"The way I look at it... the default position is that they should be installed, because that's what all the guidance recommends. To go away from the default, you have to argue convincingly why this is acceptably safe. That's the test that the Courts seem to apply, so that's the test that I use".
Extracts from PAS 79:11 (draft)
The assessment of fire precautions in the fire risk assessment does not merely involve rigid comparison of existing fire precautions with standards set out in prescriptive codes of practice. Similarly, the action plan is not based on rigid adherence to prescriptive norms found in codes of practice. To adopt such an approach would not necessarily result in risk-proportionate fire precautions. Nevertheless, in assessing or formulating measures to eliminate or control fire hazards (see 3.33), it will often be appropriate, in the case of certain fire hazards, such as potential electrical faults, to adopt guidance in recognized codes of practice. This will particularly be the case where these codes of practice
are well established, universally recognized, produced by authoritative bodies with specialist knowledge regarding the hazard in question, and based on sound scientific or engineering principles (as opposed to arbitrary judgements).
......In addition, sometimes different recommendations apply to new and existing premises. For example, recommendations within guidance that supports building regulations often differ from recommendations within guidance that supports legislation applicable to existing premises.
Typically, guidance on fire protection measures for new premises (e.g. guidance that supports building regulations) is more onerous
than guidance on fire precautions in existing premises (e.g. guidance that supports the relevant fire safety legislation). This makes rigid adherence to any particular code of practice even less appropriate. It also means that guidance that supports building regulations in respect of new premises might be unduly onerous to apply for the purposes of a fire risk assessment for existing premises, constructed before the
introduction of the current building regulations.
.........This has led to a school of thought amongst some experts that the application of prescriptive codes of practice within the fire risk assessment is inappropriate. However, while there is a need for risk-proportionate fire precautions, rather than rigid application of prescriptive norms, it should be borne in mind that prescriptive codes of practice have achieved their objective; for example, it is rare for multiple
fatality deaths to occur in non-domestic premises that comply with the relevant prescriptive code of practice, unless a number of failures in fire safety management have occurred.
.............This PAS is intended to be suitable for use by, for example, fire risk assessors with a background in application or enforcement of traditional prescriptive fire protection codes of practice. Accordingly, it is assumed that published guidance will be a starting point or benchmark for assessment of the adequacy of fire precautions in the premises. It is, however, further assumed that the fire risk assessor is capable of exercising judgement to determine whether the recommendations of such guidance should be relaxed, or added to, in order to determine the appropriate level of fire precautions and to formulate a risk-proportionate action plan.