Just a few points:
1. I think B&B makes a very persuasive point when he says that many B&B owners don't feel able to challenge fire officers. My experience is that many also do feel able and do so quite forcefully. It takes all sorts. What fire officers should learn from this is that we need to be proportionate and follow the ethos of the concordat. We can't expect people to talk to us if we project ourselves as being unapproachable. Whilst I'm certain that many inspectors are approachable, I reckon a few who maybe don't have the confidence to enter into a reasoned debate with a risk assessor or RP may possibly hide behind the guides using them as a smoke screen. That's a problem for FRA's in terms of training, support, management and the like. Don't forget, the RRFSO has been as much of a culture change for FRA's as it has been for everyone else.
2. Inspectors are employed and authorised by FRA's to enforce the requirements of the RRFSO, no more no less. They should be making sure the RP is taking reasonable steps to protect occupants from harm by fire. Sure, we can make recommendations to improve safety further but any who are 'covering their backs' or working to personal agendas are frankly operating outside the requirements of the law and should be challenged. You don't need to appeal or complain to do this, you can ring the FRA concerned and ask to talk to the inspector's boss or another senior officer. Fire officers are at the end of the day public servants and complaints are taken extremely seriously, my FRA goes to great lengths to publish complaints procedures widely.
3. And yes, I agree that the letters are long and wordy. I know it doesn't help the lay person but unfortunately that's the nature of the beast. When FRA's do have to take the ultimate sanction and take on a prosecution, the court needs to see that the RP has been kept fully informed of the requirements and their rights throughout the whole process. I suppose it's a bit like the small print at the bottom of contracts and the like, tricky to read, unpopular, but sadly necessary. They could be clearer mind you.
4. FRA's are enforcing the law based on guidance from the CLG. That's what they have to go on. Re-reading my previous post I would like to withdraw the comment about 'why are ministers involved'. It's becoming obvious that this situation has to some extent been left to sort itself out - find its own level as it were. Ministers should be aware of both the difficulties being experienced by B&B owners and also (importantly) the problems being experienced by FRA's in enforcing the legislation. As I said before, perhaps we need to raise the profile of fire safety enforcement issues. Having said that, maybe the reason the profile isn't so high is the relatively low number of fire deaths in B&B's as compared with, say, certain demographic groups of the housing sector. Like I said earlier, it makes sense to put in most effort where it will have best effect.
5. I think one important point hasn't been raised yet - why are FRA's seemingly targetting B&B's? I can only speak from personal experience and say that we are finding problems. FRA's are following the recommendations of the Hampton report and the Better Regulation Office and targetting their activities. They look at premises which have a higher than average potential risk (as identified by the CLG, such as sleeping accomodation) then sample some premises. What we have found is a significant number of problems.
Food for thought?