Author Topic: Significant Findings??? (Read 23467 times)

PhilB · « **on:** June 25, 2005, 07:51:36 PM »

Please allow me to ressurect the debate on the definition of 'significant findings'. Some of you may be aware that the draft guide to offices & shops implies that these are deficiencies, as does CFOAs draft guidance for consistency of enforcement!!!! The ACOP to MHSW Regs gives a very different and I beleieve correct definition.
Furthermore, at the risk of upsetting Mr Todd, the ACOP states that the significant findings should include a record of the preventitive & protective measures, in all but very small premises how can this be achieved without the use of a plan?

The FPA 71 never required a plan, but most certificates usuall included one as this was the simplest way. Spookily enough PAS79 recommends a glorifired check list..without a plan!!

Suitable and sufficient......I wonder??

Brian Catton · « **Reply #1 on:** June 25, 2005, 08:10:09 PM »

If you look at PAS 79 carefully it includes an action plan which will detail the specific areas clearly together with the action to be carried out. I think the action planning section of the PAS requires a litte more development and a better structure so that action required can be effectively detailed followed through. PAS 79 is a skeletal framework on which you can hang your own protective structures. I am sure it is not meant to be the answer to all situations. It does not prohibit the use of plans, or anything else for that matter. Since you have mentioned FPA 71 plans I must have examined hundreds if not thousands of plans since 1971 and I cannoy remember any that were 100% accurate and up to date. Why was this? Because the system was so labour intensive that the Fire Service did not have the time to administer it. This is why plans are not being rewuired under the new system. Having said that I will probably develop a system for my employer that can eventually utilise plans as and when they become available.

colin todd · « **Reply #2 on:** June 25, 2005, 09:58:22 PM »

Well let's consider means of escape Phillip. Is it a significant finding that there is a VP on a specific door and shown as such on a plan. Or is it significant that protection of inner rooms is adequate. You could have a look at the ODPM representation to the parliamentary review of the RRO. Or by ananogy, is it a significant finding in the H&S RA that the P&P measures include first aid kits, or should it have a drawing showing where they are and a list of the number of Band Aids they contain (thats sticking plaster to you, Brian, not a self-styled group of crooning 3rd world savers).

PhilB · « **Reply #3 on:** June 25, 2005, 11:22:14 PM »

Well yes Colin...if it needs a vision panel is that not a significant finding??..and should it not be recorded..to what detail???...it must be proportionate to the complexity of the building I believe. I do not suggest that every minute detail has to be recorded...but in more complex premises a plan is surely the only effective way.
Incidently I have a lot of respect for you and your PAS...but I really think the poor blokey on the street deserves some consistent guidance!

colin todd · « **Reply #4 on:** June 26, 2005, 12:00:04 AM »

AWWWWWWWWW shucks, you country blokes say the nicest things, not like these met blokes! but as we know Philip the only way we will ever know the answer is to put it before a man with a wig and deviant sexual tendencies. In the meantime, I cannot see how all the work of preparing plans can be justified as a legal requirement. But if it is bring it on. It usually exactly doubles the cost of an FRA.

Brian Catton · « **Reply #5 on:** June 26, 2005, 12:11:28 AM »

Once again you are right Colin. It can help to identify the requirements in a large building though. It also serves to assist the recipient of the report to know exactly to which part of the premises the Assessor is referring. As you say though it should never be a legal requirement otherwise we may as well go back 24 years.

PhilB · « **Reply #6 on:** June 26, 2005, 10:11:26 AM »

Once again you are right Colin..Pleeeeeeeese!!!!!!!!!!!!!

Careful Colin I only said I respected your PAS, that does not mean I have not found significant problems with it.

I do agree however that it will be the strange man in the wig who will ultimately have to decide what is suitable and sufficient. No doubt he will refer to guidance documents. If he refers to the new draft guide to offices and shops he may believe that significant findings are deficiencies only, CFOAs latest guidance would tend to support that view. If he refers to the ACOP of MHSW Regs, he will see that significant findings is correctly defined. It should include a record of the preventitive & protective measures.

For the time being you are safe Mr Todd as most SFSOs wouldn't know a suitable sufficient, or deficient RA if it bit them on the backside. But be afraid...be very afraid...there are some good training courses available that look at a variety of methods of RA.. not just PAS79. Who Knows......perhaps someone with some knowledge of fire risk assessment may be able to prove to the wig wearer that your method is not so good. And that the responsible person has not shown all due dilligence.

Brian I never suggested that it should be a legal requirement, if you can show the significant findings without a plan in a complex building please carry on. However I believe I could usually demonstrate to a Court that you have not done enough.

But hey...only the Courts can decide...so all the consultants out there ....some with very little knowledge or other qualities can carry on.....for the time being!!

colin todd · « **Reply #7 on:** June 26, 2005, 02:27:48 PM »

1. It is not MY PAS. ownership rests with BSI, who consulted widely throughout the fire safety profession before publishing it. You will note that consultees include, but are not limited to, CFOA, IFE, IFPO and BSI fire committees and as I recall health and safety committees; the BSI review group certainly received comments from the health and safety profession. The full list of consultees is in the PAS. The PAS was only published once a review group, on which CFOA and IFE were represented, considered all comments. You may be right and all of those who commented and those on the review group, who did include 2 SFSO's complete with bites on their bums presumably, could have missed massive shortcomings. Not for me to say really.
2. PAS 79 is not a method, it is merely a structured approach.
3. Forgive me for not being afraid. A bus load of SFSO's and other practitioners can be fielded to talk to the man with the wig in support of the structure outlined in PAS 79.
4. I think that Brian and I feel that you cannot demonstrate to a court that he has not done enough, so we have an impasse. But bearing in mind government policy is that the employer may be able to do it himself, my money is on Brian, not least cos he thinks I am right a lot apparently, so his judgement must be good.
5. You are urinating in the wind by banging on about the ACOP in the same sentence as the new draft guides, as the Regs that the ACOp supports will no longer apply to the fire risk assessment once the RRO comes in, so you are trying to converse, as it were, in Euros and Dutch gilder simultaneously. Unhappily, that does not compute.

PhilB · « **Reply #8 on:** June 26, 2005, 02:48:02 PM »

1.Yes I am aware of who you consulted.
2.Yes I know, but I believe it has deficiencies...my opinion.
3. Would they all be competent to make comment?
4. Well I believe you and Brian are wrong, yes the man in the street can carry out basic RAs. More compex situations will require more expertise.
5.I am not 'urinating in the wind by banging on about the ACOP in the same sentence as the new draft guides, as the Regs that the ACOp supports will no longer apply to the fire risk assessment once the RRO comes in,' that is exactly my point....the ACOP will still be relevant for carrying out risk assessments to comply with the relevant statutory provisions..........but the blokey on the street will have a different definition of S.Findings when complying with the RRO, but the publishers of the guides consulted widely just like you...so they must be right!!!!!

Good discussion though Colin!

colin todd · « **Reply #9 on:** June 26, 2005, 05:03:01 PM »

1. Good.
2. Life is never perfect, Phillip, unless you happen to be ''underworked and overpaid''.
3. One would hope, Phillip, that most would be as competent as your good self, since they would all be fire safety specialists. If they were not competent, one would hardly put them on the bus in the first place.
4. Yes, we gathered you thought that Brian and I are wrong, but Brian and I await the evidence that flies in the face of the views of authoratative bodies, other than Brian's suggestion that we are to go back 24 years, which alas Brian and I remember well. (Well, in Brian's case, only when he is sober!)
5. I don't think that the blokey is getting different advice. I think you are interpreting something in a way that it is not generally interpreted.
Anyhow, the guides don't officially exist yet, so who knows.

steve walker · « **Reply #10 on:** June 26, 2005, 09:32:36 PM »

I recommend using floorplans to record the physical features. If an assessment just says that the escape routes, exits, extinuishers, etc are adequate then how do you revise / review the FRA? Surely you need to know what was adequate. Also I think that it is useful to record why the safety measures are considered adequate. For example: does it comply with british standards or the Employer's Guide (yes, I do think the EG is flawed). Variations should be recorded and explained.

Steve

PhilB · « **Reply #11 on:** July 01, 2005, 03:51:10 PM »

Colin
Why do you think interpreting something in a way that it is not generally interpreted?

The ACOP clearly states what should be recorded. Let's hope the new guides are amended to coincide with the ACOP.

I do believe a consistent approach is needed ...and that is why I said I respected the PAS. I am slightly concerned that PAS79 was developed by a private consultant and is now being approved by such bodies as IFE...who then decide who can be on their approved list of assessors. Whose on that panel I wonder?

I think we need a few alternative publicly available templates etc. that are approved by professional bodies to assist in consistency.

colin todd · « **Reply #12 on:** July 01, 2005, 09:26:30 PM »

All Pas's are developed by private indivduals or organisations. That's what they are. The ACOP does not clearly state what should be recorded. If it did you would not need to debate the issues. Moreover, the ACOP is as good as dead as far as the fire safety world is concerned; indeed, many in that world never even knew it existed, in which case they are like those who split infinitives, who Mr Fowler describes as a happy band of people who don't know any better but are none the worse off for not knowing. The PAS is not ''approved'' by the IFE. The IFE were keen to see it devloped. Wrong way round, I am afraid ( that's very afraid) Phillip.

PhilB · « **Reply #13 on:** July 02, 2005, 05:51:54 AM »

The ACOP does clearly state that the significant findings should include a record of the preventitive & protective measures.....hence my original point.

"The ACOP is as good as dead as far as fire safety is concerned"....!!!!!!!!!...so we only use that definition for RA carried out to comply with HASAWA and a new completely different one for the RRO....good idea!!! that will help the blokey in the street!

Yes I agree many did not know of it's existence and some of them call themselves consultants.....not you included of course Mr Todd!

I appreciate that the IFE were keen to see the PAS developed......something was definately needed...with a bit of tweeking it may be adequate......but the IFE will surely be keen to see other methods that may be as good if not even better developed and promoted.

colin todd · « **Reply #14 on:** July 02, 2005, 12:07:24 PM »

1. Again, you miss the point, Phillip. A record is the word used, not description. The building has emergency lighting. There ya go! There is a record of a preventive and protective measure. The Ra only has to document significant findings. The location of each fitting is not a significant finding. You may think it is and you may hanker back to the good old days of a fire cert but they are gone. And the people who wrote the legislation told the Parliamentary committee that they did not want plans and use of consultants as they want to make it easier for the employer. Now, Phillip, I know that this is not conducive to those who want to make a big new science and art form for fire risk assessments, usually for reasons on their own agenda, but do not shoot me, I am only the messenger.

2. The ACOP was an imperfect document as it was written round H&S, and then strained to take fire into account. Whether you like it or not, it is as good as dead, and will soon be irrelevant. What will then be relevant will be the stat guidance under the RRO> When it says there MUST be a plan for the RA to be suitable and sufficient do come back to me won't you.

3. I keep telling you that the PAS accepts a million and one methods so long as they meet the structure advocated. Now I know that not may suit people who want to sell pseudo scientific and rather worthless crap, but it does please many users and consultants who quite legitamately claim compliance even though they have a multitude of different formats, etc.

News:

Author Topic: Significant Findings??? (Read 23467 times)