Inspection/Survey procedures under RR(FS)O

[ian gough]

The Enforcement management Model has been adopted as it is a recognised method.

More importantly in this age of accountability, if a fire authority is to prosecute, they have to evidence that a process has been undertaken and it isn't just a whim. The EMM is auditable and robust and can be used to show that the process has been caried out, hence the little tick box on the audit form that says "EMM applied?"

Who says so?

[val]

[The Enforcement management Model has been adopted as it is a recognised method.]

Several FRS in the NW have 'improved' the HSE Enforcement management model, which was only partially adopted anyway. THe model posted on the CFOA web site didn't go the whole hog with gap analysis and so can appear unduly presecriptive in its approach.

The model developed by the NW gives an element of discretion back to those 'bad old' FSO's so that they can avoid taking everyone to Court for daft trangressions and chucking enforcement notices around like confetti.

If the HSE want to pickup on the better model ... they are most welcome!

[ian gough]

So the NW say so?

[Nearlybaldandgrey]

Is it that relevant "who says so"?

For once, the inspecting officers are demonstrating that a process has been followed which is recognised within the legal system. It's robust and auditable which I feel is important, and if required I would be able to justify my level of enforcement when it may be considered too harsh.

If it's CFOA guidance, then the answer must be CFOA say so?

[ian gough]

Yes I think it is relevant.

[kurnal]

If I recall the EMM was devised by the "Better Regulation task force " which was later to become the "Better Regulation Executive" an official National Government body -part of the Cabinet Office.
The EMM was one of their earlier initiatives and I recollect that all government enforcement agencies were "encouraged" to adopt its principles- but I dont think this was ever a dictat. Certainly the HSE were the first organisations to embody its principles and many brigades therefore base their systems on the HSE version. But they did not invent the idea so far as I recall

[ian gough]

Thanks Kurnal.
My view of this EMM is that it may be fine for most H&S risk assessment work; however, fire risk assessments are something different. Clearly though, some fire authorities have decided to make use of it (with DCLG/HMIFS support? I wonder...) and we shall therefore have to see how this works out.
It is relevant because fire risk assessors might well take a relaxed view about a premises, advising accordingly, only for the client to be hit with an enforcement notice because of a less than satisfactory sytem being applied in a few areas of the UK.
I'm less than impressed with any of the correspondance I see being sent out by brigades at the moment!

[Pip]

Yes and I am less than impressed than the guidance currently being sent out by DCLG etc!

[val]

Pip,

You are ahead of me. What guidance from the DCLG?
Still took thirty years of circulars to get the FP Act right and then it was repealed. I get sooooooo depressed.

[black arts]

For those Officers who inspect petrol stations is the EMM the correct document?
The EMM refers to RRO.       Petroleum comes under DSEAR.

[wtfdik]

For those Officers who inspect petrol stations is the EMM the correct document?
The EMM refers to RRO.       Petroleum comes under DSEAR.

The EMM is not just for RRO it is used by many Enforcement agencies and the Fire bit of DSEAR was added to workplace Regs sometime ago