Plans with a risk assessment.

[PhilB]

You are correct John FSO only requires the prescribed information to be recorded which includes the significant findings.

Now look at the definition of preventive & protective measures......these are the measures that have been identified in a risk assessment as the 'General Fire Precautions' you need to take....with me so far???.......

Now from that surely you must agree that general fire precautions must be significant findings and therefore they should be recorded.

Have a look at what general fire precautions include...article 4...and then you will see why I say that sometimes it is best to use a plan.

On the question of recording the assessment itself the Approved Code of Practice to the MHSW Regs 1999 says ..."in many cases, employers will also need to record sufficient detail of the assessment itself, so that they can demonstrate that they have carried out a suitable & sufficient assessment."

On your final point of the fire authority paying for plans if they require them...don't know where you got that from but the point is the fire authority are not requiring plans.......it is the complexity of the building that makes plans necessary if the assessment is to be suitable and sufficient.

[johno67]

I absolutely agree with you Phil. The Fire Risk Assessment Guides give a clear definition of what the significant findings should include (Page 31 of the Offices and Shops Guide).

My thinking is, that unless there is a plan to refer to, (the Guide states "It can be helpful to include a simple line drawing to illustrate your fire precautions. This can also help you check your precautions as part of your ongoing review" (Page 31 again) then the Responsible Person would need to produce something akin to the old Means of Escape Schedule that used to be produced under the Factories Act.

Good reference to the Management Regs ACOP, I hadn't picked that one up (one for me to store away)

As I said in my previous posting, I may have dreamt the bit about the enforcing authority paying for the plans, or it could have been a Principal Officer trying to placate my tirade of annoying questions.

So not much objection to your comments from me.

[kurnal]

Good answer Phil.

This will mean that my audit will take longer, and therefore I will carry out less audits over a period of time, and will therefore have less effect on driving down the risk of fire in the community that I serve.

This is a tetchy point and I recognise that your audit covers more than compliance, but your role in this respect is surely to enforce the order- to make sure that the RP is driving down the risk, yours is a policing role in fact? This may have an indirect effect on driving down risk just like the threat of punishment can deter some of us from committing offences.  (whereas the rest of us just dont fancy sheep).

[johno67]

This is a tetchy point and I recognise that your audit covers more than compliance, but your role in this respect is surely to enforce the order- to make sure that the RP is driving down the risk, yours is a policing role in fact? This may have an indirect effect on driving down risk just like the threat of punishment can deter some of us from committing offences.  (whereas the rest of us just dont fancy sheep).

Absolutely right kurnal,

I am there to enforce the requirements of the Fire Safety Order on behalf of the enforcing authority, in my case the Fire Authority.

As we generate our audits from:
A risk based inspection programne (RBIP) which ensures that we target the highest potential risk (high life risks etc);
Complaints (e.g. someone phones to complain about blocked fire exits);
After a fire (a failure will have occurred somewhere for a fire to start); and
As a sampling measure (to look at certain groups of premises that may have grabbed our attention for some reason)
this ensures that we are driving down risk and targetting the highest potential risks at the same time.

I approach every audit looking to ensure that the requirements of the Fire Safety Order are being complied with. If the premises I am looking at are complying, I will say 'well done, keep up the good work', plus it gives me an opportunity to offer best practice advice if they require or want it.

If they aren't complying, then I have the full range of enforcement powers at my disposal, including prosecution in the worst cases.

I think that ultimately it is everybodys interest that we all work together to drive down the risk from fire and its often devistating effects.

[val]

Kurnal

Matlock? Sheep?

[kurnal]

Baaa humbug. Its all lies.  Anyway you cant get wellies with wide enough legs anymore.

[Tom Sutton]

Let me raise an old issue.

Check out one of the old threads at http://www.fire.org.uk/punbb/upload/viewtopic.php?id=664 if you would like to hear some pearls of wisdom from Toddy on this subject and I am sure you will not like this one Phil

[PhilB]

Like it??? I love it...a blast from the past.

That was the debate where Toddy and his pals were telling me that plans were not necessary and the ACOP to the MHSW Regs was not relevant when dealing with fire risk assessments.

Now thanks to Guidance Note No.1 they have been proved wrong on both counts!!!

Seriously though I am pleased that the ACOP is now referred to in the Guidance note. Anyone involved in carrying out or auditing fire risk assessments should read this document as it clearly explains the meaning of suitable & sufficient and signifcant findings.

[jasper]

Now thanks to Guidance Note No.1 they have been proved wrong on both counts!!!

It is only a ''Guidance Note'' nothing more, just guidance for the ill informed  

[William 29]

I made this point earlier in the debate.  To sum up in the overall scheme of things when IO's are doing their best just to get PR's to do any sort of FRA is the fact that they contain plans or not going to affect their judgement as to if it is suitable and sufficent.  I do take Phil B's line on the recording of the significant findings POSSIBLY not being able to be recorded without a plan but still feel it unlikely that an IO or a senior officer would reject a FRA soley on the basis of no plans.

And I still go back to the cost element to the RP's



Purpose

3. The purpose of this guidance document is to provide enforcing authorities with advice
about enforcement of the duties contained within the Order. It should be consulted
together with the Order itself, not instead of it. The guidance is founded upon
current knowledge and legal advice. It must however be accepted that any defi nitive
interpretation of the Order will be made by the courts.

FSO Guidance Note No 1 (Page 6)

[PhilB]

Now thanks to Guidance Note No.1 they have been proved wrong on both counts!!!

It is only a ''Guidance Note'' nothing more, just guidance for the ill informed  

Yes but this guidance has been issued by the secretary of state no less......

...and.......to quote the Statute.....26.(2) In performing the duty imposed by paragraph (1), the enforcing authority must have regard to such guidance as the Secretary of State may give it.

....and you know how IOs love to guide hug!!!!!

Let's hope that the guidance is treated as guidance....some times a plan will be necessary....many times it will not.........let common sense prevail.

But I do sense that some of you consultants out there may becoming twitchy because your chosen method doesn't include plans............I bet old Toddddy is shaking in his fur lined slippers as we debate this one.

[Tom Sutton]

Where can I get hold of FSO Guidance Note No 1?

[PhilB]

Where can I get hold of FSO Guidance Note No 1?

http://www.communities.gov.uk/documents/fire/pdf/guidance1enforcement2005

See paragraphs 32 & 62

[Tom Sutton]

Thanks Phil I found 1 and 2 after I post my question. I haven't found time to read it yet but I will shortly.

[Tom Sutton]

I have never done a fire risk assessment or likely too but I am trying to understand the procedures for my own benefit. One area confuses me is the recording of information.

Let’s take Means of Escape, an assessor conducts a FRA and finds the MOE satisfactory, does he record it simply as MOE - satisfactory or if he finds deficiencies, highlights them, prioritises them and how they can be rectified, this is what PAS 79 appears to recommend.

This would mean a third party (RP) reading the report would not know what the MOE scheme was, he would only know it was satisfactory at the time of the assessment. Furthermore he would not know which doors need to be available, which doors need to be FR, which areas need to be covered with AFD or emergency lighting, etc. So how does he maintain the MOE standard to a satisfactory level?

If the assessor choose the PAS 79 recommendations then I would imagine plans are not necessary in most cases. If he decides to extend his report to providing a MOE schedule then a written schedule and plans would be required for the larger and more complex premises.