RRO - Effect on Existing Fire Safety Measures in Old Properties

[Jon Barrett]

I would appreciate anyones view on the following in understanding the impact of the RRO on existing premises that were NOT designed or protected to the level expected by todays fire safety standards.

In the past the general view has been that if you are making modifications to an existing building, say a shopping centre for example, then any alterations/refurbishment should not make conditions worse then they were originally i.e. there should be a gradual move to improve conditions but there was no obligation to bring things up to todays standards.

With the RRO the emphasis appears to have changed quite dramatically. Instead of a gradual improvement, under the general banner of 'not making things any worse', we now have an obligation to ensure that any risk is not unreasonable.

This would appear to introduce a requirement to review the whole life safety measures in terms of a comparison with what would be required today, regardless of the age of the building/installation.

Here's an example - A place of public assembly where means of escape does not satisfy current requirements - there are alternate means of escape but they are not adequately spaced apart - will it be required to provide means of escape to comply with current recommendations? Presumably the Competent person has to make a judgement call on what is considered reasonable? Which for some, because there is the responsibility that comes with this role, will be a conservative approach and others a more reasonable approach based on experience and knowledge of the likely threat.

Hasn't the grey area got even wider?

The question really is - Are existing buildings that do not currently comply expected to increase their measures to that which would be acceptable today or does the general principle of 'don't make it any worse' still apply?

Thanks.

[kurnal]

Jon
I think you have answered your own question.
Not making things any worse is not making things any better.

The only acceptable  measure now  is to make things as safe as is reasonably practicable - but only a court can decide what that is.

[wee brian]

Thats about the long and the short of it.  A deficiency in a building could be regarded as a risk. There may be a way of adressing this without changing the building.

If I have an old building with an escape route that runs through a working area. I may not be able to change the route but I can consider what can be done to reduce the fire risk in that work area.

Its all very subjective. I expect a lot of uncessary building work will get done to bring buildings up to standard. It'll cost a fair few quid but I guess its not the end of the world.

[jokar]

The two tenets of RR(FS)O are Risk Reduction and Fire Prevention.  All FRA's should be guided by these and if that justifies existing standards then fine, if it doesn't then extra work may be required.

[AnthonyB]

Many buildings are to old standards because of the certificate time warp or not being covered by legislation. So with no onus to improve gradual sensible upgrades over the last 30 years failed to occur. This makes the action plans under the RRO look artificially extreme as they've gpt to jump 30 years in one go rather than continue a gradual tweaking that should always have occured.

I'm dealing with several timewarp buidings on a voluntary basis (never previously covered by regs) & they all require a variety of key works. Fortunately as many are smallish the flexbility the RRO gives me means I can often spec simple lower cost solutions

[Ken Taylor]

The 'reasonably practicable' approach will take into account both the sheer practicality of improvement and the cost to the duty holder.  We should, of course, have also been taking this approach in terms of the general safety of workplaces irrespective of what building regs (if any) applied at the time of construction and also under the FP (Workplace) Regs.