Alteration Notice.

[martyn brandrick]

Is anyone using this part of the order/act?  Is it section 8 in new money or is it something that we are not going to use as it may have a limited use?  Do we serve it on all high risk premises so the responsible person/duty holder informs us of changes prior? Or is it to be used after the changes when we catch it through building control? Or what?
Awright PB!!

[PhilB]

Hiya Marty

It's the old section 8 of the FPA without placing that burden on all premises. In my opinion it should be used on higher risk premises that FRS need to retain control of, such as shopping malls with engineered solutions.  I have not heard of many being served as yet though....no doubt the soon to be published enforcers guide will clarify this.

[Fishy]

Every London Underground sub-surface railway station has had an Alterations Notice served upon it.

[wee brian]

Its also a way of making people produce written records when the Order wouldn't otherwise require it.

[fred]

There is an excellent article in Fire Prevention & Fire Engineers Journal supplement April 2006 written by Glyn Evans which describes the RRO Scrutiny Committee thinking behind the introduction of Alterations Notices.  It's worth a read.

If you can't get a copy I might be able to scan it and send it.

[messy]

I just do not understand the rationale for Alteration Notices.

On the one hand we are told that the FSO has delegated all responsibilities to the RP and that the UKFRS now have just an auditing and enforcing role.

Then Article 29 say that we (Fire Authorities) can ask for more if we feel fit.

We are also told that it is not an enforcement tool - which is a trick missed if you ask me as applying an Alterations notice on a RP for a defined period of time, would be similar to imposing specific monitoring a criminal by probation.

As for serving such notices on buildings with high degrees of fire engineered solutions, that is not required as the FA could just decide to audit the premise more frequently than it otherwise would.

[fred]

Messy,

Extract from Glyn Evans' paper published April 2006 that may help.

"The idea of an alteration notice first came about during the Fire Safety Orders passage through Parliament, when it was scrutinised by a Select Committee.  Concern was expressed that the Order might not be seen by the public as offering the same level of safety as the fire certification procedure under the FPA ... This concern was compounded by the fact that, under the new regime there will be no requirement for a responsible person to advise an enforcing authority of any changes they intend to make to their premises which might increase the the risk for persons working or resorting there.

It was decided that what is needed is an enforcement tool whereby an enforcing authority can ensure that a responsible person whose premisses they believe constitute an above average risk to relevant persons, or might constitute such a risk if they are changed, can be required to notify the enforcing authority of proposed changes before they occur."

Simplistically - they were worried about losing the old Section 8(2) of the FPA, so Alterations Notices were conjured up as the replacement.

[afterburner]

Got an Alterations Notice runnng on all my Establishments. The 'conditions' require us to carry out a Review of the FRA in respect of proposed changes and put the findings of that Review into effect before we alter the place. The Review and the original FRA need to be sent to the FA to demonstrate we have carried out the review before altering anything which affects fire safety. However, the FA do not approve or disapprove of the proposal. They expect a competent and valid risk assessment to reduce the risk in light of alterations.
We got the Alterations Notice for continually making alterations without even a glance at the concept of fire risk assessments. The Notice is a very effective tool in getting our very large organisation to do what we should have been doing.

[BB]

Recently served an alterations notice on a major complex who chose to ignore our good will and advice, having total disregard to the fire engeered solutions within their own building.

Once served the fatcats from head office were soon on the phone to us asking how they could co-operate and work together to lift the alteration notice.  

Funny that!! They did not want any bad press, bad for business.

[wee brian]

Nice to see the Order being enforced - well done guys.