Special Premises regs.

[martyn brandrick]

Any thoughts on the Fire Scotland Act in relation to special premises.  Special premises cert no longer have force and HSE no longer the enforcers unless it is plant/process areas, however where does this end and what bearing does the process have on the MOE for relevant persons.  A bit of a fuzzy layer!!!

[PhilB]

Hi Marty

Much the same in England and Wales..yes special premises certs are gone..so FRS now enforce fire safety law in these premises ..but this only deals with general fire precautions....HSE retain control of process risks. Of course process risks will impinge on the general fire precautions so it does become a little confused.

But..the responsible person retains accountability and has a duty to appoint competent persons to assist him...so in the scariest places the enforcers should have access to someone who can answer the difficult questions.

P.S I hope your adjusting to life back in the real world.

[slubberdegullion]

A bit of a fuzzy layer!!!

"Fuzzy layer!!"  I think you're straying into my territory.

Come in, come innnnn............wellllcommmme............

[kurnal]

Its ok for the enforcers as Phil says you have a lever to ensure the RP gives you access to somebody competent. For the competent person appointed to advise on fire at these plants sometimes its harder to get access to specialist advice. In fact often you encounter situatons in industry where the process risk is definately not well controlled and makes your bottom constrict even though you dont have the competence to put it right. But what do you do? Well you advise your client that an enforcement visit is very likely and is likely to reslt in a prosecution/ prohibition/ enforcement  and information will be shared with HSE. You then make recommendations and apply appropriate travel distances etc  according to your assessment of the current risk and the  residual risk.

Example was in a confined underground space under a foundry. Uncontrolled process risk due to zero ventilation and use of argon- heavier than air. Fire risk assessment outcome- no access whilst argon system live. If argon isolated and O2 monitoring in place access may be possible- but current travel distance of 45m unacceptable - if kiln fails or spills risk of sudden conflagration and rapid fire spread. Apply travel distances of 6 and 12m in addition to outcome of process risk assessment by others.