Dry Riser Removal Enquiry

[PhilHallmark]

I have a customer who has requested we remove both dry riser stacks within her property. She holds the position of Health & Safety Manager (!).

Can anybody define for me what Regs are in place to back up my decision to advise against carrying out this work? All I have spoken to (Including ex Brigade) advise against removal.

Have any of you guys ever heard of this being carried out before?

Please bear in mind this property is 5 floor plus undercroft with all floors fully occupied.

Am I correct in assuming this is a complete no no?

Many thanks,

Phil

[John Webb]

How about the requirements of Approved Document B? Sections 16, 17 & 18 of the 2000 editions cover the need for dry and wet risers, dependent upon height, floor area and purpose group. Presumeably the building was constructed to this or a previous edition and therefore the dry risers were required under Building Regulations. If the current Building Regulations still require them, she cannot remove them and also must see that they are maintained under the requirements of the RR(FS)O. About the only thing that they could have done to remove the need for dry risers is to fit an appropriate sprinkler system to the whole building.

[afterburner]

If there is a Fire Risk Assessment in place for the building / premises, does this 'proposal' not trigger a a need to Review the original fire risk assessment? The lack of risers may well affect the fire safety strategies and the provisions required to deliver those strategies.
The safety of fire fighters under the new legisaltion (Sorry I'm assuming the English and Welsh processes are the same) might be an issue which needs further exploration.
Lastly has an explanation been offered as to why the risers are now being considered for removal?

[Chris Houston]

Why does she want you to do this?

Aside from the legal issues, you might want to recommend to her that she run this by her property insurers.

[Martin Burford]

PhilH
why does this lady want then out ?
Conqueror

[CivvyFSO]

Building act:
3.—(1) In these Regulations “building work” means—
(c) the material alteration of a building, or a controlled service or fitting, as mentioned in paragraph (2);

(2) An alteration is material for the purposes of these Regulations if the work, or any part of it, would at any stage result—
(a) in a building or controlled service or fitting not complying with a relevant requirement where previously it did

(3) In paragraph (2) “relevant requirement” means any of the following applicable requirements of Schedule 1, namely—
paragraph B5 (access and facilities for the fire service)

So it would have to be approved at the planning stage for a start, without even considering article 38 of the RRFSO.

But... Are we back to having some approved inspector who might decide that if the fee is high enough he will 'accept' it? And if so, once it is taken out can a FA do anything about it?

[PhilB]

Article 38 is quite clear on this in my opinion.

[CivvyFSO]

But if someone actually gets the 'ok' to get it removed from building control (unlikely I know but imagine some unscrupulous AI.. then we are faced with a building that has no dry riser to maintain/keep working. Article 38 says nothing about putting a new riser in place. If it is there they have to maintain it, but once it is out surely we have no legislative power unless it somehow affects MOE. If the building is evacuated in 2.5mins then the riser has no benefits for relevant persons so cannot be introduced retrospectively under RRFSO?

BUT... After thinking about it a bit more... If there's a dry riser there will also be a firefighting shaft... And the riser is an integral part of the firefighting shaft, and if removed we can have it reinstated as a necessary facility in the firefighting shaft.

YAY! We win. I think.

[Fishy]

Article 38 is quite clear on this in my opinion.

Absolutely, Phil.  By installing the kit it in the first place it has been demonstrated that it's a reasonably practicable risk reduction measure - it has therefore been established as being 'necessary'.  Once that's established, Article 38 kicks in.  

Using risk assessment to justify reducing existing levels of safety is known as 'Reverse ALARP', and all the HSE guidance on risk assessment states that this practice is unacceptable.

[PhilHallmark]

Your replies have been very usefull and informative.

Many thanks to all.

The lady in question, I believe, acted upon impulse regarding the condition of the system and my subsequent advice to get them pressure tested (not having been inspected for a number of years), which I have re iterated is still required. I have also advised she contacts her local Safety Officer and her insurer to provide a written confirmation for removal to me prior to any removal - which undoubtably she will not receive and has a RA carried out to confirm the fire cover requirements.

Now with your info I can do the relevant research for the correct Regs to quote her with.
I requested from you guys some back up info as I am not clued up on the relevent Building Regs and thought I would take a short cut with you guys and you have come up trumps.

Many Thanks,

Phil

[PhilB]

Article 38 says nothing about putting a new riser in place. If it is there they have to maintain it, but once it is out surely we have no legislative power unless it somehow affects MOE. If the building is evacuated in 2.5mins then the riser has no benefits for relevant persons so cannot be introduced retrospectively under RRFSO?

Article 38 is about facilities provided " for the use by or protection of fire-fighters" not for the safety of relevant persons. So evacuation time is not relevant.

[CivvyFSO]

I was on about if the dry risers are actually taken out without our knowledge, whether we would have the capability of getting them reinstated AFTER that under the RRO. Once they are out there is no need to maintain them etc as they are not provided any more.

You really need to read things through properly!

[CivvyFSO]

But also see the part I mentioned regarding them being an integral part of a provided FF shaft.

[PhilB]

"the responsible person must ensure that the premises and any facilities, equipment and devices
provided in respect of the premises for the use by or protection of fire-fighters under this Order or
under any other enactment, including any enactment repealed or revoked by this Order, are subject
to a suitable system of maintenance and are maintained in an efficient state, in efficient working
order and in good repair."

I would suggest Civvy that the removal of the riser would be a failure to maintain it in an efficient state or efficient working order. There is a slight problem in that failure to comply with Article 38 is only an offence if relevant persons are placed at risk by that failure, and firefighters are not relevant persons.

But If a FRS discovered a situation where a main has been removed they could serve an enforcemnt notice to have it replaced...in my opinion of course.

And I did read it through throughly...honest!

[PhilHallmark]

PhilH
why does this lady want then out ?
Conqueror

I think she felt her authority was in question to be honest C.  as I advised a full wet test when I carried out the extinguisher servicing as well as removal of the hose reels (You would not believe the state of those! Seriously poor, not been maintained for years and some could not move i.e. turn that is , swinging was out of the question, within the recess, literally trapped, with a locked door on the recess. No signage to indicate the risers or hoses within these locked cabinets either! (Very handy for the Fire Fighters)) and she had a knee jerk reaction - to show her boss that she was in control as she was not impressed with anothers (mine) critisism of her domain. Although it was advice not a critisism as that never works.
She therefore demanded we remove the risers, but this has obviously led to problems for her.

It is just one of those jobs that makes life interesting!

Phil