Dangerous Substances

[Nearlybaldandgrey]

Just after some opinions/views on this one .........

Article 16, (additional emergency measures in respect of dangerous substances) obviously stses that information on emergency arrangements is available etc etc ...... cut and paste straight from DSEAR!

If, when auditing the fire risk assessment of a premises which has dangerous substances, how far will the FSO go to ensure that the general fire precautions are maintained in relation to the dangerous substances?

[PhilB]

Baldyman as you know the fire safety order is only interested in dangerous substances in so far as they may have an effect on general fire precautions. Process fire precautions will remain under the control of HSE.

In my opinion the FSO will not need to be an expert on DSEAR or have a degree in chemistry. If dangerous substances are present he can check to see appropriate control measures are in place, for example is a competent person appointed to assist and is his competence sufficient considering the scariness of the dangerous substances!

For example if you're inspecting a factory and the escape route passes containers of nasty chemicals you should make enquiries to ascertain if they are likely to effect the safe evacuation in a fire. The responsible person should be able to give you the answers, if he can't I would suggest he is failing in his duty to appoint competent persons (Article 18).

Any problems identified may be matters of evident concern that should be referred to HSE.

[jokar]

I would concur with PhilB and just add that the FRA should consider the dangerous substances in the light of their affect on means of escape and the control measures in place to enure that persons are safe from them.

[Nearlybaldandgrey]

Thanks for that..... all seems clearer now!

Just to progress a bit further .......... I go to inspect a factory where, by nature of a process there are dangerous chemicals kept near machinery. If the chemicals were moved to appropriate storage, will this reduce the risk of the process AND will I need knowledge of storage requirements?

[jokar]

As PhilB stated earlier, the process is the process and subject to HSE requirements.  As regards dangerous substances, storage in the workplace is set at 50 litres in an FR /flamms bin or something similar.  If the chemicals can be considered an ignition or fuel source then the FRA should consider them and put in place the necessary control measures to protect people, the premises and firefighters if they will be exposed during firefighting.  The question really is what the RP knows and how he/she is taking action.

[kurnal]

I beg to differ. I think the reason for the emphasis on hazardous substances in the Fire Safety Order is not only because of their potential effect on means of escape - I think its all to do with the principles of prevention- reducing the risk of fire starting by eliminating, substituting, mechanical contols, safe system of work etc if hazardous substances are present in the workplace. So there is an inevitable link to process risks and a fuzzy area of overlap.
If the fire officer, who can be expected to have a certain level of competence in recognising hazardous practices, sees a problem with a process which generates a risk of fire then this is all part of step one of the fire risk assessment procedure. If the fire Officer cannot recommend a suitable control measure  that he feels he can enforce, because he feels it encroaches entirely on process fire precautions,  he recommends a review and sends a copy to the HSE. As an interim measure he may also add additional temporary precautions from lower down the principles of prevention in the areas over which he does have confidence.

Any other approach puts us back in the old days of expecting a fire to occur and  prescriptive measures.
And yes if you are in the fire safety industry I would expect you to have a working knowledge of DSEAR- how can a fire officer be competent without?

It can be really embarrassing just like in the old days when we were responsible for petroleum regs but many officers not in the Black art did not know the rules for storage and would fail to act on improper storage or inappropriate containers being filled at petrol stations. And it goes further than flammable liquids- for example all fire officers should know the basics of the firework legislation enforced by trading standards too. I could go on of course......

[PhilB]

In an ideal world Kurnal it would be nice for FSOs to be experts on DSEAR, Care Stanfdards Act, Housing Act, Licensing Act etc, etc........however many SFSOs are reducing the quantity and quality of training being delivered to a reduced number of inspecting officers.

All this at a time when the number of premises for which they are the enforcing authority is about to increase drastically.

I didn't say the FSO should have no knowledge of DSEAR; but I do believe they can perform their role to audit premises without being experts in that field.

Yes the control of dangerous substances can reduce the risk of fire as required by the Order, but I retrurn to my original point. In the type of premises where these problems are likely to occur the responsible person must appoint competent persons to assist and advise.

[wee brian]

I think as the dust settles on the many changes in fire legislation we will all start to get our heads round all this stuff.

It aint gonna hapen overnight, unless you have more than one brain and a TARDIS but we'll get there in the end.

[Nearlybaldandgrey]

True, but if these questions aren't asked, then how do we know what is expected of us?

I'd rather go out on inspections with some basic knowledge than none at all.

[wee brian]

Sure - I think you can tell if somebody has their act together or not. You may not know all the regs but you know they exist.

[Nearlybaldandgrey]

In trying to sort this out for my own information, I've obtaioned a copy of The DSEAR regs, some codes of practice to comply and some other information.


Like PhilB says, there are so many premises that are now covered and to have a knowledge of every piece of applicable legislation is an impossibility ....... but some advice and guidance is better than none I suppose!!!