Plans with a risk assessment.

[PhilB]

Let me raise an old issue. I have always advocated the use of plans when recording the findings of a risk assessment as I can see no other effective way of recording the required information.

Plans are not always necessary in small simple premises but in larger complex premises how can you record the 'General Fire Precautions' without a plan?.......I am of course assuming that you agree that the general fire precautions are significant findings.

The 71 Act never made plans compulsory but most FRS chose to use them to record the information that a fire certificate had to contain.

I am therefore please to note that the RR(FS)O Guidance Note No.1 tends to support my view.

See paragraph ........"61.   The suitability of a risk assessment and its recording is partly reliant on its ease of understanding.  In some buildings, particularly in complex buildings, the risk assessment may need to incorporate plans showing the general fire precautions arrangements - this may be where it is not possible to identify matters clearly in the narrative of the risk assessment.  There is nothing in the Order which would directly compel a responsible person to create new plans. However, for some complex buildings a risk assessment will not be suitable and sufficient or properly recorded without additional plans.

Maybe a bit of a concern to Mr Todddd and his followers. Time to revise the PAS??

[Neil G]

I agree.

Prose or (heaven forbid) tick box forms make it difficult to indicate effective MoE, travel distances, lines of FR, locations of safety equipment, etc, etc. A picture (and plan) speaks a thousand words and are often easier to understand...

[kurnal]

Nah.
Plans have their limitations too. You can use them to indicate the locations of hazards and to illustrate the nature and extent of  risk control measures but they do nothing for evaluation of risk.
They rely on the person interpreting the arrangements and comparing them to the benchmark  guidance.
Using a plan theres no way you can say that because of X it is OK to do Y.  Thats where the SWOT analysis comes in. It doesnt refer to that in PAS 79 either.

Hey Phil have you seen paras 31 and 32 which link the definition of "suitable and sufficient"  to the traditional definition in the Management Regs and is  not  slightly different definition as we previously thought.

[PhilB]

Hey Phil have you seen paras 31 and 32 which link the definition of "suitable and sufficient"  to the traditional definition in the Management Regs and is  not  slightly different definition as we previously thought.

Yes Kurnal....good news...the ACOP states that there should be reasoning to support any conclusions......something lacking from the guidance issued so far for the Fire Safety Order.

The ACOP has been there for years and in my opinion is an excellent guide as it clearly explains the meaning of suitable & sufficient and significant findings.

[PhilB]

Nah.
Plans have their limitations too. You can use them to indicate the locations of hazards and to illustrate the nature and extent of  risk control measures but they do nothing for evaluation of risk.

I totally agree Kurnal they do nothing for the evaluation but they do enable the general fire precautions to be adequately recorded.

Without a plan how else do you record, MOE, means for securing MOE, FFE, means for giving warning etc?

These are surely significant finding that should be recorded and the plan is the best way to record them...in my opinion.

[kurnal]

I use a (fairly long) tick box section of the report which sets out expectation statements and then a tick indicates compliance or if not fully compliant a statement as to why and what needs to be done if anything  ( all significant findings) , and if necessary summarised and  prioritised in the action plan

Heres an example of one of the items from the checklist

The external fire escape was protected by having all windows within the specified distance (horizontal distance 1.8 metres, vertical distance above 1.8 metres and vertical distance below 9 metres) fitted with fire resistant glazing to a half hour standard in frames fixed shut.

[PhilB]

I'm not suggesting for one iota of a second that your risk assessemnt is not suitable or sufficient but I can see how an enforcer...following Guidance Note No.1 may consider it so if there is no plan.

From the Order itself.....preventive & protective measures are measures that have been identified in a RA as the general fire precautions you need to take.

Therefore general fire precautions are significant findings.......and article 4 clearly defines what general fire precautions are...including MOE, FFE, AFD etc.....now if you can record all that without a plan ok...but often a plan is the only effective way.

[kurnal]

I think enforcers like plans because it makes it easy for them to enforce using traditional code hugging methods and it is only of benefit if everything is simple and correct.

You cannot tell from the plan that we have justified an increased travel distance due to ceiling height or utilised borrowed light in lieu of escpe lighting luminaires?  

That smoke detection has taken account of downstands or that fire doors are upgrades to the English Heritage standard?

Or that there is a risk of fire spread in undivided cavities in between floors

Or fire resisting partitions only extend to the false ceiling etc etc.

Thats why in the old days the plan was used to rubber stamp the fire certificate standard once the benchmark had been achieved and maintenance was the only concern. Before we got to that stage the plans were marked up in red and the key information was in the schedule of requirements (in text ).

I tend only to use plans in simpler buildings or if someone else draws it. In former certificated buildings I have even stopped using fire certificate plans in my risk assessments because  they are so often a work of fiction and confuse the issue.

Reading one of my tomes may be a pain for the enforcer but I hope all the info is there.

[nearlythere]

Does a plan not help to capture the layout of a building on the day the risk assessment is carried out. When a risk assessment is complete goodness knows what the owner/occupier would do the the layout. At least it would give you protection from liability if any layout changes compromised the means of escape for example.

[jokar]

The RP can use and do what they want to secure the FRA, plans prose, tick box, anything thing that assists.  The FRA is theirs and if plans help them to manage fire safety on a daily basis thats good for me.  However, if someone can point out to me how a plan defines the risk from the hazard that would be more than helpful.  A full audit of the premises in prose and then a calculation of the risk surely is a risk assessment and that can only be done in prose and with a matrix.

[PhilB]

The point is though Joker that the enforcers guidance note seems to suggest that risk assessments without plans may not be suitable and sufficient. I would tend to agree. Don't forget that this is guidance issued by the Secretary of State and enforcers must take note of it.


Having said that the latest animal farm guide apparently "has been approved by Ministers and has official status." and that shows horses in inner rooms, cows in bedrooms on upper floors and horses in dead end corridors........I give up do what you want the world has gone mad!!!!!

[jokar]

Perhaps the author has been to the FSC in the past with the "animals"

[kurnal]

The next argument will be what exactly constitutes a "complex" building.
Is it the expectation that if suitable plans do not exist (no mention of scale cf licensing act) the RP will have to draw them to meet the requirement of the fire safety order? The guidance clearly states not. So any plans will do???

On animals- all the cows were of the same ethnic mix.I would have expected a few brown cows, a few black and white ones as well as the white ones. Plus a footnote to point out the need to provide adequate ventilation to avoid a build up of explosive methane. Otherwise Phils canary may perish.

[William 29]

Can you tell me how you incorporate the drawing or CAD time into the fees for the FRA AND remain competitive?  It is not an issue if you have good up to date plans provided by the client but if not the cost and time implications can be more that the FRA itself.  I would like to include plans in all my FRA's but cost does not allow it.

I still feel you can do a suitable and sufficent FRA without plans and there is no required to do so under the RRFSO.  Phil, would an FRA ever be rejected by an efforcing authority solely the non production of plans.  Would a F and RS issue a notice as such?  Maybe ONLY if they could not understand the FRA without plans.

I also feel that if it were a requirement to have plans then some FSO's may return to the plan hugging days and we may as well produce fire certs again.  Just my opinions..........................

[Neil G]

It's not just the risk assessor and IO who need to view AND understand the risk assessment, but the RP and possibly maintenance guy, managers, etc who may not be as conversant with fire risk assessments; a quality plan with all necessary written words can be easier to understand than a full ream of text. If the risk assessment is only read and used by the author and IO it's of no value is it?

There were no cows in the bedrooms! They were in the udder rooms...