Fire Behaviour

[novascot]

Hello Mike.
you know what they say about stastistics.

The point I was making was that the phrase "reasonable in the circumstace" is being forgotten about by FSO's. It is all about what is in the Guidance Documents. They are not assessing the assessment which I thought the audit was meant to do.

[Mike Buckley]

Yes I agree about stats I just put the example forward to show how risk is affected by numbers.

As far as 'reasonable in the circumstance' it joins the 'as low as reasonably practicable' stable. It all calls for a judgement to be made and a gamble to be taken. There is also the problem of public perception, at the moment there is a big campaign about knife crime with tales of 17 people being killed with a knife in London this year. However on the same scale in Leicestershire there were 10 people killed in road accidents last week.

It makes the audit job difficult as a decision in a 'sexy' area can be condemned as overbearing in a different area and the goal posts may rapidly change depending on the whim of the politicians, the press and the public. No wonder there is pressure towards the 'code huggers'.

[novascot]

Understood but back to grass roots and FSOs and the failure of many of them to recognize when the risk is as low as REASONABLY practical. EG:

A res care home with a two seat sofa in an alcove of a corridor complying with the F & F Regs. Ideal for the old folks to rest as they get around "their" home.
FSO asked for it to be removed. When asked why, he quoted the Guidance Doc. Where was the assessment.

[Ricardo]

The point I was making was that the phrase "reasonable in the circumstace" is being forgotten about by FSO's. It is all about what is in the Guidance Documents. They are not assessing the assessment which I thought the audit was meant to do.

A res care home with a two seat sofa in an alcove of a corridor complying with the F & F Regs. Ideal for the old folks to rest as they get around "their" home.
FSO asked for it to be removed. When asked why, he quoted the Guidance Doc. Where was the assessment.

I totally agree with you novascot, I work with such people, cant seem to get past the guides, its their comfort zone, yet they've all done their FRA course and training, but out there, it all seems to go out the window, they've got it in their heads that everyone must have a certain standard or else.

[novascot]

Yes Ricardo, it is very worrying. How do we combat this? I beleive there is a lack of good quality training of our FSO's at Brigade  level (not pointed at anyone in particular) or they are told to "forget all that mumbo jumbo, here are your Guides. It used to be "Here are the Building Regs."

I have seen letters from F&RS saying that the premises did not meet the benchmark standards and there were no compensatory features. The inference being that if you don't meet the Guide Benchmarks you need to do something else to compensate.

The answer is, maybe. Doesn't it depend on the FRA?

On another thread there are concerns re the standadrd of FRA's from "Consultants". Could it be that these "Consultants" are newly retired FSO's and if they didn't know how to carry out an Audit by using Risk Reduction principles based among other things on probability, as FSO's there is not much chance of them doing it as "Consultants".  

Worrying. We are all doomed!

[kurnal]

My experience is that very many fire officers are enforcing the guide and there is all too often little heed taken of the RRFSO's emphasis on proportionality.

To many fire safety officers porportionality goes something like this- the London Hilton has 1000 fire doors and 2000 smoke detectors.  I am telling Farmer Postlethwaite in his farmhouse B&B just to install 10 fire doors and 10 detectors. So thats proportional.

[novascot]

Kurnel,
LOL that about sums it up.

A couple of quotes from The Strategic Enforcement Guidance: (I don't know if Englands' is the same)

" Authorities should work with all dutyholders so that they can meet their legal obligations without unnecessary expense and clearly distinguish between statutory requirements and guidance about what may be desirable as good practice but not compulsory to meet the legal requirements"


and again

It is not appropriate for an enforcement officer to provide a prescriptive solution as the sole means of addressing deficiencies.

Ooops they have forgotten that bit. Or were they aware of it in the first place?

[CivvyFSO]

It is not appropriate for an enforcement officer to provide a prescriptive solution as the sole means of addressing deficiencies.

Ooops they have forgotten that bit. Or were they aware of it in the first place?

So what do you want? 4 options? 5?

Something is going wrong if you think we can enforce the guides. The legal part of the enforcement notice should just tell you which articles you are not complying with (i.e. Article 13, No means of giving warning), and basically tell you to comply with them. (i.e. Provide a suitable means of giving warning) How you comply is up to you and this should be made clear. (N.B Scotlands notices may be different to ours)

The 'advice' given should not be part of the enforcement notice. If advice is required then why not give the same advice that CLG sees fit to give out? Don't get me wrong, I am an advocate of risk based solutions, I am really defending my right to stick to the guides if I so wish and leave any other options up to you.

Anyway, if we didn't have the guides people would be wittering on about inconsistency.

[novascot]

Civvy FSO
The point I am trying to convey, is that Brigades here ARE using the Technical Annexes as minimum standards and that is not correct.  It isn't about options it should be whether you can recognize a "safe" building and what can be done to make it a safe or safer building. Ways of doing that may not be found in Guidance Documents.

In conversations with FSOs, it is apparent that the concept of Life Safety and the tenebility levels allowing safe evacuation  are lost on them. Or lots of them.

I asked an FSO how long he thought the compartmentation of a zone in a building would protect the tenebility levels and he asked "What has time to do with anything?"

I rest my case.

[Tom Sutton]

The way I see it both sides are to blame, if FSO's are auditing as described on this forum then there is a training need to be addressed by the FRS. If risk assessors are so certain about their solutions then they should convince the RP to take the FRS on in court and let the court decide. There is nothing more sobering than knowing you have to prosecute or defend yourself in court and it could be beneficial to all parties.

[CivvyFSO]

You can't even spell it.......

TenAbility. I rest my case.

(Just teasing! )

It just seemed to be turning into a good old FSO bashing thread so I thought I would speak up.

I agree the guides should not be taken as minimum standards, but using them as a benchmark standard is different. If you run some death trap of a building and I come and find you working away on the 4th floor with no protected stair, no AFD etc, then I will quite possibly give a solution straight from the guides. Protect the stair, get detection. I won't ask you for detection that is not required, and I won't ask for a fire door that is not required. I may ask for an extra detector to compensate for a 25m dead end. But, why should I spend hours looking at other solutions at the tax payers expense when it is your responsiblity to comply in the first place?

If you want to submit an solution looking at ASET and RSET and backed up with a strategy/risk assessment etc then you submit it, and you should be so confident in your solution that you are prepared to defend it. If an FSO/FRS is being unreasonable then challenge them, appeal the notice. The appeal will at some point end up on the desk of someone who knows more about the subject, and if you are on the right lines then I am sure it will go no further.

I guess the main point I am trying to convey is; You cannot expect us to sit around doing smoke mass calcs, plume calcs, running CFD programs etc, just to save the RP a bit of money, we will go for the simple solution.

[lambie]

I posted some time ago that in my experience the risk assessment was required to be produced at audit but it was not necessary to read it.This still seems to be the case and the guides still remain the prescripive norm. The very term GUIDE should give the game away. The best premises,the most comprehensive risk assessment, the tests recorded and training given, still the footprint of the building can have a detrimental affect on your score and the risk assessment is a token gesture. Novascot you have summed up the frustrations a number of us have felt.

[novascot]

Civvy FSO
sorry for the spelling mistake. The fingers were working faster than the brain.

If I were still an FSO I would do exactly as you have suggested in your scenario. You are not meant to risk assess the building, only give advice. Should it not be a case that you tell the RP that he needs a suitable and sufficient FRA to be carried out? Then your job, as I understand it is to read through the FRA and agree or disagree with the findings.

That is where the problems occur. Too many FSO's cannot read the FRA and make a judgement without reference to or quoting the Guides.

Surely the questions to be asked are:

1. Can persons leave the building or go to an area of comparative safety before the products of fire affect their escape?

2. If a fire occurs can it be contained in the room/area of origin until safe and effective evacuation can take place.

The methods of ensuring the answers to these questions are yes, can be wide and varied but each solution, in their own right can give a positive outcome.

It does not have to come from any Guidance document. Many Brigades are missing that point when you read letters sent to RP's.

Back to the Local training or the lack of it. The FSC MiM was many things but at least their was a common thread throughout the UK and the principles of Fire Safety were not taught as whimsical notions of individuals.

[CivvyFSO]

As I said before, any solution offered should be explained as an 'option' and it should be made clear that there may be other ways to comply. If the FRS/FSO involved is blindly not entertaining alternative solutions offered because they are not comfortable with it, or worse "don't understand it", then that is indeed wrong. Even if the FSO is out of his/her depth, there should be someone within the FRS who has the capability to assess it properly.

Lambie, there are 2 different scores you get. One is the compliance level, and the other is the relative risk level. A large footprint with a good compliance level should prompt the crews visiting for local operational knowledge of the building and not necessarily pointing towards regular inspections by FSOs. (Especially with the new regulators compliance code being out which should ease the burden on compliant businesses.) This was different when the whole audit/scoring thing first came out. I had a few compliant businesses that were getting yearly inspection. This should stop now, or soon at least.

[lambie]

CivvyFSO
Thanks for the explanation, it almost looked like you were damned if you did and worse if you didn't. I have to say that there are those that give credence to those assessments that are honest and have reasonable action plans agreed. Just sometimes you crave for conformity, but hats off to those IO's who understand the the meaning of guidance.