alterations notices

[messy]

My question is will LUL appeal against the Notice for every sub surface station, that could cost the LFB lots of money.  Proving that a premises has a serious risk when that term is not defined antwhere could be difficult.  .

With the LU system, virtually every item on our FS shopping list is non applicable, in the sense that the features of the underground system are unique: Travel distances measured in miles. Compartments measured in scores of miles. Occupancies in tens of thousands.

Until the late 1980s LU's management of FS was appalling. Limited AFD and FFE. Poor training and responsibilities. Poor maintenance and hardly any proper procedures.

I attended a fire involving a wooden sleeper in a tunnel which, despite sparks being drawn into the the tunnel every time a train passed overhead, LU wanted to allow it to burn all day so that engineers would have less timber to remove overnight. (Yes a controlled{?} burning in an occupied public transit tunnel!). I later attended the Oxford Circus 20PF (just prior to Kings X) which was caused by smokers material discarded into uncontrolled builders storage on the platform, in which we nearly lost a number of FFs and LU staff.

Since Kings X, LU management have evolved - indeed were forced to evolve-  and have introduced £millions of pounds of changes. The most significant is their management regimes.

I understand that it is the management structures/systems which are likely to be involved in any Alteration notices, rather than the actual infrastructure, as it's the quality of that management that is key to maintaining the systems within this difficult environment.

[val]

Messy...your arguments are compelling but, despite the political shennigans which retained the Sub surface regs (wasn't an RMT sponsored MP on the Scrutiny Committee?), why should LU management be treated any differently to every other in the country. If their management structure/control is poor then give them a kicking with an enforcement notice under the fire safety order. (Sorry... that should have been provide advice and encouragement).

[messy]

Val

I am not saying that LU management are poor now.

My understanding of the LFB's approach to Alteration notices is to apply them sparingly and only when an applied engineered solution is so critical to the safety of those inside the 'building' that extreme management systems are needed, and those systems therefore should be more closely monitored by the enforcing authority that the norm.

The issuing of an Alteration notice is not therefore, necessarily an indication of poor management. Instead it is a recognition that the risks are excessively high and the control of those risks is critically reliant on complex FS engineering and systems.

My understanding is that LU are not unhappy at the prospect of an Alt notice as after all, they get a lifetime (partial) fire safety consultancy free of charge.

[jokar]

My understanding of other FRs approaches are to issue the alterations notices to their high risk premises, have that as there inspection programme proactively, react to fires in premises and have a smaller fire safety workforce to meet the perceived need.  How will that work in London?

[Ricardo]

London's approach to this is that  Alteration notices will be used in two areas:

All sub surface rail stations and

Mainly on buildings with complicated FS engineered solutions which require a greater degree of management control and competence.

Such notices will be issued by principle LFB management (not local team managers) when requested. I anticipate that many will be issued to exisiting buildings

There are no plans to use Alteration notices to correct/monitor poorly performing RPs. That is a matter for enforcement and prosecution

Can I just confirm with this one, am I correct in saying that as messy has said above, all london underground stations have been issued with an alterations notice under the RRFSO? and that they also still have to comply with the FP sub surface railway stn regs 89 as well?

I am sure I have read somewhere that these regs will eventually be withdrawn, is this correct?

[ST1878]

The Sub Surface Railway Regulations 1989 are currently still in force, but it has always been the intention to replace them, therefore there has already been some pre-consultation on how this is done. I understand that a 3 month consultation document will be released, possibly in June this year, detailing the proposed changes.
Until the Regs are repealed or replaced, Fire authorities are advised to approach sub-surface stations using the RRO first, and only to fall back to the 1989 regs when absolutely neccessary.

Merseyside FRS has issued Alterations Notices to its 5 stations. This was not done to extend or prolong any control over the premises, but to formalise the arrangements that are already in place requiring notification and consultation prior to any material changes. The fact that by defenition, sub-surface stations can be considered to be premises where there is a 'fire engineered' approach to extended travel distances, was also a significant factor.

[jokar]

Ricardo, that is not correct only sub surface stations have alterations notices issued to them as meesy has stated.  Some Ug stations are above ground and are not subject to AN.  Section 12 regs are still in force and are used to be prescriptive in sub surface stations.