Defining the Key Requirements of Article 11

[Messy]

I am reviewing the format of our fire risk assessment report document that I inherited, and one area that needs clarifying is the matters recorded under Article 11.  i believe that the current report format does record the necessary information, but it hides it in various sections across the report.

I would like to create an index as an appendix to the report which shows where the relevant information is located within the report. For example, the fire drill policy....... page 21. I want to go a little further and divide the index into headings that reflect Article 11 such as:

1) Planning,
2) Organisation,
3) Monitoring
4) Review

But I am struggling to determine the definition of the above terms. For example, is a fire drill planning? (as its scheduled), Monitoring? (as observers will be in place and staff feedback encouraged)  or review? (as its essentially reviewing current arrangements)

So in the absence of interpretation information in Article 2, how would you define 1 to 4 above? - (or is there a formal definition somewhere??)

[Mike Buckley]

Prior to Mr Todd leaping in. Why bother? Look at adopting PAS 79 which covers most areas and is fairly well accepted throughout the country, if you need additional information there is nothing to stop you adding more fields to cover your particular circumstances.

[kurnal]

My initial and possibly ill-considered response is I think it can be a mistake to try and match the duties under the RRO to the general HASAWA and management regs and the more recent  HSG 65. The order specifically  disaaplies the management regs and HASAWA provisions where these are covered by provisions within the RRO.

On further consideration if you wish to go down this path it may be  best to work through each article of the RRO and consider where these would sit under POCMAR as this is explicit in the RRO. (You already appear to be taking this approach). You could for example analyse the PAS 79  checklist with each element measured against a matrix with the POCMAR headings using a tick box. If this was not enough you could then re-order the PAS 79 risk assessment template to be more helpful by setting out the POCMAR headings  in the checklist and a 1 line statement under each main heading.

[colin todd]

Davey, you should know from your previous employer that FRS will use A11 for anything they fancy if they want to prosecute someone.

[Messy]

Davey, you should know from your previous employer that FRS will use A11 for anything they fancy if they want to prosecute someone.

And Colin, you should know that from contact with my previous employer (as I witnessed one famous telephone conversation) that not all IOs are as switched on as others and some can get a little 'confused' sometimes.

I agree, Article 11 is a favourite enforcement tool to use as its so loosely worded and pretty much anything can be squeezed into a definition. This is why I want any reviewed design of the FRA report to be able to guide IOs to the various sections of the report where Article 11 applies. For example, some IOs are now insisting that there is a separate document detailing fire safety policy, and it's this document that should be crammed full with Article 11 stuff, even if its repeating information that is already recorded elsewhere. OK, for some premises, and certainly for some RPs, I agree this sensible, but not all.

It seems to me that Article 2 should have had details of how the phrases in Article 11 should be interpreted to stop these confused IOs getting more lost!

[K Lard]

I am reviewing the format of our fire risk assessment report document that I inherited, and one area that needs clarifying is the matters recorded under Article 11.  i believe that the current report format does record the necessary information, but it hides it in various sections across the report.

I would like to create an index as an appendix to the report which shows where the relevant information is located within the report. For example, the fire drill policy....... page 21. I want to go a little further and divide the index into headings that reflect Article 11 such as:

1) Planning,
2) Organisation,
3) Monitoring
4) Review

But I am struggling to determine the definition of the above terms. For example, is a fire drill planning? (as its scheduled), Monitoring? (as observers will be in place and staff feedback encouraged)  or review? (as its essentially reviewing current arrangements)

So in the absence of interpretation information in Article 2, how would you define 1 to 4 above? - (or is there a formal definition somewhere??)

Refer to Collected Perceived Insights Into and Application of The Regulatory Reform (Fire Safety) Order 2005 For the Benefit of Enforcing Authorities if you haven't done already. This will give you an idea of what enforcing authorities are looking for.