Probabalistic risk assessment vs. good practice

[Tom Sutton]

It appears that there is a consensus of opinion that companies should maintain a minimum level of fire safety precautions but there will be those who ignore the legislation for various reasons and the “I have never had a fire why do I need fire precautions” may develop more widely.

If this is the case do we have an enforcement regime that will curtail those companies or have the FRS cut back on enforcement officers to a level that may give concern and those that we do have will they have the necessary training.

[Ken Taylor]

Whilst there will be some buildings where the risk of and from fire is negligible (such as unoccupied concrete or brick boxes) once you introduce persons, work activity, plant, equipment, materials, substances, heating, electrical installations, etc, etc into the equation, the risk must increase to, at least, a level requiring appropriate controls - which for life safety will need to include information, warning and extinguishant. History may be a guide but risk assessment needs to consider what could happen in future and it's consequences.

[Fishy]

But we’re not discussing ‘negligible’ risk – there is no obligation in law to make risks negligible.  The obligation is to reduce them As Low As Reasonably Practicable (‘ALARP’).  This means that you do NOT have to address all foreseeable risks.  

The HSE framework for tolerability of risk separates risk into ‘Unacceptable’, ‘Tolerable’ and Broadly acceptable’ regions.  If you have reduced a risk so that it is in the ‘Broadly acceptable’ range (or it is inherently in that range) the guidance says that you generally need do no more – the risks can be regarded as insignificant and adequately controlled.  The HSE limit for ‘Broadly acceptable’ is a risk of death of 1 in a million per annum.  HSE guidance quotes the annual risk of death from “fire, explosion or carbon monoxide poisoning” in the UK population as roughly 1 in 1.5 million per annum.  The bulk of this risk must be when people are in their own homes; in the vast majority of cases the risk in their workplace will be lower.  So why should the people responsible for those premises be expected to shell out hard cash to mitigate what is already a vanishingly small risk?  Can the above not be their risk assessment?  If not, why not?

As a fire professional I am not particularly comfortable with the above line of argument – but I find it difficult to spot why it isn’t legal!  There are a few potential flaws; for new works it takes insufficient heed of good industry practice (British standards) and the HSE also obliges those assessing risk to take into account societal concern (difficult to do, unless you adhere to the Codes, which are written with that in mind).  If there are other flaws, what are they...?

[Ken Taylor]

The 'theory' may meet some HSE terminology, Fishy, but I wonder what the Courts will make of it. To take the Carbon monoxide example, imagine the response to quoting national statistics as a defence to not  servicing heating appliances or providing adequate ventilation.

I would, of course, gladly replace the term 'negligible' by 'insignificant' in my contribution above - a term which the HSE are on record as saying describes risks that can usually be ignored. When we get round to recording and addressing the significant risks, I cannot imagine personal injury or death by fire within buildings as being excluded or that the provision of the normal control measures for these is not reasonably practicable.

Risk assessments need to be suitable and sufficient and published guides and codes do seem to indicate measures generally deemed to be of this nature. Departure seems a risky course to take or advocate.

[Uncle Dave]

If the risks are ‘Tolerable’ or Broadly acceptable’, surely this is because steps have been taken to reduce these risks, so to continue keeping the risks low these steps must still be taken.

To use the carbon monoxide example, the death rate is low because rules are in place to ensure that appliances are serviced.  To keep the deaths low servicing must be continued.

Hope this makes sense.

Dave

[Donna]

If the risks are ‘Tolerable’ or Broadly acceptable’, surely this is because steps have been taken to reduce these risks, so to continue keeping the risks low these steps must still be taken.

To use the carbon monoxide example, the death rate is low because rules are in place to ensure that appliances are serviced.  To keep the deaths low servicing must be continued.

Hope this makes sense.

Dave

Sorry to go off the topic for a min, Regarding the carbon monoxide bit, When it came to the news the terrible accident where those children lost their lives in Corfu back a couple of months ago, I thought, hang on a minute, (as this sad news gave me a kick up the backside) Im one of those who qualify for the well advertised "free annual, carbon monoxide checks" endorsed by the government, (available to Disabled or pensioners) I had not ever had a check before, so I tapped in to the relevant info web page and followed links to see how it could be arranged, it said to contact whoever supplies your gas to you, and they would sort it out,
Well to cut a long story short, after many many telephone conversations, It is only for Natural gas customers! and  misses out the thousands of gas users who sadly live in areas where they have NO MAINS GAS available and have to rely on LPG, so lets think about this for a minute, what is one more likely to do with a portable appliance, (my personal lpg fire is fixed in the wall, but some peeps do have those wheeled ones with blue bottles in )  on low income, maybe someone confined to one room, yes exactly that! and its those people who actually are the more vulnerable and so more at risk! so I gave a lot of ear bashing to the people who are the regulaters of gas, and even one told me that LPG does not give off carbon monoxide, I obviously has a quick sticks apology when I asked to speak to their manager! but nevertheless, Until the government recognise that LPG has as important dangers as natural gas regarding carbon monoxide then its the same old chestnut,
One rule for one, and a different rule for another, no wonder we are all so confused to whats a risk and whats not....

[kurnal]

Portable heaters with gas cylinders within are a big concern because as you know they do not have a flue and there are no checks to ensure inlet air is provided in the rooms in which they are used.
All the products of combustion- mostly carbon dioxide and water vapour are discharged into the room leading to condensation. The instructions always say open a window- but how many do that whenever they are using the heater? Just a few years ago there were many deaths each year from monoxide poisoning.

If I recall one key factor was the condition of the ceramic radiant panel on the front of the heater, the gas was always intended to burn up the front of the ceramic panel, but these were mounted in a bed of fire cement which can crack and fall out. When this happens gas can burn at the back of the ceramic panel, usually accompanied by a popping sound. When this happens the heater gives off large quantities of carbon monoxide.

The moral of the story is not to use this type of heater in sealed rooms, and most important to have them inspected and serviced regularly. Do not use it at all if there are any cracks or gaps in the ceramic panel or if it makes a popping noise as it burns.

[Donna]

Your Quite right Kurnal, I personally hate those wheeled portable heaters, (which we used to call a "super ser") but I used to know 2 old ladies in my area, who Did use these, and they stayed in the same room with them all day, with all doors and windows closed, (they are now in nursing homes) this was because it was the cheapest heating they could afford, as they regarded the electric storage heaters too expensive, and years ago we used to have loads of power cuts and the elderly couldnt take the risk of their heat sorce failing, even though I dont get out visiting anymore to "see" this still happening, I do not have a doubt that this IS happening in 100s  if not 1,000s of homes around the country, who do not have the pleasure of mains gas, (I was so surprized to how many villages dont have mains, when I looked into it)

But my point was is that the government recognise that there is a need for advertise these free checks for the vulnerable, but to exclude LPG when (in my opinion) its these users are at the most risk ,is very very unfair and (again in my opinion) negligent!

Its ok for us to say that providing these heaters are serviced regularly they are ok, but in reality its down to money (peeps on low incomes) and then it comes down to hoping the vulnerable person actually has an "on the ball" visitor or relative that will actually organise a service and or Pay for it to be done!

[kurnal]

Bang on Donna.
Many Fire Brigades in conjunction with Age concern and other charities do free electric blanket checks for vulnerable people.  If they find a defective blanket- usually around 40-50%- they give a voucher for a discount on a new one- or in some more unusual campaigns they  replace them free of charge.

A campaign on portable heaters / LPG systems would be of equal value especially in view of what you say about the free safety checks. May be worth emailing a few environmental health departments and fire brigades to see what the current statistics for death and injuries are. Then targetting the charities that serve any particular groups identified as being vulnerable.
Most of the LPG based fixed installations will be in rural areas and of course whist rural poverty is less visible than inner city poverty, where it occurs it tends to be more extreme because of a lack of infrastructure and support services.

[Donna]

I totally agree,
I did make a few phone calls, and tried to rattle a few cages, but I was (and still am) embroiled in another personal campagne, and I just had to "but it on the back burner" (pardon the pun) for a while as I was trying to do too many things at once...but it is something that I will follow up, Ive just got a few more weeks of (this DDA thing Ive got going on) another annoying campagne for fairness and justice to fight for, first.

[Ken Taylor]

It's not just gas appliances with a CO risk, donna. Solid fuel burning will also produce CO when the oxygen supply starts to reduce (eg when chimneys and flues are not regularly swept). Ventilation is essential for all heating involving the burning of fuel. CO detectors can be useful but must not be a substitute for maintenance.

[Fishy]

I'm not sure that The Carbon Monoxide example is entirely relevant.  Firstly, sticking in a CO detector is cheap; fire precautions can often require engineering that is far more expensive.  Secondly the discussions above are on domestic installations - are there similar requirments for non-domestic installations?

Going back to Donna's other threads - could the approach outlined be used to justify not making provision for means of escape for people with mobility impairments?  If a Responsible Person can demonstrate that their level of risk is in the Broadly Acceptable region without having any particular plans in place, does legislation demand that you do anything to reduce risk further?  This is a potentially huge issue...

PS - Don't assume that I'm advocating this approach - I'm just putting it forward for discussion!

[Mike Buckley]

I had a look at the RRO itself (not the Guidance) and there it states in Emergency routea and exits 14 (2) "The following requirements must be complied with in respect of premises ............in order to safeguard the safety of relevant persons. (b) in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible;"

This looks to me as if the legislation demands that the means of escape must be available to relevant persons ie anybody legitimately in the premises. It does not define any special cases ie mobility impairment. So the risk assessment arguement cannot stand, the magic ALARP phrase does not appear.

In other threads I know there has been the arguement about Stay Put Policy and Phased Horizontal Evacuation but nowhere has the issue been raised that these policies should replace adequate means of escape. As I have read it these practices are in addition to the MoE due to the particular features of the situation.

[Martin Burford]

Subject: Key Boxes
I recently inspected a new build HMO [ completed August 06 ] and found that some doors deemed by the Approved Inspector to be FIRE EXITS..were secured by keys in boxes. I recall from my FPO days that these arrangements were outlawed by the then HOme Pffice in the middle 1980's....anyone any comments.
Conqueror.

[wee brian]

Mike the reasonableness bit is there even if its not actually in the law - (a Government lawyer explained this to me)

As quickly as possible could mean a firemans pole (dont get smutty) next to every desk!

Conq - Keys are pretty much frowned upon - it makes you wonder if we should go back to prescription!