Fixed hosereels in an office environment

[Mike Buckley]

Ok lets take a different look at the situation. If extinguishers are provided the employees only have a limited ability to fight the fire once the extinguisher/s are empty they then have to leave to get more or evacuate the building. If the fire has not been extinguished after using one or two extinguishers then the best bet is to get out as the fire is getting away. If there is a hosereel the employee can continue to fight the fire ad infinitum and they will probably stay fighting the fire longer than is safe.

Logically by replacing the hosereel with extinguishers the safety of the employees will be enhanced as they will evacuate earlier.

As far as the law is concerned the guidance given in the is enough to show compliance. So provided the guidance is followed ie one extinguisher per 200 sq m etc. the responsible person has complied.

Take it to the extreme, there is a building that used to use a lot of flammable liquids therefore there are foam extinguishers all over the place, the firm changes direction and is now producing concrete paving slabs are we saying that the number of extinguishers cannot be reduced as this would reduce the firefighting capability even though the risk has changed?

Back to the risk assessment, is there a change in the risk because the hosereel has been replaced by extinguishers? If not and the firefigthing equipment still complies with the guide, then it can be done. If there is a change in the risk then further measures are needed.

[Tom Sutton]

It may well have been reasonably practicable to provide the hose reels 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 hose reel does not necessarily mean that it was appropriate or necessary to do so.

In my experience of "the bad old days!" the first thing we did was to classify the area as high, normal or low risk before we made any decisions. I do agree with part of the second paragraph, because we never required hose reels, portable water extinguishers was the first option. However if the owners, occupiers or architects wanted them we usually didn’t object.

On most occasions, and providing the solution was satisfactory we accepted the cheapest option, this is why we accepted made up doors as opposed to new fire doors. Also remember we were on a steep learning curve at the time.

[PhilB]

In my experience of "the bad old days!" the first thing we did was to classify the area as high, normal or low risk before we made any decisions.

 Also remember we were on a steep learning curve at the time.

Some did TW but some just threw the red, blue or lilac book at the place without really considering the risk.

I'm not having a pop at you ex inspectors but merely pointing out to Fishy that the fact that something has been provided does not necessarily mean that it was required.

[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.

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

On the contrary; I have many years experience of risk assessment in the Nuclear and Transport industries and have full 'Yellow Book' training in the latter.  I've discussed this precise issue directly and personally with very senior people both in the HSE and in Fire Authorities, all of which support the view outlined in the HSE Guidance.  The guidance in RR151 is similalarly based upon decades of risk assessment experience.  Yes, you use judgement - but the benchmark of acceptability is that you do not increase risk.  That is an absolute requirement.  The judgement lies in how you achieve that benchmark - either by compliance with published guidance, or by arguing equivalence using other risk reduction measures.

I am not saying that anyone needs to keep the hosereels; I am saying that you have to be able to argue that risk is not increased by their removal.  You might have to implement other risk reduction measures in order to do this.  You can like or dislike this view - frankly I care little - but if the worst comes to the worst I'd suggest that a highly paid man in a funny wig could pull you to pieces if the advice you gave to remove safety kit had increased risk in a building where fire fatalities occurred.

[kurnal]

I've discussed this precise issue directly and personally with very senior people both in the HSE and in Fire Authorities, all of which support the view outlined in the HSE Guidance.  The guidance in RR151 is similalarly based upon decades of risk assessment experience.  Yes, you use judgement - but the benchmark of acceptability is that you do not increase risk.  That is an absolute requirement.  The judgement lies in how you achieve that benchmark - either by compliance with published guidance, or by arguing equivalence using other risk reduction measures.

I am not saying that anyone needs to keep the hosereels; I am saying that you have to be able to argue that risk is not increased by their removal.  You might have to implement other risk reduction measures in order to do this.  You can like or dislike this view - frankly I care little - but if the worst comes to the worst I'd suggest that a highly paid man in a funny wig could pull you to pieces if the advice you gave to remove safety kit had increased risk in a building where fire fatalities occurred.

Thaks Fishy I understand where you are coming from but I still believe that fire safety is different to almost every other aspect of Health and Safety and so RR151 may confuse the issue.

In almost every other aspect of H&S the hazard is tangible and can be measured.

Sound levels can be measured, manual handling loads measured and assessed before exposing anyone to risk, levels of radiation and chemical exposures can be measured and compared against occupational health data. There are accepted safe benchmarks or safe levels and whilst we have a duty to eliminate, substitute or control risks that cannot be avoided  if we are working below the accepted benchmarks as expressed in ACOPs and othe guidance we wont go wrong.

In this way for example under the noise at work Regulations if I change the mountings on a machine for operational or cost saving reasons and after the change the operator experiences an increase in ambient noise levels from 48 to 53 dBA nobody is going to bother me because although I have gone against RRO151 guidance I am hugely below the 80dBA hazard level.

Fire is of course very different- the hazard of fire cannot be measured and there are no safe exposure levels. Hence the description of "The black art" and the  duty to minimise the risk of fire occurring and then to ensure that if a fire does occur people will not be harmed by it.  Instead of safe measurable limits all we have are guidance documents as a benchmark- but these achieve the same ends- through interpretation and application of the guides we arrive at a standard at which Society determines that the level of risk is tolerable. So long as I work around this standard no Judge will be able to criticise  me.  

I dont recollect any National Standards documents published in the last 30 years that have recommended hosereels as part of this benchmark standard. So I would feel easy about removing them and replacing them with more appropriate equipment and bellieve the outcome may well be much safer as a result for all the reasons expressed previously in this thread

However I do remain one of the few who feel that they remain the right solution of first aid firefighting in some environments. But not offices.
I was in an indoor market hall the other day that had hosereels and I thought them highly appropriate.

[PhilB]

On the contrary; I have many years experience of risk assessment in the Nuclear and Transport industries and have full 'Yellow Book' training in the latter.  I've discussed this precise issue directly and personally with very senior people both in the HSE and in Fire Authorities, all of which support the view outlined in the HSE Guidance.  The guidance in RR151 is similalarly based upon decades of risk assessment experience.  Yes, you use judgement - but the benchmark of acceptability is that you do not increase risk.  That is an absolute requirement.  The judgement lies in how you achieve that benchmark - either by compliance with published guidance, or by arguing equivalence using other risk reduction measures.

I am not saying that anyone needs to keep the hosereels; I am saying that you have to be able to argue that risk is not increased by their removal.  You might have to implement other risk reduction measures in order to do this.  You can like or dislike this view - frankly I care little - but if the worst comes to the worst I'd suggest that a highly paid man in a funny wig could pull you to pieces if the advice you gave to remove safety kit had increased risk in a building where fire fatalities occurred.

Have you any experience of fire risk assessment Fishy?

So prescriptive standards is the way forward is it? Regardless of the actual level of risk that remains, if any actions slightly increase the risk a person commits an offence? What if the measures were not required in the first place, but have been provided anyway?

Back to my previous hypothetical example then........ there are three exits provided in my building occupied by two people. I have risk assessed the situation and the occupants are perfectly safe with two exits and I therefore remove the third. According to your very senior chums in the HSE and the Fire Authorities I commit an offence?

Who are these senior people to whom you refer, perhaps I could offer them a training course.

[Mar62]

Keeping upto date with all this dialogue as I added to it earlier on in the "conversation". I am shortly to begin discussion with the local BCO regarding the removal of the hose reels from the premises I mentioned earlier, so I shall let you know the outcome when it happens! Thanks for all the advice given on this subject.

[Fishy]

On the contrary; I have many years experience of risk assessment in the Nuclear and Transport industries and have full 'Yellow Book' training in the latter.  I've discussed this precise issue directly and personally with very senior people both in the HSE and in Fire Authorities, all of which support the view outlined in the HSE Guidance.  The guidance in RR151 is similalarly based upon decades of risk assessment experience.  Yes, you use judgement - but the benchmark of acceptability is that you do not increase risk.  That is an absolute requirement.  The judgement lies in how you achieve that benchmark - either by compliance with published guidance, or by arguing equivalence using other risk reduction measures.

I am not saying that anyone needs to keep the hosereels; I am saying that you have to be able to argue that risk is not increased by their removal.  You might have to implement other risk reduction measures in order to do this.  You can like or dislike this view - frankly I care little - but if the worst comes to the worst I'd suggest that a highly paid man in a funny wig could pull you to pieces if the advice you gave to remove safety kit had increased risk in a building where fire fatalities occurred.

Have you any experience of fire risk assessment Fishy?

So prescriptive standards is the way forward is it? Regardless of the actual level of risk that remains, if any actions slightly increase the risk a person commits an offence? What if the measures were not required in the first place, but have been provided anyway?

Back to my previous hypothetical example then........ there are three exits provided in my building occupied by two people. I have risk assessed the situation and the occupants are perfectly safe with two exits and I therefore remove the third. According to your very senior chums in the HSE and the Fire Authorities I commit an offence?

Who are these senior people to whom you refer, perhaps I could offer them a training course.

I can only assume that your misinterpretation of what I said is deliberate.  I never advocated prescriptive standards (though they are usually risk-based and might be absolutely appropriate, in certain cases).  I advocate equivalence, however that is demonstrated.

You've (presumably) read the government guidance to which I refer.  You appear to disagree with it.  That is your prerogative. All of us have the opportunity to ignore good industry practice and if you're comfortable to do so, that's entirely the affair of yourself, your clients and their regulators.

To answer your question - I assess fire risk every working day of my life.  That assessment is regularly and robustly peer reviewed.  I have have discussed fire risk assessment and have had a hand in the development of associated governmental guidance; british standards and enforcement policy over the last decade or so.  I shall stop there; I don't come on this Board to present my CV on demand.

Lastly I would suggest that anyone who uses the description "perfectly safe" when ascribing levels of fire risk might benefit from some training.

[Chris Houston]

Gents,

Please remember this is a public forum.  There is no need to question each others skills or offer each other training etc.  Please try and keep it professional and diplomatic.

Thanks,

Chris.

[Clevelandfire]

Firstly I'd agree with sensible comments made by member Kurnal regarding a risk appropriate common sense approach to fire safety. PhilB is also correct. Fishy we need to establish if the hose reels were required in the first place. That not only represents a risk assessed view point but also a legal view point where I'd question if I could stand up in court and argue that I needed the hose reels in the first place and that their removal constiuted a failing or an offence. Then I'd question if the removal would warrant an equivalent provision of fire extinguishers. In theory you could never have an equivalent provision of fire extinguishers because hose reels would chuck out water till the resevoir ran dry and the user was burnt to a crisp.

I understand what you mean but to be a fully competent risk assessor you have to then also look at the other implications of the precautions being either removed or installed. Im not saying you arent competent I merely making an observation to others who may be reading this thread for their own benefit. Hose reels in my opinion are often more trouble than they are worth. They prop open fire doors when run out they can be responsible for legionella and they never run out of water leading the firefighting employee pouring water on a fire that continues to grow.

Health and Safety legislation and guidance must never be confused or cherry picked when required or carried over to deal with fire safety related issues in this manner. It makes things too confusing. The guidance for covered by the regulatory reform fire safety order stands, and a risk appropriate view point taken to establish overall best practice and sensible solutions prevail over guidance which has nothing to measure itself against.

[Chris Houston]

It wasn’t you who put that horse in the inner room was it?

What training course do you suggest I attend Fishy, always open to suggestions.

Yellow card.  You are welcome to debate, but we don't need the personal comments.

[Clevelandfire]

It wasn’t you who put that horse in the inner room was it?

What training course do you suggest I attend Fishy, always open to suggestions.

Yellow card.  You are welcome to debate, but we don't need the personal comments.

Harsh. Healthy banter I think, other people and perhaps myself included have been closer to the mark than that and not received warnings. i think he was just giving a bit healthy banter and trying to show he isn't taking himself too seriously and that things remained friendly .

[Chris Houston]

I'd rather avoid having to get into debates to explain my moderation decisions.  I have (unusually) taken the step of publicly requesting people to keep to the topic at hand.  The thing with discussion forums is that readers can't always tell when someone is joking and when someone is making a personal insult.  This forum can be read by anyone, so the onus is on the poster to appear respectful.  I would like to draw a line under this debate about the debate and for all posts after this to keep to the normal good spitited and helpful nature of FireNet.

[PhilB]

It wasn’t you who put that horse in the inner room was it?

What training course do you suggest I attend Fishy, always open to suggestions.

Yellow card.  You are welcome to debate, but we don't need the personal comments.

Bit harsh I feel Chris.

I did not question Fishy's competence yet he suggested I need training, however I took no offence as I believed none was really intended.

I asked if Fishy carried out fire risk assessments because , as Kurnal correctly points out they are a different animal to other risk assessments. Years of experience of risk assessment in the Nuclear and Transport industries and full 'Yellow Book' training in the latter does not necessarily confer competence in fire risk assessment.

Fishy chose to advertise his CV, I did not ask him to "come on this Board to present his CV on demand", however he chose to do so.

I have have discussed fire risk assessment and have had a hand in the development of associated governmental guidance; british standards and enforcement policy over the last decade or so.

We all have to start somewhere Fishy, only a decade, I’ve been doing it for a little longer.

I do believe, as do many others that the CLG guidance is poor and to be fair it was Fishy who advertised his involvement in its production, not me.

The horse comment however,  as Cleveland correctly identified was intended in jest as I'm sure most identified.

As you correctly point out, this is a public forum and many look here for advice including me, hence my reason for questioning Fishy's dubious interpretaion of HSE guidance and the relevance of it's application to the Fire Safety Order .

If my comments were deemed offensive I  apologise to Fishy, however I believed it was healthy debate.

I will post no more Chris so the red card will not be needed.

[kurnal]

Everybody is bowing out of this debate yet there is an important fundamental that is worthy of further discussion, Fishys interpretation

The logic is refutable; 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 would be interested in Fishys view of my interpretation which is that case study 24 will only apply if someone can demonstrate that the safety kit in question was relevant and appropriate in the first instance. If a previous manager fell victim to a persuasive fire extinguisher salesman and provided 20 extinguishers where two would suffice, and the new manager gets rid of 18 this is not reverse ALARP.  I believe that in most cases, where hosereels cannot be justified through risk assessment then it is appropriate to replace them with extinguishers in accordance with EN3 and BS5306.

Comments please?