Fixed hosereels in an office environment

[devon4ever]

I think Kurnel hits the nail on the head, a reluctance of LAFRS to think beyond the box or contradict dated certification and risk assess  to "engineer-out" a problem. Competent FRA's in these modern times means just that, see whats on the market, embrace new thinking and dare I say - be brave enough to make a (competent) assessmet of what is required. We are all sometimes wary of change, but where it is for the better; or lends itself to a more easily managed environment it should be embraced and taken onboard.

I once worked within a brigade where the CFO muted a radical idea of not shutting doors in private dwellings in order for a quicker response to the smoke alarm fitted in the stairwell should a fire occur in the living room, (it was also documented in Fire magazine circa 1998-ish - I did not share or endorse his view, but it promoted rational debate - it may still do at this later stage),  - on reflection, it goes against the grain only in so much as we need the conviction and pioneer instinct to evaluate new thinking from someone who just may come up with an idea that was there for the grasping - and the rest of us were brain-washed into "miopic vision"

[nearlythere]

Nearlythere. I believe they are demanding they remain in place due to the length of the building?

One has to now ask them if it is a "requirement" for them to remain.

[AnthonyB]

Nearlythere. I believe they are demanding they remain in place due to the length of the building?

Hardly as with extinguisher provision you have a travel distance requirement as well as floor area - if you are having to travel more than 30 metres to reach an extinguisher point you must place another extinguisher point nearer.

Hose reels only have a maximum reach of 30m (to the current EN - older reels could have up to 45m of hose) so in a long building you would need another main and reel anyway.

It's building height (30m or 25m if over 930 sq m) as well as area that is a key factor under London Building Acts to quote the District Surveyors:

"Section 20 of the London Building Acts (amendment) Act 1939 (as amended primarily by the Building (Inner London) Regulations 1985) is principally concerned with the danger arising from fire within certain classes of buildings which by reason of height, cubical extent and/or use necessitate special consideration.

...

As buildings vary so much in height, cubic capacity, layout, siting, use and construction the relevant Council will deal with each case on its merits. Basically the principles incorporated in this Guide seek to provide not only such fire-fighting facilities as would enable the fire brigade to tackle the seat of a fire with the utmost speed, but also to provide early warning of fire, contain an outbreak of fire and to prevent its rapid spread throughout a building prior to the arrival of the fire brigade.
Additionally the principles seek, in certain buildings (or parts of buildings) to ensure the safety of the structure against fire."

Incidentally hoses are only a 'should' under section 20 and the BCO can waive it under S144 (they have in some parts of central London). If you can argue the case to the BCO and justify it you should be fine as according to the District Surveyors guide it's nothing directly to do with LFB (consultation only, but the BCO has the final say) and they are stuck with the RRO which doesn't mandate reels.

Considering you already have a life safety sprinkler system under section 20, hose reels as well as extinguishers is a bit overkill and with a good FRA I'd call their bluff, I'd love to see their detailed reasoning other than 'the Act says so'. Try & get hold of course materials & guidance documents that their training section use on commercial fire safety courses - I bet the shy away from using reels - & hang them with their own literature.

It's worth persisting as it has been done - I'll try & find the name of the building that got to remove them, but it was a couple of years ago so may take a bit of digging!

[jokar]

The LDSA has an agreement with the LFB that it is ok to remove hose reels in premises.

[Mar62]

Thanks ever so much for all your advice. I'm glad I joined this forum! I forgot to mention before. They also have 5 dry risers and a lot of it is sprinklered as well as providing ext's in common areas and the tenants providing their own in the offices. I carried out the FRA late last year but have now taken over the account - I would just like to get rid of the hose reels and save him a fortune in maintenence costs!!! Thanks Anthony for your advice. I'm on hol this weekend now for three weeks (USA) so I shall start looking into this properly when in get back. Thanks all.

[Psuedonym]

Each Hose Reel has to be pressure tested and the hose also has to be pressure tested. However as the hydraulic pressure testing in situ for a hose is not a practical option, the hose length is therefore advised to be replaced - inducing additional cost: parts / labour. Pressure testing of the reel is simply a water pressure test under BS stipulations and can be carried out as part of the annual maintenance - Check BS EN671-1.
To use a piece of fire fighting kit an employee has to be trained in its use as is agreed on all these pages and as per legislative guidlines: How many are trained in the use of hose reels (water)? - None.
The fire rating equivalent for hose reels is 52A. The equivalent no. of water Exts. is 4 x 13A or 2 x 26A 9Lt Water exts.
The majority of hosereels are fitted on fire exit routes, at a fire door or at the top of a staircase: Excellent forward planning - lets block a fire exit with a swinging reel, it's cabinet and of course the 30M length of hose.
Fixed reels are not as versitile as swinging types, do staff know the difference between auto / manual types, gate valve water release use and control, jet/spray nozzles and their use on a fire?
Finally, if the hose needs to be fed through a door/s, someone needs to hold the door/s open - putting more staff at risk - mind you they could'nt have passed through the fire exit anyway due to the pile up of bodies who have tripped over the trailing hose.
In the majority of cases a large percentage of reels fail the maintenance or pressure test due to the previous co's lack of correct servicing (They can be awkward to service during a businesses working environment, so they simply get signed off as passed (imagine that reel being used on a fire) or hose or reel damage.
Oh nearly forgot... gallons (quite literally folks) of water, falling all over countless electrical outlets and appliances causing another minor issue.

To conclude then: No training, blocked escape routes, equivalent ext already in situ (staff are trained in their use), electrical / water hazard, etc etc etc.

Now then..reels or exts? You decide.

Having serviced thousands of these and discussed with the client what policy on their use is, the best conclusion is to remove them and use the recess as a fire point. As long as the fire fighting rating is not affected i.e. an equivalent portable class A is in the same situ, removal is not ussually a problem. The majority were installed in a bygone age of less H&S awareness and companies must be brought up to speed so as to allow today's H&S manager to make an informed decision.

I'm moving on from portables and reels so there's no hidden agenda here.

[Fishy]

You cannot legitimately remove fire safety kit unless:

- You can prove that is has zero risk reduction benefit or;
- You replace it with other equipment (or other risk reduction measures) that allows the same level of risk to be maintained.

This is because, in providing the kit, you have demonstrated that it is reasonably practicable to do so. Therefore, if its removal increases risk (even ever so slightly) then risks are no longer ALARP and you're in breach of the law.  The HSE report RR151 (www.hse.gov.uk/research/rrpdf/rr151.pdf) explains this in more detail.  It take a particularly dim view of using savings in maintenance costs as justification for removing existing safety measures.

So... it would appear that it would only be OK to remove them if you provided enough portable fire extinguishers to maintain the fire risk at the same level as it was before they were removed, or if you made other improvements to maintain risk at the same level or lower.

Thanks ever so much for all your advice. I'm glad I joined this forum! I forgot to mention before. They also have 5 dry risers and a lot of it is sprinklered as well as providing ext's in common areas and the tenants providing their own in the offices. I carried out the FRA late last year but have now taken over the account - I would just like to get rid of the hose reels and save him a fortune in maintenence costs!!! Thanks Anthony for your advice. I'm on hol this weekend now for three weeks (USA) so I shall start looking into this properly when in get back. Thanks all.

[messy]

I do not think that HRs need to be replaced by the equivialent number of portable devices.

The FFE provision needs to reflect the actual risk (determined by the FRA) and if HRs were 'over provision', then in my view there's no need for a 1 to 1 replacement with extinguishers

Surely, it's the RR(FS)O 2005 which is the primary legislation and not this HSE document which states:

.......... The report sets out examples of good practice in relation to risk assessment, ......................................... Its
contents, including any opinions and/or conclusions expressed, are those of the authors alone and do
not necessarily reflect HSE policy.

[Fishy]

There's no conflict - of course the RR(FS)O takes precedence, but RR151 is relevant good industry practice and accurately reflects the apprach that HSE takes with regards to enforcement of risk-based legislation.  Therefore, when you are performing risk assessments I'd suggest one should either follow it or be ready to demonstrate how an equivalent level of safety is achieved by other means.

The 'pitfalls' described in RR151 document apply to fire risk assessment every bit as much as they do to other risks.  The logic is irrefutable; in providing the safety kit, you have demonstrated that it is reasonably practicable to do so. Therefore, if its removal increases risk (even ever so slightly) then risks are no longer As Low As Reasonably Practicable (ALARP) and you're in breach of the law unless you reduce the risk in other ways, using other risk control measures.  Case Study 24 ('Reverse ALARP') of RR151 is relevant here.

I do not think that HRs need to be replaced by the equivialent number of portable devices.

The FFE provision needs to reflect the actual risk (determined by the FRA) and if HRs were 'over provision', then in my view there's no need for a 1 to 1 replacement with extinguishers

Surely, it's the RR(FS)O 2005 which is the primary legislation and not this HSE document which states:

.......... The report sets out examples of good practice in relation to risk assessment, ......................................... Its
contents, including any opinions and/or conclusions expressed, are those of the authors alone and do
not necessarily reflect HSE policy.

[PhilB]

The logic is irrefutable; in providing the safety kit, you have demonstrated that it is reasonably practicable to do so. Therefore, if its removal increases risk (even ever so slightly) then risks are no longer As Low As Reasonably Practicable (ALARP) and you're in breach of the law unless you reduce the risk in other ways, using other risk control measures.  Case Study 24 ('Reverse ALARP') of RR151 is relevant here.

It may well have been reasonably practicable to provide the hosereels but that does not mean that they were necessary in the first place. Don't forget that many existing provisions were introduced in the bad old prescriptive regime where level of risk was not always taken into account.

Therefore the fact that it was reasonably practicable to provide a hosereel does not necessarily mean that it was appropriate or necessary to do so.

To take it one step further I have three exits but all occupants can escape safely through two, for security reasons I take an exit away, am I now breaking the law?

[Fishy]

If it was reasonably practicable to provide the hose reels, that does demonstrate that they were necessary.

To take it one step further I have three exits but all occupants can escape safely through two, for security reasons I take an exit away, am I now breaking the law?

Yes, if the third exit was originally intended as a risk control measure and you cannot demonstrate that there is no increase in risk after its removal.

[PhilB]

If it was reasonably practicable to provide the hose reels, that does demonstrate that they were necessary.

To take it one step further I have three exits but all occupants can escape safely through two, for security reasons I take an exit away, am I now breaking the law?

Yes, if the third exit was originally intended as a risk control measure and you cannot demonstrate that there is no increase in risk after its removal.

mmmmmm you haven't really got the hang of this risk appropriate concept have you Fishy.

The fact that it was reasonably practicable to provide the HRs in no way demonstrates their necessity, it could have been a jackbooted incompetent  dinosaur who recommended them in the first place, like wise with my three exits when only two are required

[Davo]

Fishy

You are allowed to use your judgement on this!
If the risk rating goes up a couple of percent, so what? You follow Psue's logic and argue the increase in risk in spraying gallons of water about.
Assuming the HSE find out about it and actually turned up, they will look at all your activities and risks before deciding if you are a good employer or a pillock.
If the risk increases from say low to medium then obviously you have not got it right.
Don't be too precious,  otherwise Sir N will call you a taliban!

ps most hose reels were fitted before 1974 anyway so ALARP doesn't count. Replacing the hoses was a blob cos thats what you did.

davo

[kurnal]

If it was reasonably practicable to provide the hose reels, that does demonstrate that they were necessary.

To take it one step further I have three exits but all occupants can escape safely through two, for security reasons I take an exit away, am I now breaking the law?

Yes, if the third exit was originally intended as a risk control measure and you cannot demonstrate that there is no increase in risk after its removal.

I am starting to lose the plot. Why should the risk assessment I carry out to justify the adequacy of two fire exits be any less relevant than a previous risk assessment that recommended three?

So long as Phil carries out a suitable and sufficient assessment of risk he can make any changes he wishes. Historic standards are irrelevant.

[Martin]

ALARP is not quite the same same as " will ensure so far as is reasonably practicable the safety of employees".  If after removing the hose reels you can demonstrate employees are protected from risk of fire all is well. Hose reels may be useful for property protection but I would be iffy about an office environment which needed fire hose reels to protect employee safety. If the fire is big enough to justify a hose reel it's too big for first aid fire fighting.