Which FRA is valid?

[lyledunn]

My query concerns a large, rambling members club in a city centre. In all innocence the secretary, thinking it was a statutory requirement, had a new FRA carried out every year from 2010. Apart from two, they were all conducted by different organisations. I now look after compliance issues for the premises, including fire safety. I am happy to report that there were no significant differences between the assessments apart from the findings of one assessor who had been recommended by the fire alarm company. He recommended that the existing manual system was upgraded to L2 and placed a high priority on the issue. Cost was substantial at almost 10K so the club parked it. However, all other recommendations on this and subsequent assessments have been carried out. No other assessment pointed to the need to upgrade and it would appear that the existing manual system is compliant with the requirements of the current guidance for the type of premises.
I am not challenging the recommendation for the upgrade, likely it would be beneficial. However, the assessor did set out justification for his determination. All of it sound but very subjective.
Now that subsequent assessments have been conducted making no similar recommendations, where does this particular assessment rest in terms of currency and validity?

[kurnal]

Generally in terms of enforcement- periodic inspections -  the latest document will be taken as the current relevant FRA. But if a fire did occur that led to injury or death as a result of an inadequate fire alarm and detection system then previous documents and recommendations, and the duty holders response to them would come under scrutiny and examination by the court.

For those susequent assessments that did not recommend an upgrade to the alarm system the fire risk assessor should have helped the duty holder by stating why the current fire alarm arrangements are satisfactory. This would have enabled the duty holder to use the defence of due diligence and given them the protection they were paying for.

[lyledunn]

Thanks Kurnal. I should have pointed out that the various assessors were not told that a previous assessment had been conducted. They probably did ask but knowing the club secretary he likely thought that giving them sight of a previous assessment would make their job too easy! All but one used PAS 79.

[AnthonyB]

I think the answer to the discrepancy lies in the one assessor recommending significant additional work being the one recommended by the fire alarm company.......

The latest one would be the one referred to, although if there was some horrific disaster any inquest/enquiry may look at previous stuff.

I'll happily reverse excessive requirements from previous assessors (or equally impose greater ones) depending on the situation - the important thing is to give a rationale as to why it's satisfactory - a prospective client of hours has had two FRAs in a row from two different providers rejected by enforcement as they don't, amongst other things, justify why the current general fire precautions are adequate. The FRS aren't particularly requiring the extra GFP's that could be implemented but want to see in the FRA why they aren't required .

[Davo]

Hi Lyle

What do you mean by large?rambling?
Are the members ramblers or are the premises rambling? (?10K)
I would not be concerned about using PAS79, no doubt CT would see this a a big tick for his system............

davo

ps there is a requirement to keep old FRAs for evidence as Prof points out

[lyledunn]

Davo, rambling in terms of extent, at least in comparison to other private members clubs. The rambling nature with lots of rooms, some no longer used, was part of the reason given for the upgrade proposal.