Assessment of fire risk by building owners / occupiers has developed from the general HASAWA and Management Reg’s Health and Safety risk assessment regime, which relies upon those occupants to have the best knowledge of their workplace and what goes on in it, and who are thus best placed to identify the hazards and assess the risks. Why treat fire safety any different – the same people are responsible and it should be assessed in exactly the same way as the myriad of other safety risks that are dealt with successfully on a daily basis? This argument is, in my humble opinion, fundamentally flawed, for some key reasons.
For most hazards, responsible and vigilant managers should be able to identify them, and assess the seriousness of the consequences. It’s fairly straightforward to identify that a mezzanine without handrails could result in someone falling to their death, and to identify a suitable risk reduction measure, for example. Most people are nowhere near equipped to conceive how a fire can start and develop – how fast it can grow inside a building, how much smoke can result from even a small item burning and how smoke can move more quickly than you can run and how little time their might be to mobilise a response. Their sole experience of a big fire might be warming their hands in front of a nice, big friendly bonfire on November the 5th. Without this experience, unless they have clear and easy-to-follow guidance, they cannot be expected to adequately assess fire risk, or to identify appropriate risk reduction measures. I’d argue that the current RR(FS)O Guidance is neither clear nor is it easy-to-follow.
The second key issue is that the consequences of a fire can be vastly different to the consequences of almost any other workplace hazard. Most hazards might cause significant risk to one or two people. Fire can (and has) caused multiple casualties. Society has an intolerance of such incidents, especially in places where people place themselves in the charge of others (like hotels, transport premises and places of entertainment). People expect, rightly or wrongly, complete safety when they ‘surrender’ themselves into the care of others in those places. This is a prime reason why we have had incident-led legislation, following fires such as King’s Cross and Bradford.
The third key issue is that, for most building managers, there is an underlying assumption that a fire will never happen in their building. This makes fire safety a ‘grudge purchase’ – they see no benefit in investing in it, and will not do so unless someone forces them to do so. Even if they have conscientious safety people who recommend improvement, my experience is that the Bean Counters simply say “Show me where the law says that I have to do it” and, of course, the law actually mandates very little – you can do more or less what you like, provided that you believe you’ve assessed the risks. Weak and woolly ‘enforcement concordat’ – type regulation is the greatest supporter of such people, and undermines those in those organisations who want to do reduce fire risk, but cannot rely upon the Brigades to back them up with firm advice, or even enforcement. Believe me – it happens.
I predict that fire deaths in certain types of premises (hotels and other sleeping risks, and in places where a significant number of the occupants are disabled) WILL rise, as a direct consequence of this legislation. If all goes as planned, and the fire authorities target domestic fire safety, we might, though, see a reduction in deaths in the home. With a limited amount of money to spend on fire safety in the UK, maybe this is as it should be? Let’s not pretend, though, that the current risk-based regime will improve, or even maintain, fire safety in non-domestic premises, because I just don’t see the mechanism by which this will happen.
Rant over!
