Suitability of Fire Risk Assessment

[Nearlybaldandgrey]

That's a bit harsh Wee Brian.

I'll have you know I'm a professional and do not do any work outside my employment, after all, I'd hate to think I was taking work from you consultants!!!

[Nearlybaldandgrey]

Anyway, is there any chance of getting back to the topic in hand rather than wasting my thread with banter?

[jokar]

The question was, I believe, is this a suitable and sufficient risk assessment.  The answer is, it is a suitable and sufficient risk assessment methodology.  Whether a suitable and sufficient risk assessment for fire comes out of it, is a different question entirely.  But that question is not for FRS personnel to answer, their role is too enforce (police), (the only legal enforcers in the UK are the Judiciary), the legislation.  FRS personnel do not have to conduct a suitable and sufficient risk assessment they have to find out by questioning the employer, currently, or the Responsible Person after RR(FS)O is enacted, whether that person has conducted a suitable and sufficient risk assessment for fire.  The recorded RA or FRA is a journey not the end of the journey.  You can get from London to Manchester in a variety of ways, RA Methodology, but the outcome is being in Manchester.  Whether the journey is suitable and sufficient is in the eyes of the journeymaker not anyone else.  In this analogy, it is for the FRS person to find out how the journey was undertaken and perhaps advise a better one if possible taking all things into account.

Whether consultants like the methodology is a different matter entirely.  Have an opinion by all means, but make sure yours is suitable and sufficient first, after all that is how you make your money.  The same things apply to yourself about the journey, it is only your version, may not be the best or the worse, but do not humpy if someone with a different opinion questions it, that may be there job.

5 Step approach: Risk Assessment for Fire

1. Hazard = Fire
2. People at Risk = everyone
3. Evaluation = 5 causes of fire The Sun, Lightening. Friction, Electricity and Chemical Reaction.  Therefore, we need some Control Measures which in the first instance may be behavioural for people, such as training, management and policies.  But even then a fire could occur, so we need some detection and warning and then we may need to put it out.  Eventually we may need to leave the premises, not all that often so may have to look at means of escape issues or compartmentation/separation.
4. Need to write it up, including any additional control meaures.
5. Review when necessary.

Now take the above apply it at home or better still eduacte and inform your partner/children in how to do it and see what they come up with.  You may be surprised.

[kurnal]

Sorry Jokar but I disagree with most of that.
The Fire Authority should  first be interested in the outcome- ie the level of residual risk that the responsible person has achieved through his risk assessment process. If it is as low as can reasonably achieved that is the end of the matter. The route taken to achieve this is irrelevant.
The FSO may wish to query risk assessment methodology  as part of an investigation if something has gone wrong.

But during an inspection they dont have to be that helpful. All they need to do is to point out that the level of risk is unacceptably high naming the aspect they are dissatisfied with. And tell the RP to review their assessment.

Hazard may be fire, smoke or explosion, or slips trips and falls, crushing due to inadequate means of escape or lack of provision for slower moving people on staircases.

People at risk could be employees, visitors, patients, contractors, customers, people with little or no eyesight, people who use wheelchairs, very young people, old people, people whose first language is other than English, people who may not recognise European graphic symbols etc etc. All people who could be affected by fire should  be considered and their special needs taken into account. It can never be as simple as everyone. Now where did that checklist cover issues like those?

[Paul]

Agree Kurnal,

I think the FPA have let themselves down here.  Even if we consider the guidance that supports PAS 79, we can see what must be considered in assessing the overall assessment of a premise / occupancy.  I think as a minimum the PAS 79 should of been used.  Not a big fan of it, but it does use a simple methodology that if used by a suitably qualified / experienced person would result in a suitable and sufficient assessment, as it does consider the elements you point out Kurnal.

In saying that, as Kurnal says, the end result of this has to be policed, as everyones perception of risk is different.  Although I feel this is a double edged sword in itself.  

P.

[jokar]

Kurnal, your impression of what FRS's are to do after RR(FS)O may well be limited.  The CFOA documentation is not about inspection as old school FPA people will know but more linked to the question set approach.  The Policy is available on the CFOA website and the 20 page form that a FSO will have to complete will take longer than the allocated hours that the HO use now without any inspection process.  Out of that they will not particularly have to form an impression just follow the flow charts and numerical values to get to whatever notice they are led to.  All roads point to self compliance and the majority of small to medium businesses may never see an FSO again if there programmed Very High and High risk premises are large in terms of quantity and that is without consultation with the local authority and Licensing, if they still make representation under the 2003 Act of course.

As regards PAS 79, like all things, completion is easy, but knowledge can be a good or dangerous thing.  I have seen a number of completed ones and they do not actually consider risk too much, just test the control measures already in place.

[PhilB]

I agree Jokar. I have seen many PAS79 samples poorly completed. If the commentry boxes are not used sufficiently it becomes a glorified tick box type assessment. As you are all probably aware I am not a great fan of PAS79 but if completed correctly by a competent assessor it does the job unlike the FPA checklist being discussed.

[val]

Jokar,

The CFOA/ODPM/DCLG audit form is far from perfect but two thirds of it is assessing compliance with the RRO. It doesn't, in itself, take longer than an hour to fill in although a properly conducted audit may/should take longer than this. (The actual form should be pre-populated with the majority of details).
In any event it is much better than the true 'tick box' inspection that we used to carry out with a fire certificate plan!

The aim of the audit/enforcement activity is to leave the premises safer than it was before and the scoring system doesn't take away professional judgement but does provide a transparent and consistent method of assessing relative risk and taking appropriate enforcement action. Trials have shown that it produces similar actions from inspectors with a variety of backgrounds...surely this must be a good thing.

Returning to the suitable and sufficient theme, I agree it is tremendously hard to come up with a definition of S & S. Even the Courts have not tried that!! If the premises, in the judgement of the enforcing inspector, has fairly serious hazards and significant risks then the FRA is neither suitable or sufficient. Conversly, if the premises have no significant dangers then the FRA must, by default, be S & S.

[kurnal]

Jokar
Out of interest who do you think will be filling in most of the forms? Is it likely to be a qualified Fire Safety Officer or will the volume of the task require fire crews to compile the data?  If I recall (I did get involved in the early stages of their development before I bailed out) much of the data to be gathered relates to operational risk, heritage risk, societal risk and environmental risk.
Quite appropriate for operational crews to gather the info. But will they have the training and experience in most brigades to make a realistic judgement on the S&S of the RPs risk assessment?

But assuming that brigades need this information to inform their IRMP and populate the risk management model, they need the data in a hurry and so  will naturally start with a desk top exercise to identify high risk premises for the first batch of inspections. And in some brigades a desk top exercise based on looking at plans and past history may be  as far as it will go?  

I thought that allocated hours had died with many other great traditions!!!  Or is the  1100 hours still alive and well?  As long as you all wear caps and salute each other I can still sleep safe in my bed knowing the old standards are being upheld.

[Paul]

As I said in my previous post, I am not a big fan of PAS 79 either but as an example of a methodology that I assume most on here are familiar with, it does work providing it is carried out by a suitably experienced person.  Yes I agree, anyone can fill such forms in and the issue is then that it takes the form of a tick sheet, as with any predetermined proforma FRA's.

I too have seen very poorly completed assessments, not just of the PAS 79 method.  This I feel is down to the individual, not the methodology, and that brings me to my point ( eventually).  Any person who is carrying out a FRA and uses the FPA suggested method, then they should n't be in the business as Kurnal you say, it does not come close in assessing some key elements that are absolutely essential such as occupant characteristics.

I think we all agree the FPA method is poor and its a shame its been portrayed in this way.  However equally important is the competency of the person carrying out the assessment itself, as a competent person would not use it.

P

[jokar]

Kurnal, I would imagine, and I do not know, that FSO's will complete the form.  For some Brigades, the process of training operational personnel in fire safety is a massive step forward, shouldn't they have been doing it since the seventies?  Part of the process is a look backwards at previous history, although how that affects current management is a worry, and then a huge step forward into thinking and communicating with RP's and Consultants.  On top of that professional judgement and no bullying tactics, oh and 1500 hours or so I am led to believe.

Val, the form relies in some sense on computers, handheld or laptops, and a system that allows this data to be inputted into a Brigade mainframe.  This will not happen in some Brigades and will be a hand-draulic process, doubled, as the information will then need to be fed into the computer by someone.  As much as I agree that the scoring is consistent, and by heavens do we need that, the process of inputting FSEC and IRMP data takes time and needs information on builings whereby RR(FS)O is about premises and never the twain shall met.  I have to say I really like the Risk Calculator Matrix for re-inspections but getting some FSO's to divorce 1 score from the other will not be easy.  Some even have difficulty with the stair calculations in B1.

[novascot]

Having looked at many FRA templates some good, some crap and some not even as good as that, it is more important that the person who conducts the FRA is "competent". We all know the definition of that word. (Sufficient training and experience or knowledge or other qualities.)

 Many responsible persons assume that they can fill in "the form" themselves, regardless of the size, construction, layout or occupancy.

It is obvious that many "practitioners" are not competent in that sense.
We have people calling themselves Fire Risk Consultants because they spent 30 years sitting in the back of a Fire Engine.

It is time that Regulation was brought in with third party accreditation. I am not neccessarily beating the IFE Risk Assessor Register drum but it is a start.

The last bit of the rant concerns  Jokars' assertion that operational personnel will be auditing the FRA. I can see  HMI being swamped with appeals.

The interpretation of the guidance is going to be crucial. I hope we are not going to go back to quoting paragraphs from ADB or Technical Standards. The Guidance for Residential Care Homes issued by the Scottish Executive gives The Technical Standards as benchmarks which is fair. Uniformed personnel will have to realize that the benchmark, if required, can be raised or lowered depending on circumstances. They are not set in stone.  Even for new build. How many of you have seen buildings designed to DD9999?

[novascot]

sorry jokar. I misread the first line.

[PhilB]

Jokar,

If the premises, in the judgement of the enforcing inspector, has fairly serious hazards and significant risks then the FRA is neither suitable or sufficient. Conversly, if the premises have no significant dangers then the FRA must, by default, be S & S.

Val I don't agree but you raise a good point. If you follow your reasoning an inspector of a brand new building completed in accordance with Building Regs would be told by the responsible person "I have carried out my assessment, there are no significant findings because there are no deficiencies."

CFOA make the same misleading point in their draft policy directive. They say the significant findings should be recorded together with the measures taken to deal with them. Suggesting as you do that significant findings are defects only! The draft guidance for RRFSO had poor definitions of significant findings that also said SFs were defects only.

There are plenty of premises out there that have no signifcant dangers but do not have suitable and sufficient risk assessments to ensure the premises remain safe.

To be suitable and sufficient the assessment should record the significant findings. Significant findings should include:

            A record of the preventitive & protective measures
            An accurate list of deficiencies together with an action plan for their remedy
            Proof that a suitable & sufficient assessment has been made. i.e conclusions with reasoning.

In my opinion many RAs are not suitable and sufficient because there is no conclusion that the premises is safe in terms of time vs tenability for the occupants.  This conclusion must be supported by sound reasoning.

A CHECKLIST AS RECOMMENDED BY FPA IS NOT SOUND REASONING!


Finally as I climb down from my soapbox can I remind everyone, and the FPA that both existing legislation and RRFSO also require that fire safety management arrangements are recorded. i.e. planning, orrganisation, control, moitoring and review.

[Sarajayne]

I think that there is one important point that you seem to have not mentioned.  Currently under the WP Regs an employer or responsible person can only be guilty of 2 offences:  Failure to comply with the WP Regs and failure to comply with an enforcement notice issues under the WP Regs.  Therefore by conducting an assessment in what ever format, they have complied with the requirent to conduct a fire risk assesssment, what is then debatable is if the FRA is suitable and sufficient in the professional opinion of the auditor (FSO or otherwises)
To my knowledge there is no case law to determine what is suitable and suffiecient (fire safety or H&S)  but is seems that the sutability of a FRA can be directed at the level of detail which would normally be proportionate to the risk whilst the sufficency is directed at the required competency of the assessor.