RRO, risk assessment and responsible person

[fred]

There appears to be no provision in the final scrutiny document of the RRO, for anyone other than the 'responsible person' to carry out a a fire risk assessment.  Article 9(1) is quite specific.  I'd be very interested to hear the views of any learned fire professionals, or RRO Committee members on this matter.

[fred]

And just to muddy the waters a little more - there is no requirement in the RRO for the responsible person to be suitably competent to make a risk assessment

Similarly, with regard to appointment of inspectors (Article 25) nothing there about them being suitably qualified or competent either.

[PhilB]

I'm not too sure what you're worried about Fred. Who else other than the responsible person do you feel may need to carry out a risk assessment.

The ordser does require the responsible person to appoint competent persons to assist him..if he is not himself competent.

With your point about inspectors what is of slight concern is the fact that enforcing authorities may.....not must appoint inspectors. If they chose not to appoint them...how will they comply with their duty to enforce the order.

Never mind....fantastic new guidance is about to hit the streets that will no doubt calrify the situation!!!!!!!...don't hold your breath.

I believe that most people including many people who post replies on this site are lacking in competence to carry out a suitable & sufficient RA and a lot of them are making money from their incompetence!

[fred]

Fair point - perhaps I'm keen that whoever is putting the guidance on the RRO together addresses these issues.  If legislation appears to be quite specific then that's how it wll be interpreted by the enforcers.  The RRO covers the nomination of competent persons by the responsible person to implement firefighting measures, evacuation of the premises, safety assistance (undertaking the preventive and protective measures, and dealing with dangerous substances.  It doesn't say the responsible person can get anyone else ( ie. consultants) to do the risk assessment.   Ho hum !

[colin todd]

No, but the ACOP, which Phillip loves to quote states that a ''competent person'' knows his own limitations and is willing to supplement his knowledge with external ssistance. The draft guidance on the RRO--you know the guidance no one is ever supposed to see---says that for more complex situations the employer will probably have to engage specialists for advice.

[stevew]

On the introduction of the FP Workplace Regs government insisted that safety standards should not fall.   Poor advice to government gave the impression that all was rosy in the garden.  This led to  the 'softly softly' approach by the majority of fire authorities on enforcement.    

The message on standards is being repeated for the introduction of the RRO.

How is the the RRO going to prevent safety slipping further?

To expect the layman to define a 'more complex situation' is absurd.   Many care providers consider their premises presents a low risk from fire irrespective of the size, layout and construction.

There must be a place for the competent fire risk assessor.   This will ensure safety standards are maintained.   Perhaps we should ask the public who they would prefer to set fire standards, the fire service, employer or a competent risk assessor.   The fire service are no longer in the frame.   That leaves two and I know who I would vote for.

[colin todd]

I vote for myself. ( I just have, in fact, for the elections to the IFE Board). BUT!!!! The small employer is much better doing the FRA himself, rather than using consultants, who, though, one could be forgiven for thinking to the contrary, are not the answer to everything.

[stevew]

Colin
If we are voting, I have no doubt in my competence.

Operating in different sectors of the market as I believe we do  sometimes gives a differing overview of what is happening out there in the workplace.

I fully support the risk assessment, less precriptive approach to fire safety (this is coming from an ex fire officer).  The downside is convincing fire inspectors of the new approach.  

I agree that the small employer may be able to carry out his own FRA.
The risk is leaving the employer to decide when or when not to ask for help.

Still got to convince me that standards will not slip.

[colin todd]

They will become more diverse Steven, that's for sure. Fire inspectors are quite rightly sceptical. They know that there will be a long learning curve during which we will be living on borrowed time with our fingers crossed. And all there will be to save us, strangely enough , is a bit of rigorous enforcement.

[shaunmckeever]

It seems I am one of the few who has not seen a draft copy of the RRO Guidance. Does anyone know where I might be able to get a copy?

[PhilB]

I saw a draft of the office & shops guide that had a wierd definition of significant finding. i.e different to that in the ACOP for MHSW Regs. This error was pointed to the relevant people and hopefully they will take the necessary action to amend the guide. We will have to wait & see.

If they don't it will cause confussion for enforcing authorities and responsible persons. There are plenty of copies of the draft order circulating around...allegedly!