newspaper advertisements and articles to highlight awareness to the FSO. Also, there shall be a letter going to every business informing them of there obligations under the new FSO. This sounds to me like a positive step. Lets see if it happens!
Ashley Wood
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Perhaps the ODPM have been visiting this forum?
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The publicity proposals proffered by the BRE at Firex were similar to those at the CFOA training in manchester so we can only hope that it is true.
Talking of Firex: did anyone else find the idea of the St Johns Ambulance giving a presentation on the Fire Safety Order a bit surreal?!?!?!?!
Sorry must go and finish my powerpoint on emergency fitting of a pulmonary chest drain.....................
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lol reg
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Kurnal,
It's one of the ironies of the RRO that it's been made using the provisions of an Act specifically designed to speed up the process.
:) =)