Fixed hosereels in an office environment

[Clevelandfire]

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?

I agree with all you have said

[jokar]

Risk assessment is about assessng the risks of fire hazards and controlling those residual risks with the apporpriate preventive and protective measures.  Those measures should be at ALARP and in which case anything that is an over provision could be removed if the assessment deems it acceptable.

[johno67]

I agree with your interpretation kurnal.

If you went exactly by the wording then it would be classed as Reverse ALARP (your reference to the difference with fire noted). However, if that was the interpretation you could also possibly make the case that ALARP will change each year for a business. The business makes a profit each year, the manager should put away a small amount of that profit to lower the risk, by for example buying an extra extinguisher anually etc.

Not a practical approach.

[Psuedonym]

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?

I agree with all you have said

Yup, also agreed. Assess the risk and react accordingly.

[Martin]

From a legal point of view I think the distinction btween achieving ALARP and ensuring as far as as reasonably practicable the safety of employees relevant persons etc. has ben missed in this thread.

If memory serves right there is a requirement in some of the radiation legn. (excuse my rusty memory) not to exceed certain maximum exposures  and also to also to reduce expoure as low as reasonably practicable.  This is not linked to any concept of risk. If it is reasonably practicable to reduce to reduce the exposure you must do so regardles of any reduction/control of risk.

In the Reform Order any action taken is qualified by ensuring safety. If our risk assessment says fire fighting is needed and Fire Extinguishers are adequate for such First Aid fire fighting I consider this meets any fire fighting part of the requirement to provide general fire precautions to protect safety.

It is a defence to show it what was not reasonably practicable to do more than what was done. My argument would be that the appropriate level of fire fighting equipment to protect life was in place. There has been much discussion on this  forum about training in use of fire fighting equipment. For use of a hose I would insist on training not in how to turn the water on but safe position, ensuring safe retreat, when to stop fire fighting and evacuate. Unless I had a significant
 fire risk which might require such "heavy duty" first aid fire fighting to ensure a safe evacuation then I do not consider it is reasonably practicable requirement to provide hose reels for safety. The mere fact something can be done or has been done does not in itself mean that it was reasonably practicable.

I agree the question of reasonable practicability is a moving target. It is reasonably practicable in our new school build programme to put full L1 afd in. It is not reasonably practicable to retrofit L1 in all existing schools immediately. However it is reasonably practicable to put this into our asset management plan and as schools have significant works done to include afd. In 5/10 years time as this programme nears it's conclusion who knows what sophisticated devices will be reasonably practicable and make the kit we are installing today look inadequate.

[Fishy]

Blimey - you have a long weekend in the sunny Peak District, away from a PC and look what happens…

Absolutely – as I’ve said all along, provided that you can demonstrate that fire risk is not increased by works (in this case the removal of the hoses and replacement with alternative engineering), it ain’t reverse ‘ALARP’ and it’s fine.  Providing more extinguishers might be an appropriate method of doing this (it’s an additional risk reduction measure, as I’ve referred to all along).  You don’t have to be able to argue that you’re duplicating all the functionality of a hose reel, so long as you can justify equivalence, in risk terms.

Re: the 20/2 extinguishers; if somebody's made 900% over-provision I'm sure that you could argue that, beyond a certain number of extinguishers, you're effectively providing zero risk reduction benefit, so you could reduce the provision down to that number.

At the end of the day, the core principle is that if you make changes to the fire protection provisions in any premises, you must always be able to argue that fire risk is not increased due to those changes.

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?

[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.

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

Good to see that you’ve now changed your argument Fishy.

It seems from your last post that you agree that if there is an over provision you can reduce the measures provided. That was my point, the fact that something is reasonably practicable to provide does not mean that it was required in the first place.

My example of 3 exits from a building when only two are required could be extended to one hundred exits when only two are required. By reducing the exits from 100 to 2 clearly increases the risk, but if the risk is such that people are still perfectly safe (from a fire) the reduction would be justified.

….and finally without further training Fishy I am happy to describe a room with two exits as perfectly safe from fire risk if the room is for example 5m by 5m occupied by two people and with minimal fire load. They may not be perfectly safe from nuclear reactions, wild animals or over zealous forum administrators, but they are perfectly safe from the risk of fire, in my opinion of course.

I promised not to post any more and will not do so from now on, but the point had to be made. I only posted this because Chris chose to ignore an e-mail that I sent to him regarding his last post on this topic.

You or Chris may apologise any time you like.

[kurnal]

Blimey - you have a long weekend in the sunny Peak District, away from a PC and look what happens…

next time you're up this way again look us up and we could have a beer.

Same applies to Phil B but perhaps not at the same time

[Chris Houston]

over zealous forum administrators

Ouch,

I had considered my moderation of this site to be very hands off.  I've never once banned a member (only spammers and trolls).

You or Chris may apologise any time you like.

I did ask both debaters to stay away from the personal comments and you invited him to continue with the "who needs training" and started the "was it you who did the animals guide thing".  So, I felt a further warning was necessary.

I know other sides where you can swear and name call with impunity and I know sites where you might get banned without warning at the fancy of one of many faceless mods.  I feel that I have been fair and open at all times.

Again, I don't get paid for moderating this site, not that it is normally a challenge.  I am slightly offended when people think I have been harsh.  Do you think I need to appologise for anything (sincere question)?

[PhilB]

I did ask both debaters to stay away from the personal comments and you invited him to continue with the "who needs training" and started the "was it you who did the animals guide thing".  So, I felt a further warning was necessary.

Again, I don't get paid for moderating this site, not that it is normally a challenge.  I am slightly offended when people think I have been harsh.  Do you think I need to appologise for anything (sincere question)?

Chris

I don't really want to do this in public, but as I said earlier the comment about the animal guide was intended in jest, as I'm sure Fishy realised.

It was Fishy who made the personal jibe about me needing training but I took no offence.

I saw it as a bit of light hearted banter, clearly you didn't.

Personally I think you do a great job as moderator and it is appreciated, but I think you slighly misjudged the situation here.

Cleveland, bless him, offered to bury a hatchet in my head in an earlier post (which makes asking someone if they put a horse in an inner room very tame in my book) yet me and Cleveland are best of chums now and plan to go train spotting together.

[Tom W]

so anyway ....... those pesky fixed hosereels hey?!

[Chris Houston]

I don't really want to do this in public

That was my thoughts, so I had planned to stay out of this, but you did say:

You or Chris may apologise any time you like.........over zealous forum administrators

........Which was rather public.

Personally I think you do a great job as moderator and it is appreciated, but I think you slighly misjudged the situation here.

Thanks for the first bit, perhaps I did, perhaps I didn't.  But perhaps others might misjudge too, and that is what bothered me more.  If the worst I can be acused of is to "slightly" misjudge the tone of an internet forum post, then it only proves I am as normal as the next bloke.

So, to get this in perspective, I didn't ban anyone, amend or delete any posts or close any treads, I just warned both of you once and yourself a further time.

If you think I've over reacted, I must disagree, but I don't want to dwell on this.  I had more important things to concern myself with, but after the invitation to appologise, I felt the need to explain.

I hpoe we can all move on from this storm in a teaspoon and get back to the debate!  

[Davo]

Gents

Lets kill this off


RR151 is a research report called 'good practice and pitfalls in risk assessment' written in 2003 on behalf of the HSE by the HSL.
It is not, repeat not approved/endorsed by the HSE.

The FS guides do repeat do have official status being approved by the Minister.

In any case, RR151 has its flaws in my humble opinion, just like our dearly beloved guides.

The two main points getting lost here -
One) A H & S  RA is nothing like a FRA.
Two) Code Hugging gets you a bad name


davo

[Midland Retty]

A competent assessor or inspector will recognise where the 'over provision' of fire precaution exists and will therefore decide whether or not that provision can be reduced or removed.

Previous requirements placed on RPs from archaic or outdated legislation and to a degree poorly trained fire safety inspectors meant over provision occured in the past. I see that then as another good reason to review your precautions periodically.

And that gentlemen is how your risk assessment and fire safety policy should work or be approached- you should be reviewing it and adjusting it where necessary.

What was satisfactory yesterday may not be satisfactory today and just because something has been in place since Kingdom Come doesn't mean to say its right.

You shouldn't be afraid to challenge things, and ask " Is this right?" then review , evaluate, decide then implement.

The beauty of risk assessment and self compliance is that it allows greater flexibility for an RP to implement the right precautions for their particular working environment.

What they and risk assessors and inspectors alike need to understand is that sound knowledge to make these judgement calls is paramount, because otherwise my friends you just aint competent to make decisions which may impact on life and property protection issues.

10 different risk assessors will always give 10 different answers to the same prioblem. But on the fundemental bread and butter issues they should all be playing the same tune.

[Clevelandfire]

So what are you saying about reverse ALARP?