The New Guidance Documents

[val]

My apologies...I meant if the 'auditor' could identify no significant hazards then by whatever route the responsible person had arrived at their position must be suitable and sufficient.
If a highly trained professional auditor cannot ask the right questions to challenge that position then they shouldn't be doing the job.
Those who are subject to no auditing process may, I agree miss something critical.
I know...lets employ some FRS inspectors or buy-in some consultants.

[wee brian]

well said Val

Blokes like phil will spend a day looking at the paperwork in the office when an inspection of the premises is whats required.

Point to note - its only an offence if a failure to have a suitable and sufficient RA puts somebody at risk.

Its unrealistic to record every protective measure in a building even Fire Certificates didnt do that.

Where are the cavity barriers in the walls? What's the period of fire resistance for the structure, hang on I'll just cut a hole in the floor to find out!

The whole idea that the Government is pushing is that people take some responsibility for their premises and that they think about basic fire prevention and protection. It's not rocket science.

The guides provide plenty, if not too much, information for most people to do this. It may not result in an A level standard document but that's not what it's about.

If the premises is well run and reasonably safe then mission accomplished.

[Nearlybaldandgrey]

I still don't get why an inspection only is required.

Am I having a thick day or am I missing something here?

Someone explain!!!

[wee brian]

The argument is (I think)

How much stuff should be inlcuded in the "Significant Findings" of a risk assessment. There are two views;
one is -- all the protective measures that are necessary in the building should be identified, including all of them that are already in place.

The other view is that - -only those additional measures that are identified as being required should be recorded.

I am a number two and Phil is a number one.

Phil seams to be saying that unless everything is recorded it would not be possible to check if the RA was suitable a sufficient. I think that any enforcement officer looking at a premises should focus on what he finds in the premises and the way it is being run and not worry too much about the Risk Assessment documentation.

[wtfdik]

Blokes like phil will spend a day looking at the paperwork in the office when an inspection of the premises is whats required.

.

I will remember that when the police stop me I will say dont bother with the paperwork (tax MOT Licence etc)
Just inspect the car and tell me what to do and I will be on my way.

oe the HSE just check the equipment yourself dont worry about paperwork

See how far I get

[Paul]

Then what you in actual fact you are saying, Wee B, is that you shouldn't identify significant findings that are already in place and that in order for an inspecting officer to see what is in place, they must themselves carry out an assessment.

If the risk assessment were to merely point out the shortfalls within the said significant findings, then how would an inspecting officer assess if the assessment were suitable and sufficient.  He would not know, without a physical inspection, why the origial assessor had reached the conclusions to make such recommendations.

Again if you were making recommnedations regarding the significant hazards, surley you could not just make the recommndations without detailing what controls, if any, are already in place.

Wee B, you should know by now, that if you don't record something in terms of any H&S you may as well not bother doing it as you can't prove its been done.

Phil,  Obviously the dig about peresons not understanding the RA process was aimed at me.  Obviously we may beg to differ, however I would suggest that significant findings and significant hazards meet at some point.  For example if you were to identify a smoking hut in a HAC zone 20 (not realistic I know) as a significant hazard and risk for that matter, the fact that the dangers of such activities in such an area has not been communicated to staff is a significant finding.  However in my opinion both are significant findings.

I must admit though Phil I do agree with you on most of this, although I'm sure you'll disagree with me here.
P

[val]

It is all about being realistic.
I am not advocating unsafe premises or sloppy management but most organisations have other things to worry about. If spending a few hours thinking hard about reducing the risk and being able to work with the systems you put in place on a long term basis protects 95% of the people, then it is probably as much as you can ask for.
What Phil is asking for is heaps of extra work (probably copied from a web site or nicked from Colin), which MAY protect the other 5%.
If Fire Authorities are allowed to maintain a reasonable inspection team and the fire consultants who aren't purely cost driven give Mr Manager a kicking every so often then so much the better.
I have been on building projects when the CDM requirements are stored in a portacabin and moved from site to site. No-one knew what was in them but they certainly looked impressive!

[Gary Howe]

Val,

You are dead right, you have to be pragmatic about the whole process, we all know sites where there are rows and rows of FRA, H&S stuff on the shelves gathering dust.

The problem only really occurs when an injury or loss of life occurs, because then some smart a****d lawyer is going to try to rip your FRA to shreds (I know I am being cynical), if they can.

It is only at that moment in time you are glad you spent the time and effort to make sure you dotted the i's and crossed the t's, this is where 'suitable' and sufficient' rears its ugly head again.

At the end of the day its not just about the FRA document is it? (though you have to cover your rear end) its about the management and culture on the shop floor. This will undoubtley be a major, major factor in having a safe work place, will it not?

[Paul]

Yes, Gary and the Fire Risk Assessment should form the whole basis of the fire safety culture, if it is not already in place.

Although you can take a horse to water.

[PhilB]

Blokes like phil will spend a day looking at the paperwork in the office when an inspection of the premises is whats required.

How very dare you Weee Brian.....you have again missed the point...nothing new there!

 P Smith the dig about not understanding the risk assessment process was in fact aimed at Val...but if the cap fits....

Val I do not copy things from websites and certainly would not nick anything from Mr Toddd.....why anyone would want to is beyond me!!!......now has that dealt with all the insults?

Now calm down girls and boys....I do not mean to offend anyone........but it's nice to see I've got some good discussion going.


Getting back to the debate..I personally believe that significant findings should inlclude what is present...what is needed......and reasoning to support that view...........and of course it should be proportional to the risk.

Wee Brian you say fire certificates didn't record preventitive & protective measures?.......they did...blokes like me issued them... and inspected premises to ensure compliance...usually with the help of a  plan.....and no....you don't need to record all cavity barriers etc......please read the Order again...look at defintions of general fire precautions & preventitive & protective measures.........that should clear things up.

Also lets not forget that Article 11 of the Order requires that the arrangements for planning, organisation,control, monitoring and review of the preventitive & protective measures are recorded.......nothing new...but many forget this when compiling these documents that blokes  like me spend too long looking at.


It does concern me a tad that people like us have such a diversity of opinion regarding what should be recorded......no doubt the govt. will soon provide us with the long awaited circular to answer all our questions!

[Paul]

Gentlemen and Gentle ladies,

This is something I have posted on before.  The fact that the Fire Risk Assessment process is open to ambiguity and one persons perception of risk is different than another’s.  How do we then resolve these issues. Yes, as Val says, we need to be reasonable about what we are doing here, and yes we can not list every measure relating to fire precautions.  However I do believe we can have a good go.  

Unfortunately we are now stuck with what we have got and have to take it forward.  It is somewhat concerning for me that the Certification process has been replaced by what is nothing more than attempt to reduce the workload of FPO’s and even in some cases replace them with non uniformed support staff who are paid little more than a security guard to provide a professional service.

This is a time for increased enforcement not reduction.  What I am struggling to come to terms with is that such a responsibility has now been handed over to the employer, who in general terms has no fire safety experience / qualifications.

I too feel concerned that there is such a difference in opinion amongst fire safety professionals.  Is it that those with such diverse opinions are merely defending the very guides and FRA processes that they have been involved with?  I feel this may be the case.

I know that PAS 79 is currently under review. All I can ask is, who is evolved in this review?  Do we opportunity to get involved in that process, or is it the very persons who developed the ‘guides’?

Frightening!!

[wee brian]

What worries me is that FPOs will spend their time picking holes in FRAs that have been produced by those organisations who are trying to comply rather than going after the real villains.

[Paul]

Wee B,

Yes this is a concern of mine, although I haven't come across it yet.

I have carried work out for some clients that have had previous fire risk assessments carried out and FPO's have picked holes in them to the extent where an enforcement notice has been served.  In such cases I have been involved with the FRA's they have poo pooed have simply not been up to it, nothing more than tick sheets.

On the whole the FPO's I have worked with have been nothing but supportive and in actual fact very interested in how we carry out FRA's and this runs from up in Aberdeen, Glasgow, NE, NW, Mids, to London.

Still feel more enforcement is needed at times like these!!

P

[ian gough]

We agree again Wee B......(must be the weather!).

[jokar]

I can categorically state that Inspecting Officers in a large met brigade will not be inspecting premises.  They will be auditing the FRA and the management of a premises, not a builidng, and this may include a little look see as a checking point.  The role is to enforce not inspect, the legislation is for the RP after all.  As reagrds the guidance, it is just that, do what you feel is right and if you have to justify it then do so.  The absolute duty is in the legislation, Article 9.7.a. Record the significant findings, including the measures that are already in place and the ones to be put in place, an abridged version of course.