Hmmm... interesting debate; so maybe I'm working under several misconceptions then.
1) I thought that if you had a safety system, such as a fire alarm, it had to be properly maintained and to be properly maintained it MUST be maintained to a recognized or appropriate standard. It does not have to be the British Standard but has to be a suitable standard. Playing devil's advocate then; the alternative is that the RP does not have to test or maintain their fire alarm system as long as when an IO asks for a demonstration the system operates?
2) Section 3 of BS5839 is part of the standard, since when did we now allow people to pick and choose which parts of a standard they conform with? Reasonable variations yes, but surely not to disregard a whole section and then still claim that it conforms?
3) AM wrote "To serve any kind of notice, there has to be a failure of the responsible person's duties under the order, and that failure has put one or more relevant persons at risk." - I've re-read Article 30: Enforcement Notices and I can see no reference to putting relevant persons at risk only failure to comply with provisions of the Order; have I missed something?
4) Jokar wrote "If you use Article 17 what you are saying is that the equipment is not being maintained "in efficient working order and kept in good repair" and UWFS do not fit that category." Quite possibly. If it's a system fault? - definitely yes. Inappropriate detector head for the risk? - probably yes. Incorrect siting of detector? - maybe. Not being maintained to a recognized standard? - surely!!!
5) jokar wrote "In most cases the system is doing its job which is reacting to the circumstances around it." which surely is the crux of the matter. A fire alarm system, if doing its job, should detect fire, it should NOT detect steam, dust, insects, etc. FADs cause unnecessary disruption and should not be tolerated by either the business or the FRS. New developments in this field could virtually eliminate false alarms of this type.