RRFSO Article 15

[CJK]

Good morning, I am after some views on article 15 (RRFSO) "Procedures for serious and imminent danger and for danger areas"

My colleagues and I have been having quite a discussion on this article, some belive it refers only to dangerous substances that will put relevant persons in danger, where I belive it relates to places of normal risk that may put relevant persons in serious or imminent danger in the event of a fire.
Please can I have any views on this as there seems to be no definitive answer.

Regards
CJK

[AM]

I've taken this to mean areas where extra control measures and procedures are required in the event of a fire, for example a computer network that is protected by a flooding system that may harm occupants working in that room, or persons working in confined spaces or at height.

[kurnal]

My interpretation is similar to yours CJK. A fire will always have the potential to place people in serious and imminent danger from the direct effects of fire smoke and toxic by products of combustion. Article 15 requires the responsible person to ensure that having eliminated or reduced the risk of fire occurring, he has procedures in place to ensure that relevant persons are able to leave the area involved, by their own efforts (or with assistance provided by the responsible person) in order to avoid the danger.

But some areas offer an even greater risk from fire due to the processes or substances present there, and may present risk of explosion.  The procedures necessary to ensure the safety of relevant persons arising in these high risk  areas will need to be more effective and robust, for example to allow more rapid escape or earlier warning of danger.

Procedures will therefore be appropriate to the level of risk.
This requirement is of course an echo of the similar requirement in the management regs and the coshh regs  and has to be specifically re-iterated in the RRO as a result of article 47.

[jokar]

This Article is a straight copy of Regulation 8 of the MHSWR.  If you read the ACOP that goes with it, the information given is strictly with regard to special areas that require additional protection or planning.  However, in the recent draft of the enforcers guide, the authors seem to think that it relates to all places and that safety drills mean fire drills.  I would dispute this and always refer people to the ACOP.

[CJK]

Thanks alot for all your replies,
I have been doing a bit of digging and have found that Article 15 is as you say Kurnal a direct cut and paste from Reg 8 MH&SW Regs.
Regulation 8 has come from Reg 7 in the MH&SW Reg 1992 where it states the following:

Regulation 7 requires employers to establish emergency procedures for those eventualities (including fire) that might require complete or partial evacuation of the workplace or movement to a safer part of the workplace.

This is detailed in HSE document OC 200/18

This to my understanding covers all workplaces, not just those who have dangerous substances / processes.

CJK

[wee brian]

Thats how I read it too.