Fire Risk Assessment Audits

[jayjay]

Has any one had experience of their assessments being audited by the FRS?
I have had a couple of enquiries regarding some of my assessments from the FRS and they have asked when I am going to review the assessment, suggesting I should do it annually. One of the premises in question was a very low risk building used for classical music practice.

As there is no defined period for a review, particularly where no changes have occurred I was wondering if the FRS has any guidance on audits regarding the type of premises to target and the frequencies of reviews?

I have over 800 premises on my property list and although I have prioritised them and carry out annual reviews on high-risk premises such as care homes and large public entertainment venues it would be impossible to carry out even three yearly reviews on all premises.

These enquiries have also raised concerns on the experience of the auditors. The person in question was until recently a civilian employee of the FRS and is now a watch commander who has no fire safety training or qualifications, engaged on auditing assessments based on 30 years of experience and college training.
I would be intersted in knowing how other FRS are enforcing the RRO.

[kurnal]

I suppose it depends whether you are the responsible person, a competent advisor in the employ of the RP or an outside consultant brought in to advise.

Only the RP has a duty to review the risk assessment and should create his policy for managing this. The review procedure should be risk based, prioritised and reasonable, there should be a number of monitoring triggers set within the policy - to catch changes to the risk profile, persons at risk, processes or substance, near misses or fire incidents. there are no compulsory time frames for review, but a routine review based on risk over a cycle is appropriate. Why not plan say  a 1, 2, 3 and 5 year cycle based on risk?  Then as an audit you could put in some thematic reviews of the higher risk issues cutting across the risk based cycle- eg maintenance of fire alarms where you sample from high, medium and low risk premises just to keep them on their toes. All the enforcing authorities do this- HSE, Local Authorities, fire brigades.

[jokar]

Ask them what they think a review is?  The answer will probably stagger you.  As pointed out above the RP is the person set to review the FRA as and when it is required.  Most FRS will like to see a 12 month review period set and dated on the FRA.  When you consider it is a live document used to manage the life safety of the premises on a daily basis, it seems very strange that FSO cannot understand it.

[CivvyFSO]

Ask them what they think a review is?  The answer will probably stagger you.  As pointed out above the RP is the person set to review the FRA as and when it is required.  Most FRS will like to see a 12 month review period set and dated on the FRA.  When you consider it is a live document used to manage the life safety of the premises on a daily basis, it seems very strange that FSO cannot understand it.

That is in the perfect world of well-managed buildings. Not in the general case of people who do a minimal risk assessment then stick it on a shelf and forget about it.

[jokar]

A 12 month review date will then do little to assist in this scenario.

[fred]

It has to be said that if FRS's were given any meaningful guidance on enforcing the Fire Safety Order it might achieve a degree of consistency in enforcement action across the country.  The guidance to enforcement they have been given is not far short of a summary of the actual FSO.  The terms 'ashtray' and 'motor bike' spring to mind.

Without it, inspecting Fire Officers will just do what they feel comfortable with - the good ones will be good and the bad ones ..........  It is inevitable that some will fall back to the bluff and persuasion mode if they don't know something that perhaps they should - it's where they feel safest.  Not many RP's will challenge them - perhaps they should.

[Chris Houston]

For a low risk environment like an office, I would expect any employer to review the fire safety annualy.  This doesn't mean they need to bring in a consultant or start with a blank sheet, but to look at the previous assessment and see what has changed since then.

I would expect the same for all health and safety risks.

[messy]

On my Brigade's audit form that I have to complete, it asks 'Is there a review programmed?'

I ignore this because, as far as I can see, as long as the RP knows the triggers for a review and that the FRA document should be treated as live/dynamic - that's good enough for me.

All this nonsense about 12 or 6 months - it's simply not in the FS(RR)O, therefore I can't ask for it, so I don't expect it.

But this is the source of why so many IOs get confused. If their audit questioniare infers that a review should be programmed, then they expect it (despite what the Order says!!)

[Chris Houston]

Firstly, there is more to good risk management than simply complying with the law.

Secondly, the law is non prescriptive, so naturally it does not say that one can wait 6 months or a year between reviews.

In most apects of health and safety in low risk environments, the formal review of risk is undertaken annually, quite why the risk of fire cannot be reviewed at least annually amazes me.  I could not accept any argument that a reputable employer would not even consider the fire safety risks to his employees for 3, 4 or 5 years - to me it is inconcievable.

[TallyHo]

Firstly, there is more to good risk management than simply complying with the law.

Secondly, the law is non prescriptive, so naturally it does not say that one can wait 6 months or a year between reviews.

In most apects of health and safety in low risk environments, the formal review of risk is undertaken annually, quite why the risk of fire cannot be reviewed at least annually amazes me.  I could not accept any argument that a reputable employer would not even consider the fire safety risks to his employees for 3, 4 or 5 years - to me it is inconcievable.

As well as the usual resons for reviewing an FRA the guides also state "You may want to re-examine the fire prevention and protection measures at the same time as your health and safety assessment."

Is that really the best they can come up with?

[afterburner]

The Fire Safety (Sotland) Regulations 2006
  3. —(1) A review of an assessment under section 53 or 54 must be carried out regularly so as to keep it up to date.

         (2) A review of an assessment under section 53 or 54 must be carried out if–

            (a) there is reason to suspect that it is no longer valid; or

            (b) there has been a significant change in the matters to which it relates including when the relevant premises, special, technical and organisational measures or organisation of the work undergo significant changes.

So, all that needs to be clarified is the 'regularly'. Halley's Comet is regular, so is Christmas. Is there as legal definition of 'regular'?

[CivvyFSO]

Are we all being slightly pedantic here? Do we really need definitions for every word in the legislation?

Surely some common sense comes into it? For the people not treating the RA as a live document is a 1 year review of provisions too much to ask? It can then nicely tie in with extinguisher servicing, 12 month inspection of fire alarm, main test of emergency lighting......

Would everyone be more up in arms if there was an actual review period in the legislation?

Regardless of when a fire authority suggests you review it, it is up to you to review it as needed. The only time it should really be an issue is if we inspect/audit a premises and the risk assessment does not cover the risks present. Then the problem is with the RA, not the review date. The review date is simply something that would have helped the RP keep his RA up to date.

[Mike Buckley]

I think the old H&S standby of "reasonably practicable" comes in here. You could argue that in a workplace things are always changing and it is not practical to keep the FRA up to the minute otherwise it is a non stop job. If the workplace is not changing and it is regularly audited then you could argue that a review every couple of years is in order. Conversely if the workplace undergoes a major change round then it would be necessary to review the FRA again even if it was only done a couple of months before.

I don't think the Fire Authority can or should insist on a set timetable, not unless they are going to inspect on a similar tiemtable.

[Chris Houston]

12 month inspection of fire alarm

At risk of being called pedantic.......It should be inspected every day, activated every week and the subject of inspection and testing by contractors 6 monthly (or as per the fire safety risk assessment, but 6 months is the timescale suggested by BS 5839).

[AnthonyB]

You are correct but many FRS seemed happy with annual only fire alarm services & similar with EL & many occupiers are happy to stick with this as its cheaper. I suppose the arguement is that the BS isn't law...