Plans with a risk assessment.

[nearlythere]

Right, we'll have neigh mare jokes about horses in bedrooms etc. How long will it be before we receive a complaint from goats who have been discriminated against in repect of MOE?
Are they not entitled to the same basis animal rights when they stay in a hotel or guesthouse?
How could the authors of the guide forget to include themselves?

[PhilB]

I still feel you can do a suitable and sufficent FRA without plans and there is no required to do so under the RRFSO.

There is however a requirement to record the prescribed information = significant findings = preventive & protective measures = general fire precautions. i.e. MOE, means for securing MOE, FFE. fire alarm etc etc.

Now if you can record that without a plan fine....if you cant, in my opinion a plan should be provided. That is why I have never been a fan of PAS79.

Would IOs serve a notice if there were no plans....in truth most people out there wouldn't know a suitable & sufficient FRA if it kicked them up the backside......

Hopefully though, now that the ACOP to MHSW Regs is referred to in the enforcers guidance notes...that may change.

Anyway....A Horse, a duck and a cow walk into this hotel and the barman says........sorry being silly again!!!

[nearlythere]

Anyway....A Horse, a duck and a cow walk into this hotel and the barman says
" What will it be boys?"
The horse, a white one, says "We'll have whisky".
The barman asks what type of whisky.
The white horse replies "What do you have?.
The barman says "We have Bells, Stewarts, Jamesons and we even have one named after you"
The horse says "What, you mean to say you have a whisky called Eric?

[Mr. P]

Article 9 para 62 from the RRO(FS) order guidance note 1-

'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. Similar considerations will apply in respect of article 11(1) and other articles which require information or arrangements to be recorded. Enforcing authorities should seek practical solutions with the responsible person where such plans are not adequate.'

[jokar]

Hold on, that says building.  There is no definition of a building in the RR(FS)O they are all premises, so what happens next?  And as  stated above what does complex mean?

[William 29]

Good points jokar, also the clue is in the title "guidance note" for use by FSO's when auditing in my understanding.  How is the responsible person expected to know that an interpretation of the Order COULD mean the production of plans when producing their FRA?

[PhilB]

How is the responsible person expected to know that an interpretation of the Order COULD mean the production of plans when producing their FRA?

Because they should either be competent themselves or if not appoint someone who is competent to assist them.

A competent person should be able to read the Order and understand what needs to be recorded i.e. the precribed information.

If you can record the prescribed info without a plan ok...but as the guidance note correctly points out...sometimes a plan will be required.

Unfortunately some people don't appear to undertsand what needs to be recorded.

[William 29]

Thanks for the comments Phil, but no one has still addressed my point regarding the cost of producing plans and as stated previously I would prefer to include them but cost and time on site does not allow it, unless the client is prepared to pay for the additional service.  

I know an argument could be that hand drawn plans would be suitable but when you are producing professional looking FRA's (in both content format) I am reluctant to include sub standard plans.

[kurnal]

Agreed. And in practical terms I was asked in May to carry out a risk assessment in a large factory. As I pointed out they had made unauthorised and dodgy alterations without building regs approval and this needed to be addressed. they appointed an architect to prepare plans for the risk assessment and to support a retrospective building regs application. Its now nearly 6 months later and the plans are still not finalised so the risk assessment has not yet been completed. It becomes another expensive and delaying obstacle to progress. Still I guess soon a year will have passed and the BCO will then  have lost any control.

[PhilB]

I know its a problem Kurnal but you mentioned on another post that you wouldn't wear slippers because your fireboots were too tight...well something like that.

The fact that plans may cost money or take time is not really relevant....if they are needed they should be provided.

Having said that I don't see why the plans have to be to scale or drawn by an architect........as long as they record the general fire precautions.

Please, please note I am not saying that plans are alaways necessary...but if they are provide them...and the client will have to pay.

...and yes I know the client may go to a cheaper consultant who provided a tick box, or a checklist...without a plan that is supposed to record the necessary info.

The answer to that is competent auditors and effective enforcement ....a problem I know.

[PhilB]

Hold on, that says building.  There is no definition of a building in the RR(FS)O they are all premises, so what happens next?

Don't see your point there Jokar. Under the 71 Act we used to "require" plans of buildings yet building was not defined.

The meaning of the word building shouldn't be too difficult to fathom out by even the most incompetent assessor!

[val]

It is always good to be in agreement with PhilB. Leaving aside the RP, competent assessor and cost, the trick is to educate enforcers when a plan may be reasonably required and not give them carte blanche to ask for plans in every single storey industrial unit.

Perhaps I do not get out enough but I would think that many premises/buildings already have some form of plans.

I believe that the term 'complex' was deliberately chosen because of its potential for wide interpretation. At both ends of the complexity spectrum it should be obvious. What happens in the middle is what keeps us all coming back to this site.

[Tom Sutton]

Fire precautions Act 1971 - Circ. No.5

DEFINITION OF "BUILDING"

The definition of "building" has been interpreted variously but the courts for purposes of other legislation
and is therefore subject to some uncertainty. However, to ensure uniformity in the administration of the
Act, it is considered desirable that a building should generally be regarded as extending from its lowest
level to roof-top and that the horizontal limits should be regarded as set by party/separating walls
through which there is no internal communication with neighbouring buildings. Doors provided in party
walls solely as fire exits should not be regarded as a means of internal communication. Nor is it
considered that the effect of imperforate floors extending over the whole area of a building is to create
two (or more) separate buildings, notwithstanding that there may be no internal means of communication
between the parts.

[jokar]

Hey, that's not one of the circulars that was removed from use when the brave new world appeared is it?  

Simple really buildings can be built, altered or extended. FRA are on premises and perhaps the 2 will never meet.

[johno67]

A couple of questions:

Where in the Fire Safety Order does it state that a fire risk assessment has to be recorded?
Article 9(6) states that the prescribed information must be recorded, that information being
9(7) The significant findings; and
persons especially at risk.

Is Article 27 (Powers of Inspectors) not clear on the issue of plans?
27(c) "to require the production of, or where the information is recorded in computerised form, the furnishing of extracts from, any records (including plans)-
(ii) which it is necessary for him to see for the purposes of an examination or inspection under this article,
and to take copies of, or of any entry in, the records"

I agree that plans will in no way show the level of risk in the building, that will be done through your FRA, but as an enforcing officer I will need to make a judgement regarding the suitability of your General Fire Precautions in relation to the level of risk within your premises, and in all but the simplest premises a plan would greatly assist me in doing that.

If there is no plan in place, it will undoubtedly take me longer to look at the General Fire Precautions, especially when the person dealing with me isn't the, or a, person appointed to provide safety assistance (as is normally the case). 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.

I can't remember where I got it from (may have been the original training session covering the Fire Safety Order in Lancs or GMC Brigades) but I understood it to be the case that if the enforcing authority required plans then they would pay for them (although I might have imagined that bit).

Many apologies if my observations are wrong, feel free to tear my contribution to shreds.