Probabalistic risk assessment vs. good practice

[Ken Taylor]

The pole may be quick, Wee B, but hardly as safe as possible for most prospective users!

Do you know whether the key boxes were part of the CDM design or quickly retro-fitted by the users, Con?

I've had a few concerns about the Approved Inspector route.

[AnthonyB]

Key boxes are rather archaic and their use for fire routes always brings back the Woolworths & Summerland fire reports which frowned on them as being possible contributory factors to some of the deaths & injuries.

Sadly with respect to workplaces although a lot of the guidance uses the 'without resort to a key' type phrase the actual order IIRC doesn't when describing the basic duites re exits

[John Webb]

If the HMO is new build in Aug 2006 then AD'B' 2000 edition applies. Para 6.11 under door fastenings clearly says "...these fastenings should be readily apparent and without the use of a key..." So it seems that there is a breach of Bldg Regs in this case?

[jokar]

Ahh, we are back to risk and assessment again.  There may be a feasible reason for a scenario with the use of a key, for example a care home where patients abscond for whatever reason and all staff carry the key.  I don't know about the rest of you but I lock my doors at home of a night, perhaps it is the area in which I live!

[Martin Burford]

Thanks for everyone who contributed to my observations on key boxes. Jokar if you read my narrative you would have known that it referred to HMO occupation by key workers......I don't subscribe to your example if workers carrying keys.......there are many other ways of securing doors without the use of keys.
Conqueror

[Ken Taylor]

And we have the old issue that the ADs are not the actual Building Regs - even though there is a lot of reference around to key boxes not being 'acceptable'.

[Fishy]

I had a look at the RRO itself (not the Guidance) and there it states in Emergency routea and exits 14 (2) "The following requirements must be complied with in respect of premises ............in order to safeguard the safety of relevant persons. (b) in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible;"

This looks to me as if the legislation demands that the means of escape must be available to relevant persons ie anybody legitimately in the premises. It does not define any special cases ie mobility impairment. So the risk assessment arguement cannot stand, the magic ALARP phrase does not appear.

In other threads I know there has been the arguement about Stay Put Policy and Phased Horizontal Evacuation but nowhere has the issue been raised that these policies should replace adequate means of escape. As I have read it these practices are in addition to the MoE due to the particular features of the situation.

Mike:  the bit that you missed out is important.  The full quotation is:

"The following requirements must be complied with in respect of premises where necessary (whether due to the features of the premises, the activity carried on there, any hazard present or any other relevant circumstances) in order to safeguard the safety of relevant persons".

The 'where necessary' removes the (perceived) demand to provide the list of 8 risk reduction measures that follows.  If you conclude that it isn't 'necessary' to comply with all the 'musts' and 'shall's you don't have to.  This is at the core of the issue - there's lots of specifics in the legislation, but they are all modified by the 'where necessary' obligation.  How do you work out what's 'necessary'? By means of risk assessment, consideration of good practice etc - hence my question.  If you could prove that risk was broadly acceptable, could you legally get away without catering for means of escape at all, especially if disabled people were in your premises only infrequently?

I stress again - I'm NOT supporting this view -I am just seeking discussion on its legality!