Jokar
The CFOA guidance doesn't seek to replace FPA Circular 28. It does present a new way of measuring relative risk, thereby giving FRS a chance of developing a quantifiable and defendable risk based inspection policy. The data is supported by the ODPM and means that FRS can direct their resources, (if they have any left that is) at those premises presenting the highest risk. (Mostly life risk but now incorporating some aspects of societal risk). CFOA, who have no real power, have indicated that all FRS should adopt this guidance and tweak for local conditions 'where necessary'. It is true that maverick CFO's (or finance managers) may ignore it but that's local democracy for you.
The enforcers guidance will be published by the Fire policy Division of the ODPM 'shortly'. CFOA, (or rather a group of pretty experienced FSO's from around the country) have had a hand in this. It is still being refined by an extremely capable civil servant. I have no doubt it will help FRS understand some of the more tricky aspects of the new legislation.