Fire Safety Manuals

[DRV]

Firstly, be gentle with me as this is my first venture into posting onto the Forum !

May I ask how both Enforcing Officers and Consultants are viewing the requirement to achieve compliance with Article 11 Fire Safety Arrangements of the RR(FS)O.

Clearly the article states the 3 criteria for formal documentation. The Enforcement Management Model exemplars, as used by subscribed Enforcing Authorities, suggest that the production of a Fire Safety Manual may be a way of demonstrating such recording methodology. Approved Document B Appendix G now includes the requirement to produce and provide fire safety information to the responsible person on completion of a project, highlighting, that reference to BS 5588 Pt 12 Managing Fire Safety may be a useful start point for production of a Fire Safety Manual for complex buildings. Again further mention of Fire Safety Manuals is included within the 'guides'.

When would you expect to see a Fire Safety Manual in place ? Are Fire Safety Manuals readily available ? Are Fire Safety Manuals needed or are there other ways of providing suitable and sufficient information ?

I note PhilB on previous threads has stressed the necessity to record fire safety arrangements as well as the Risk Assessment process. The inclusion of Article 11 within the Order was surely to redress the removal of the Fire Certificate and as such is it not a means of ensuring a legal framework is provided  ?

I would be most interested in the views of the Forum membership.

[PhilB]

The answer I'm afraid DRV is not black or white, there are as you point out many ways of recording the management systems. The important thing, in my opinion is not how it is recorded but that the necessary info is recorded.

HSG65 gives good guidance.......as to when would you expect to see one in place??....when the premises are first being used.

Don't worry though, from my experience not many people out there know much about this. Ask to see a companys health and safety policy and very often they can produce it and show you their statement of intent displayed on the wall. Ask to see their fire safety policy and they usually stare blankly back at you.

The fire safety in the building cannot and will not function adequately without an effective policy.

The level of detail should of course be proportionate to the risk, Mrs Prendergasts corner shop policy will be slighty less detailed than Brititish Nuclear Fuels....but  all the constituent parts should be there i.e statement of intent, organisation and arrangements in place.

I see no reason why the general health & safety arrangements cannot be combined with the fire safety arrangements, but would expect competent persons to be appointed as part of those arrangements.

[jokar]

I concur with PhilB.  There are not many Fire safety Policy documents out there but that is what Article 11 requires the RP to do.  The only place that you can record information on training records or other records is in 11 and the following of HSG 65 will be the correct way of doing this.

[Davo]

Jokar
On another recent post we talk of the Management Regs definition of suitable and sufficient. Now we talk about HSG65. Are we saying H & S is still connected to Fire Safety?
After all, fire was removed from the Management Regs, was it not?

[PhilB]

How can fire safety & general health & safety not be related. Yes fire was removed from the managemnt regs when the order came into force to remove a legislative overlap.

Have you read the latest guidance note No.1 Davo?......


"Enforcing authorities should note that the requirement for suitability and sufficiency is one and the same requirement as that in health and safety law. Detailed advice has been produced by the Health and Safety Commission as part of the Approved Code of Practice and Guidance to accompany the Management of Health and Safety at Work Regulations 1999 (ISBN 0-7176-2488-9). That guidance is equally applicable to the suitability and suffi ciency of risk assessments under the Order."

[kurnal]

I wonder if the following newly published document may help?- PAS 911:2007- Fire strategies - guidance and framework for their formulation.

I havn't bought it yet- would be interested in the views of anyone who has.

[CivvyFSO]

The fire safety in the building cannot and will not function adequately without an effective policy.

Indeed.

Since the introduction of the 5 weeks notice for inspection this has become even more important in my eyes. If someone knows they are getting an inspection then they are going to make a special effort on that day (Usually anyway...) to ensure that all exits are open, ffe is in test etc. So from that point I want to know how they can prove to me that fire safety is an ongoing issue and done for the benefit of relevant persons, and not just something done purely to keep me happy on my visit. In some respects I want to have some faith in what they will be doing in a years time, not just taking a snapshot of what the building is like now.

[CivvyFSO]

I wonder if the following newly published document may help?- PAS 911:2007- Fire strategies - guidance and framework for their formulation.

I havn't bought it yet- would be interested in the views of anyone who has.

I think it is more aimed at the strategy at the design stage.

[jokar]

Davo, the RR(FS)O is a piece of H&S legislation wrapped up as a fire document.  It is purely reactive as are the other H&S document and uses H&S terminology.  As with other documents it is a "MUST" absolute duty in H&S terms for the RP to do a number of things to make their premises safe from fire and the effects of fire to protect the relevant persons.  The enforcers, all 5 of them, enforce by using the EMM and for FRS they use other documents or put into place an inspection programme, IRMP Guidance Note 4 and the National Framework Document are examples of this.  This is the proactive bit for enforcers to use but not enshrined in the legislation.

[Davo]

Jokar
Most of H & S legislation has sfarp or just practicable, RRFSO as you rightly say are all MUSTs.
I had to point this out to my (H & S) boss when he wanted to integrate my Fire Policy into our H & S Policy.
We now have a two page policy guidance??? telling each rank what they are responsible for and an eight page document giving more detail as to the actual Order
Have you also seen the guidance given to HSE staff on what to do if they spot fire deficiencies? It clearly limits HSE actions because, quite rightly in my opinion, fire is a whole new ball game. Thats why I listen and learn on here!

[kurnal]

I think it is more aimed at the strategy at the design stage.

Yes- I was wondering if it may support the new Building Regulation 16B?

[PhilB]

Jokar
Most of H & S legislation has sfarp or just practicable, RRFSO as you rightly say are all MUSTs.

The Fire Safety Order is not all musts, it is very very similar to MHSW Regs. Yes the responsible MUST carry out a fire risk assessment and must take general fire precautions.....but...........he only needs to take them so far as is reasonably practicable for employees and reasonably in the circumstances of the case for everyone else.

So whilst there is an absolute duty.......that duty is qualified....and common sense should prevail.

[DRV]

Don't worry though, from my experience not many people out there know much about this. Ask to see a companys health and safety policy and very often they can produce it and show you their statement of intent displayed on the wall. Ask to see their fire safety policy and they usually stare blankly back at you.

Thanks guys thus far.

That's exactly my concern though PhilB, there understandably appears to be a lack of knowledege of what is required from all parties involved, fire consultants, enforcing officers, responsible persons etc. [This is a new concept and one that was previously achieved by the fire authority through production of the fire certificate]. Have people missed this entirely, or am I trying to make a mountain out of a mole hill.

Lets take a multi occupied building of 'so' many floors, landlord controlled and fire engineered solutions [I'm generalising] to achieve the fire safety strategy. What would you expect to see as a model of recorded fire safety arrangements. I personally would like to see a formalised strategic framework document capturing all the necessary information requirements for fire safety, inclusive of the policy statement [signed]. Within this document sitting the Risk Assessment, Emergency Plans and dare I say it, but wholeheartedly believing so, fire safety plans. That for me is what Article 11 is aiming to achieve, again though proportionate to premises.

Are any consultants out there producing these manuals, there appears not to be much available via the web ?? I have seen a couple in varying forms and depth of detail, one of which though was particularly good.

[PhilB]

I totally agree with your last post DRV. it is apparent that many consultants and FRS inspectors are clearly not competent in this area and do not understand what must be in place and recorded i) to comply with the Order and ii) more importantly in my opinion, to ensure that the premises are safe.

Particulary in multi occupied buildings with complex systems in place.

This is due in my opinion to a lack of training by FRS and the fact that so many so called consultants are popping up all over the place charging ridiculous sums for producing documents that neither addrees all the issues or record all the necessary info.

It is a vicious circle because the incompetent auditor will not recognise the incompetent assessor, and it appears that not many of us care about that.

....................and the poor old responsible person has a suite of guidance documents produced by CLG that contain many errors and pictures of cows in bedrooms.