Plans with a risk assessment.

[PhilB]

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.

Exactly my point TW stating MOE satisfacory is not recording what means of escape there is.....PAS79 can read like that if not completed with enough info......I have seen many assessments carried out using PAS79 that are far from suitable & sufficient.

Hence the reason Toddy didn't like it when I said plans would sometimes be necessary. By far the easiest way to record the general fire precautions in all but very simple premises is with a plan....it doesn't take that long and often plans are already available.

The ACOP to MHSW Regs explains that significant findings should include:
1) A record of the preventive & protective measures;
2) An action plan for remedial work
3) Proof that a suitable and suffcient assessment has been made.

A tcked box stating MOE is satisfactory is not a record of 1) and is not proof i.e. no reasoning to support the conclusion.

A simple template with a plan does record all the prescribed info.

[jasper]

bring back the plan drawings as with the old 1971 Act then?

[PhilB]

no Jasper, that clearly is not what I'm saying! If you can RECORD the info in some other way fine, but many assessments I have come across do not record the precribed info.

[jokar]

PhilB,  Whilst I understand where you are coming from and the Article quite claerly states that you have the record the prescribed information at some stage an assessment of the risks posed by the fire hazards has to be doen and that can not be doen on a plan.  part of a package maybe but it is not thwe whole thing.

[PhilB]

I never said it was the whole thing!! My simple point is how in a complex building do you record the prescribed info without a plan???

Some people are doing so without a plan, some are just ignoring the fact that the info needs recording because it would make life too complcated.

[jasper]

no Jasper, that clearly is not what I'm saying! If you can RECORD the info in some other way fine, but many assessments I have come across do not record the precribed info.

I was only having you on mate!

Personally I go down the descriptive route i.e. what risks etc are present and the existing control measures. However for large complex buildings (don't ask me how I define large and complex) I do go for plan drawings with salient information on them.

[Big A]

Phil, I agree absolutely.

[Tom Sutton]

Those opposed to the use of plans how do you record, in the larger complicated premises, the significant findings as defined by the ACOP to MHSW Regs especially items (1) and (3)? I cannot see how the pro-forma in PAS 79 achieves this also what are the reasons, is it cost or is there other reasons.

Jasper your submission accepted.

[wee brian]

Why would I use an ACOP to the MHSW regs to establish compliance with the FSO?

[PhilB]

Why would I use an ACOP to the MHSW regs to establish compliance with the FSO?

beacuse the Secretary of State told you to in Guidance Note No.1 Enforcement.

"32.Enforcing authorities should note that the requirement for suitability and suffi ciency
is one and the same requirement as that in health and safety law. Detailed advice has
been produced by the Health and Safety Commission as part of the Approved Code of
Practice and Guidance to accompany the Management of Health and Safety at Work
Regulations 1999 (ISBN 0-7176-2488-9). That guidance is equally applicable to the
suitability and sufficiency of risk assessments under the Order."

[Davo]

PhilB/Wee Brian

Ignoring the guidance only angle, answer me this please.
Joe Public RP buys the Guidance relevant to his establishment, how on earth would he know about the new Guidance Notes? Without you chaps and of course Aunty Lin/Val on FNF to educate/entertain me I would not have known about the shifting of the goalposts on S & S and its the main part of my job.
Surely this should have come out as an Amendment to the Order? It is after all a very crucial point
Does this mean a Mk3 for colin to write?

[PhilB]

PhilB/Wee Brian

Ignoring the guidance only angle, answer me this please.
Joe Public RP buys the Guidance relevant to his establishment, how on earth would he know about the new Guidance Notes? Without you chaps and of course Aunty Lin/Val on FNF to educate/entertain me I would not have known about the shifting of the goalposts on S & S and its the main part of my job.
Surely this should have come out as an Amendment to the Order? It is after all a very crucial point
Does this mean a Mk3 for colin to write?

Davo

I raised this point many moons ago when the Guides were being written. The ACOP to the MHSW Regs was there and explained what suitable & sufficient meant and what significant findings should include.

I thought it a tad daft that the new guides didn't use the same definitions. They did not listen at first but then they agreed to amend the guides and the definition of significant findings(one of the reasons for the delay in publishing them). But they still chose to use terms slightly different to the ACOP.

The biggest difference in my opinion was the lack of a need to show proof that a suitable & sufficient assessment had been made i.e. reasoning to support your conclusions.

Many consultants were quite happy because it meant they could use tick box templates and that would comply with the guide.

If you look in the guides at the further reading section it does refer you to the ACOP, but most people wouldn't spot that link quite understandably.

There is no need to amend the Order, nothing has changed!! There has always been a statutory requirement to record the prescribed info......only now are they explaining what constitutes a suitable & sufficient way of recording that info.

[jokar]

Unfortunately only the enforcers will look at, hopefully, the Enforcers guide.  The Rp will pick up the copy they want and just do their thing.  An addendum to the guides for the RP would be good just so that all are aware of the change in stance.

[slubberdegullion]

What about photographs?

What could be better for recording and for identification?

Stu

[kurnal]

One of my clients has just been served an enforcement notice by a fire authority in the West Midlands. (No names no pack drill!!)
The notice is an absolute disgrace. And then some of you have the audacity to ask for plans to make the risk assessment clearer and easier to understand!

The notice is dated 5 November and the follow up inspection to check the work has been completed will be on or after the 20 November. Any problem with that do you think?

Heres the worst bit. Direct quote from the notice.

Action required

The Responsible Person must take such fire precaution measures in the premises, (as defined in Article 4, paragraph (1) (a) to (f) of the Order) as will ensure the safety of employees. With regard to the deficiencies identified in particular, take, From Article 4(1):-(a) measures to reduce the risk of fire on the premises and the risk of the spread  of fire on the premises (b) measures in relation to the means of escape from the premises (c) measures for securing that, at all material times, the means of escape can be safely and effectively used
(Part 2, of the relevant HM Government Fire Safety Risk Assessment Guidance Booklet refers)

So thats fine then isnt it. Clearly sets out what is to be done.