PAS 79 available for public comment

[Eli]

PAS 79 is out for public comment

http://drafts.bsigroup.com/Account/Login?ReturnUrl=%2fDocument%2fManage%2f809

Interesting! particularly in light of the fire risk assessor getting sent to prison; the advice on selecting competent assessors is at best duff and at worst selective to say the very least.

[kurnal]

Interested to hear more detail of your views Eli as I sit on the steering group (as the FIA representative)  and I  believed the information reflected the situation at the time the draft changes were discussed back in January this year. Things have moved on apace and it would be appropriate to review the content in the light of recent developments.

[colin todd]

I think a particular certification body should be spelled out in capital letters so it gets prominence amongst all others.  Happy now Eli (aka xxxxxxx).

[Phoenix]

Just had a quick scan.  I might have to make some comments but I thought I'd ask some questions here first.

Firstly, I couldn't get the above link to take me to the document but found it at this link:

http://drafts.bsigroup.com/Home/Details/809

Excuse me if I have misunderstood or missed some things in my quick scan, but I would make these comments:

• The scope states that this is not intended as a guide to fire safety and that it is for use by people with a knowledge of fire safety.  So why do we have sections 13, 14, 15, 16, 17 and 18?  These seem to give the fire risk assessor instructions on fire safety principles - shouldn't he/she know all this (and much more) anyway?
  Shouldn't this guide stick to what it says it is targeting?
  
• The definition of fire risk is 'Combination of the likelihood of the occurrence of fire and consequence(s) (number and severity of injuries) likely to be caused by a fire.'  What concerns me is the measurement of consequences under this definition - 'number and severity of injuries.'  Is it okay if only one person dies?  Is it worse if a hundred people get away with minor but permanent lung damage?  The whole concept of consequences is often mis-placed in the fire safety world.  The way it's applied came across from health and safety but this method of application is often meaningless in terms of fire safety. 
  Later on in the document we have a table with likelihood set against likely consequences, the consequences are 'slight harm', 'moderate harm' and 'extreme harm' - okay, if we have an EL fitting out, the worst that might happen might be that someone breaks their leg on the stairs (is that slight?) - but aren't we looking at 'extreme harm' (i.e. people dying) as the likely worst consequence in most (if not all) cases when considering means of escape?  Either people get cut off by a fire or they don't.  Either they suffer burns to their skin and lungs or they don't.  The whole aim of fire safety is to get people out of the building without suffering any significant injuries; any failure, to me (and hopefully to you), is 'extreme.'
  So if the consequence is virtually always extreme, isn't two thirds of that table redundant?  Isn't the concept of trying to guess what the worst injury might be, due to some shortfall, redundant?  Shouldn't we forget this naive distraction and concentrate on controlling the defect?
  
• Figure 1 is a pig's ear and clarifies little
  
• But the worst thing about Figure 1 is that it is one of only three in the entire document!  I find the whole document inaccessible due to its verbose, circumlocutory bulk.  Who's going to wade through all that?  If you're queueing up out there to pore over every word please get back to me and tell me I'm wrong to think that the presentation of this document makes it cumbersome and turgid.
  I'm not attacking the content particularly here; there are, of course, good points (many of them) in the document but they are not easy to find in the morass of flim flam.
  I remember the first attempts at the CLG guides, they were all words, and the same for the first attempt at BB100.  All thrown out and replaced with documents with diagrams, illustrations, graphics and other devices that abbreviate much of the wordiness and serve to make the documents more manageable for the reader.  I'm not saying everything in these other documents is great, I'm just saying they're accessible. 
  
• Going back to the scope, the document dismisses property protection, environmental protection, business protection, etc.  These elements might not be required by legislation but they are often of particular interest to the building occupier and I would have liked to have seen some more discussion of the inclusion of these elements in FRAs.  Maybe, the document does come back to this matter in its appendices, I don't know, I haven't the stamina to check.
  
• The terminology, 'trivial risk' doesn't sit right with me.  If something is trivial, it is of little worth and insignificant.  If it is insignificant, why bother mentioning it?  There is a place in FRAs for comments and observations regarding matters that are noteworthy but which do not require any remedial action.  Personally, I always record these under 'observations' and give a discussion and rationale for those who may follow to understand my thought processes.  But 'trivial risks' - either something is a risk and requires remedial action or it is not a risk and requires none.  I don't think there's any place for 'trivial risks.'
  
• In a similar way, what is a 'tolerable risk'?  If something is 'tolerable' then it is satisfactory and requires no remedial action.  I think I understand what class of risk is intended to be addressed by this phrase but I believe the use of the word 'tolerable' is misleading.  To the lay person it conveys something that can be tolerated and that needs no rectification.  What about 'slight'?
  
• Figure 3 could be better depicted showing a more realistic safety margin between RSET and ASET.  I know that the graph shows no scale but the small margin shown is, unfortunately, mirrored in many fire engineers reports and design fire strategies.  It would be better if this document did not serve to preserve this bad practice.
  
• Apart from that, fine.
  

Stu

[Eli]

I think a particular certification body should be spelled out in capital letters so it gets prominence amongst all others.  Happy now Eli (aka xxxxxxx).

Conflict of interest again! IFE last time wasn't it?

Just do it right Colin; without bias and blatant promotion. I believe the IFE stuff got pulled in the second edition no doubt you thought you could get away with it this time too.

It is a PAS not an advertising brochure for what ever scheme you are chair of at the time.

[John Webb]

A minor comment on BSI practice - if drafts are for 'Public Comment' why do you have to register with the BSI website before you can view a such a draft........

[jokar]

If risk assessment as a methodology for the BSI is available as BS 18004 why aren't the principles of that document on show in this attempt?  Surely BSI should follow the rules already set in motion for risk assessment.  As has been mentioned above clear definitions such as significant and insignificant risk are needed and these are already set.

[colin todd]

Ah Eli, so jaundiced, so twisted.  The IFE were an active supporter of the first edition and acted as a form of sponsor, so they were rightly acknowledged.  There was nothing "pulled". Nor is there anything to get away with, as I have no axe to grind SINCE I DO NOT (amended by Kurnal) TRY TO CONCEAL ANY AFFILIATIONS THAT I MAY HAVE. So when I make comment here or elsewhere, everyone knows who I am and what any affiliations are, though in drafting public documents I am always impartial.  Now do you want to tell people who you are and who you work for, Eli, so we all know your particular angle on life.

[Eli]

Ah Colin, so deflective, so narcissistic.

So if you pay for a PAS you can stick in what you want? I am shocked, are there no rules? Who do I send a cheque to?  

Cash for promotion in a PAS; sounds like a scandal to me! Who do I call at BSI?

BAFE and FIA must have coughed up a ton of cash! They first appear in page V in the foreword with a very special mention. No other bodies get such a promotion which I find strange.

Colin is it me or is it loaded in favour of two specific organisations? Is that what you call impartial?

UKAS or not?
Why FIA and BAFE?
What about the IFPO, IFSM, IFE, FRACS registers?
Have you read the forum rules?
Did you read my responses last time you tried this?
Did the moderator not make direct contact with you?


For a point of accuracy all I want in the PAS is unbiased sound advice. That can be done without any direct promotion of any specific schemes. Or can it?

[colin todd]

Well Mr Anonymous Eli, whoever you might work for, here is the answer to your questions as to what about IFPO IFSM and Warrington, (content deleted by Kurnal).But let the public of firenet decide whether the above are impartiality covered by the following text which is a copy and paste from the draft PAS 79:

There are a number of means by which the public can be assisted in selecting a competent fire risk assessor and/or a commercial company that carries out fire risk assessments.  At the time of writing, these include registration or certification schemes operated by the following bodies:

•   The Institution of Fire Engineers (IFE), which has, since 2003, operated a “Register of Fire Risk Assessors and Auditors”, on which can be found persons who are considered by the IFE to be competent to carry out fire risk assessments (or to “audit” dutyholders’ fire risk assessments as the inspecting officers of enforcing authorities).  The list can be accessed at: www.ife.org.uk/frr/.
•   The Institute of Fire Safety Managers (IFSM) operates a register of fire risk assessors.  The IFSM Register can be viewed at: www.ifsm.org.uk/register.html.
•   The Institute of Fire Prevention Officers (IFPO), operates a register of fire risk assessors.   IFPO can be contacted via their website, www.ifpo.org.uk.

•   Warrington Certification Limited, a third party certification body, operates a register of fire risk assessors and a certification scheme for companies that carry out fire risk assessments on a commercial basis (www.warringtonfire.net/6/113/default.html).

In addition to the above, membership of the Fire Industry Association (FIA) includes companies that carry out fire risk assessments.  These companies are signatories to an FIA code of practice, under which member companies of the FIA that carry out fire risk assessments agree to have in place various quality management systems and to employ competent fire risk assessors.  FIA member companies that carry out fire risk assessments can be viewed at www.fia.uk.com.

At the time of writing this PAS, British Approvals for Fire Equipment (BAFE) are in the advanced stages of publishing a third party certification scheme for companies that carry out fire risk assessments.  The intention is that this scheme will be operated by any third party certification body that is, itself, accredited by the United Kingdom Accreditation Service (UKAS) for the purpose.  It is likely that, during the lifetime of this PAS, one or more certification bodies will begin to offer certification under the BAFE scheme.

If this is not impartial enough for you, by all means complain to BSI. I can only imagine that you dont like the order in which the organizations are set out, which, as it happens, was chosen to be chronological in their initial date of operation, so as to be impartial.  However, please feel free to suggest a basis for another running order, and I am sure we will take that on board.

[colin todd]

In the meantime, I shall pass your post on to BAFE and FIA, with a note that I have discovered that, according to you, they have coughed up a load of cash for their mentions.  I am very annoyed about this, as I have not been cut in on the dosh.  Where is my share?  Thanks for the tip, Eli. I shall make sure that when I get my share of the loot I cut you in for 10% for drawing it to our attention.

Equally, I do hope that you are correct in your allegation or BAFE and FIA might be a tad upset.

[colin todd]

On a further point of accuracy, concerned that somehow, unbeknown to me, there might be even a tiny morsel of truth that "the references just keep coming" I have word-searched for the organizations to which Eli refers, but can find none after the foreword, other than the cut and paste above. So, where are all these references??

So that everyone is aware, as also made clear in the draft, for impartiality, the stakeholder group that is steering the draft includes BAFE, FIA, IFE, IFSM and IFPO.

[kurnal]

On re-reading the relevant section of the draft, and to be fair to all parties involved, the following form of words may be more equitable:

Warrington Certification Limited, a third party certification body, that is, itself, accredited by the United Kingdom Accreditation Service (UKAS) for the purpose, operates a register of fire risk assessors and a certification scheme for companies that carry out fire risk assessments on a commercial basis (www.warringtonfire.net/6/113/default.html).

Thanks to Phoenix and Bleve (though on a different thread)  for a range of interesting comments worthy of further consideration and comment, though in the context of this being a periodic review of an existing PAS, (as always these things are authored by a third party) I cannot conceive the Author agreeing to make the fundamental changes Bleve suggests in moving towards a graphics based approach. Can we realistically expect such fundamental changes at this review to a document that has been in use for 6 years with only minor modifications in 2007. Besides this the use of diagrams, though useful also has its pitfalls. Diagrams can be used to illustrate a point but cannot impart the underlying logic behind that point.  So many people just look at the pictures- including some enforcement officers.

Phoenix my views on the inclusion of technical guidance are similar to yours - the best place for detailed technical guidance is in the sector specific technical guidance documents, though others may feel that  the guidance is included to illustrate points relative to the process of conducting the risk assessment. Further consideration of the guidance is justified in my view.
More on your comments later.

As moderator I would ask all parties to keep on topic and to respect the privacy of other posters, even though some may wear a very thin veil

[Eli]

In the meantime, I shall pass your post on to BAFE and FIA, with a note that I have discovered that, according to you, they have coughed up a load of cash for their mentions.  I am very annoyed about this, as I have not been cut in on the dosh.  Where is my share?  Thanks for the tip, Eli. I shall make sure that when I get my share of the loot I cut you in for 10% for drawing it to our attention.

Equally, I do hope that you are correct in your allegation or BAFE and FIA might be a tad upset.

According to Eli

[Eli]

On a further point of accuracy, concerned that somehow, unbeknown to me, there might be even a tiny morsel of truth that "the references just keep coming" I have word-searched for the organizations to which Eli refers, but can find none after the foreword, other than the cut and paste above. So, where are all these references??

So that everyone is aware, as also made clear in the draft, for impartiality, the stakeholder group that is steering the draft includes BAFE, FIA, IFE, IFSM and IFPO.

Fire and rescue authorities can advise on the fire safety legislation that applies to any
premises, and on means for compliance.
If in doubt regarding the requirements of
legislation, consultation with the fire and rescue authority is strongly recommended.
Advice
can also be obtained from a suitably qualified and experienced fire risk assessor or fire
safety practitioner.
A number of bodies maintain a register of persons who they consider
competent to carry out fire risk assessments. These include professional bodies and at least
one third party certification body. Registration of a fire risk assessor on such a register can

give the duty holder confidence in the education, training and experience of the fire risk
assessor to those who wish to use the fire risk assessor’s services.
At the time of publication of this Publicly Available Specification, one third party certification
body also provides a scheme, accredited by the United Kingdom Accreditation Service (UKAS), for companies that carry out fire risk assessments on a commercial basis. British
Approvals for Fire Equipment (BAFE) are, at the time of drafting this PAS, also in the
process of developing such a scheme, which, when published, will be able to be operated by
any third party certification body that is accredited by UKAS for this specific scheme.
“Company certification” schemes of this type are based on a combination of assessment of
the competence of the persons who carry out the fire risk assessments and a suitable quality
management system. Member companies of the Fire Industry Association (FIA) that are
listed by the FIA as offering fire risk assessment services are required to comply with an FIA
code of practice and will, ultimately, be required by the FIA to achieve third party certification
under a company certification scheme.

The foreword as printed.