(split topic) minimum requirements of fire safety for their residential block of flats under the RRO

[Hi Tower]

In his reply, jasper raising another issue which went into a different topic.  I've split it here.  The origianl thread was an enquiry about risk assessors in yorkshire.  Chris.

Jasper
I can put you in touch with the fire service down our way - who are now undertaking FRA's on behalf of the public.  To clarify:

I have just viewed a recent letter sent to a RP telling them exactly what they need to do to meet the minimum requirements of fire safety for their residential block of flats under the RRO.  The advice that isn't referenced to any guide or document comes with the official seal of the FRS and their headed paper.  It will save your clients considerable amounts of money as it is deemed that close fitting doors (without strips or seals) are suitable for 4 storey buildings that have stay put policies in place, no mention of routine electrical or other 3 phase maintenance and servicing is required as recommended by BS7671 or the manufacturer's guidelines (for passenger lifts etc.).  
Best of all, if a peril does occur nobody can be prosecuted because the FRS have compromised their own position as enforcer - a direct conflict of interest.

In fact I did the original FRA for the above property and because I now don't where a uniform with shiny boots and a yellow hat I'm deemed as not competent by the RP that originally instructed me as of course the FRS know best.

I appreciate the FRS should provide advice (as suggested by the Hamilton Report and other public body codes of practice) but a full FRA, that is documented, well that's something else.

Perhaps there are others out there that know of other FRS's that are confusing the heck out of everyone by telling RP's that they need to conduct a FRA and if they don't they may well be prosecuted whilst at the same time offering free FRA's to others.

Good luck with your business plan!

Seriouly though has anyone else come accross this sort of thing going on?

[kurnal]

Hi HT
Do you know if it service policy to do this or is it a friendly helpful fire officer doing his own thing?

[Hi Tower]

Kurnal

I am just in the middle of writing to the said FRS to determine what their policy is.
All I can say at the moment is that the advice was written on their headed paper with a clear statement of their significant findings.

Friendly advice is welcomed and one thing, but completing the whole jolly thing is quite another, is it not?

[Clevelandfire 3]

If it is the case that the FRA are touting or getting business that is totally out of order. Let us know the outcome because if thats what they are doing I shall write and complain.

[CivvyFSO]

as it is deemed that close fitting doors (without strips or seals) are suitable for 4 storey buildings that have stay put policies in place

There have been many threads on this subject, and the general concensus is that this would generally be ok. CLG guidance says so, Todd says so, Aunty Lin says so, what more proof do you need?

no mention of routine electrical or other 3 phase maintenance and servicing is required as recommended by BS7671 or the manufacturer's guidelines (for passenger lifts etc.). 

So where exactly in the RRFSO is the need to maintain your electrical systems and passenger lifts?

I appreciate the FRS should provide advice (as suggested by the Hamilton Report and other public body codes of practice) but a full FRA, that is documented, well that's something else.

Do you mean the Hampton report? (Just being a little pedantic now, I shall stop...)

I do actually agree with the basic idea that we, as an enforcing body, should not be undertaking risk assessments in any guise. It is a conflict of interest, and a clear unfair business advantage.

[nearlythere]

With the maintenance of electrical systems, would that not come under a "Duty to take general fire precautions" Civvy?

[kurnal]

So where exactly in the RRFSO is the need to maintain your electrical systems and passenger lifts?

Article 4 does it for me. Many fires are attributed to an electrical cause.

Persons using a lift at the time of an alarm are relevant persons. Its surprising how often you find that no provision has been made for emergency lighting in lifts. Great. Fire occurs, power fails, lift stops between floors and I cant even see to find the emergency communication button.

[BLEVE]

There is no chance that "a close" fitting door would be acceptable in relation to smoke spread in the situation described

[CivvyFSO]

With the maintenance of electrical systems, would that not come under a "Duty to take general fire precautions" Civvy?

Can you see any FRS enforcing it? Why not go the whole hog and enforce a service of the gas boiler too while we are at it?

It is measures to reduce the 'risk' of fire. I think there is a valid argument to say just protect against the fire that 'could' happen. You have to do this anyway, since we can't realistically 100% eradicate the actual likelihood of a fire, you have to put in a suitable level of protection "just in case". So if you can ensure the safety of relevant persons 'if' a fire occurs, then what more work is needed to comply with the fire safety order? i.e. If I can prove that regardless of how a fire starts, that my means of giving warning will work, the means of escape can be effectively used, and the premises will effectively be evacuated, then what more can any FRS really ask me for?

BLEVE, to take Mr Todds approach... How many people have been killed or seriously injured in the flat next door to the flat of origin due to the lack of smoke seals or strips?

Don't get me wrong here, I would prefer it if everywhere had strips and seals, but it is not automatically justified just because it is an improvement.

[kurnal]

Taking it the other way Civvy if we see an obvious electrical hazard during a fire safety inspection we have to refer to it and recommend an inspection and test by a competent person. No choice.

If then we become aware that an installation has not been inspected within the recommended time scales set out in the 17th edition, do you think should we should ignore it unless we see an obvious fire hazard involving the installations?

Should we ask to see a copy of the last inspection report during a fire risk assessment? I always do. Many category 1 and 2 defects are reported that could lead to fire - and are never actioned.

[BLEVE]

Dunno Civvy, I would have to look that up. However, I still disagree that they are acceptable in the four storey, remain in place premises as described previously.

I do know that quite a number of fatalities have been recorded at various points along means of escape from multi storey buildings due to smoke.

 

[Hi Tower]

Civvy - a few days have passed and I've now been able to cool down, well only just, the weather's good isn't it?

I know that doors and the need for strips and wot not have been discussed over and over; I've viewed the threads many a time, didn't get the opinion though that the general concensus was that a well fitting door would do - in fact I felt that the general opinion was quite split?

[CivvyFSO]

Yes it has generally been a split vote. But that is the exact reason that you shouldn't be knocking the FRS in question if they have decided that good fitting doors without strips and seals might be acceptable in certain circumstances. It is something that will always promote discussion, but IMO they should be applauded for actually biting the bullet and making a definite decision if nothing else. Also is there not some guidance issued by the secretary of state that suggests that good fitting doors that used to meet a standard should still be acceptable?

Kurnal, I am not talking about obvious electrical hazards, I am talking about the routine maintenance of electrical/mechanical equipment not supplied as part of fire safety.

Bleve, if you can attribute even 1 death a year purely to the lack of strips and seals on a good fitting door then that is enough to convince me that (on moral grounds at least) we should always try enforce them until a determination or successful appeal shows otherwise.

[Midland Retty]

I agree with Civvy and to a certain extent Kurnal.

Take Kurnals scenario - a dodgy electrical installation. We know most fires are caused by faulty electrics so it would be reasonable to expect an auditor to make comment about any diodgy looking installations, sockets, et al. YOu would also expect the auditor to ask for the last inspection report. But what the auditor does from there then depends.

Lets say Kurnal's dodgy electrics are in a hotel. Being as it is a hotel it should, based on guidance, have the relvant compartmentation, MOE, fire doors, AFD to L2 coverage, etc etc, and this brings in Civvy's point.

There should automatically be sufficient levels of protection in place to warn people of a fire occuring, allow them to escape safely regardless of just a dodgy electrical installation. If that electrical installation did catch fire, but the AFD raised the alarm, the fire was contained, and and everyone got out safely has the RP complied with the Fire Safety Order ?  

Again to agree with Civvy we need to be careful about using article 8 as a total catch all, because as Civvy states where do you stop? Ok the electrical installation is something I think would fit under the duty to take fire precautions, as is the gas installation.But what else? Are we going to then look at water leaks too? At what point does that get too onerous? or too tenuous?

Ordinarily fire safety inspectors will verbally point out general health and safety failings or non fire safety related issues to the RP and will then and pass those observations on to the relevant enforcing authority to be actioned as they see appropriate.

[CivvyFSO]

A nice diplomatic approach Retty.

I might (just might) have been tending towards 'taking the issue a little too far' in order to explain my thoughts.