Statutory requirement for extinguishers to be on brackets, stands or cabinets?

[nim]

If a FRA  does not mention how extinguishers should be sited is the default that there is a statutory  requirement for extinguishers to be placed on brackets, on floor stands or within cabinets if the manufacturer says that extinguishers must/should be on brackets, on floor stands or within cabinets and or BS 5306-8:2012 says this.

The RRFSO says you must nominate a competent person to maintain and to maintain they must use the manufacturer’s specifications and BS5306 so do brackets, on floor stands or within cabinets naturally follow or is there something else?

Does the RRFSO state that extinguishers must be commissioned installed and maintained in accordance with the manufacturer’s specifications?

Thanks in advance.

[colin todd]

NO it doesnt.

[TFEM]

The RRFSO Part 2 (17...Fire safety duties) states that the responsible person must ensure that any equipment installed under the Act is "subject to a suitable system of maintenance".
I am not a legal person and I'm not sure whether this has actually been tested in court but to my simple eyes, a suitable system of maintenance would be one that is in accordance with British Standards....ie Maintenance (5306 Part 3:2009) and Selection and positioning (5306 Part 8: 2012). Section 6 of the latter refers to "Positioning of extinguishers" and sub section 6:1 (a) states that extinguishers should be "in conspicuous positions on brackets, on floor stands or within cabinets". Section 6 also refers to visibility, mounting height and brackets.
So, in answer to your question, as Colin rightly says, "no it doesn't" but............
John

[Tom Sutton]

Check out http://fire.org.uk/forum/index.php?topic=5463.0 it may be worth a read but whether its helpful is another matter.

[Midland Retty]

Simple answer is no, the RR(FS)O doesn't specify it.... it should be down to the fire risk assessment.

The risk assessment should highlight any need for maintenance, if it doesn't then I would suggest it should be reviewed ASAP.

There is no default position - you can have any maintenance regime you want, but whether it would stand up to scrutiny is a different matter.

Enforcers will generally refer to British Standards, or other accepted guidance as "benchmarks" so that has to be your starting point, and if you decide depart from those benchmarks,which of course you are free to do, you need to justify it.

[nearlythere]

How does the panel feel about a departure  from the weekly fire alarm user check to monthly?

[Midland Retty]

It depends. Are we talking simply a cat M System? or L system? (ie; detection) What type of premises? How sophisticated is the alarm system?

BS 5839 Part 1 states that a different call point should be tested each week in rotation, so that all call points are tested over a "prolonged period". There is no limit to how long this rotation takes (ie if you have 200 call points then each call point will be tested once every 200 weeks)

So you can have some small buildings with say three or four call points which perhaps get tested 13 times a year for example. Yet you can have larger buildings with lots of call points inside where each call point  gets tested in two year cycle for example.

So to me yes if you only had a few call points then what is the point of testing those same MCPs so regularly? But then again some would argue that because there aren't many its easier to test them more regularly and demonstrate good testing practices. 

But what about landlords in HMOs for example? Its difficult to undertake weekly tests of call points in HMOs. Would monthly checks suffice?

[colin todd]

Retters, retters if you would only materialise the visit to Retty Towers, I could explain so much to you. Weekly testing is more or less nothing to do with the condition of MCPs, it is primarily to make sure the system has not completely died.

So many fire officers and so many myths and misconceptions................

[kurnal]

The purpose of weekly testing as described in BS5839-1 is to ensure the system has not suffered some catastrophic failure that has gone unnoticed- caused by a meltdown of the battery charger shorting out the batteries or a  lightning strike for example- and to familiarise the occupants withthe sound of the alarm. The weekly test simply limits the time before such problems are found though they would normally be apparent from the daily check on the panel.

If you choose not to carry out a weekly test then perhaps you should consider what alternative measures you could take to ensure a similar standard of safety. There should also be consideration of the risk in the equation- the point that a failure of the alarm in a sleeping risk is likely to have much more serious potential consequences than in an office. And very often its the the sleeping risks - HMOs, none compliant blocks of flats that are the most inconvenient to have tested on a weekly basis and the least likely to have daily checks on the panel.

If the RP always carried a vibrating pager, if diligent daily checks are made of the panel, if the alarm system is monitored by a BMS, if all fault alerts generate an SMS or email, if you somehow had enhanced monitoring,  if the fire alarm system has only been installed for property protection, if failure of the alarm would not lead to a major risk to life safety then maybe you could make a reasonable case .

It could also be suggested that if catastrophic failure does occur the failure might not be noticed for 7 days under BS5839-1. In quantifiable terms how much worse would it be if it was not discovered for 30 days? And how likely would it be that a fire would occur on one of those days?  Though Murphys Law would probably see to that.

[AnthonyB]

Putting extinguishers on brackets and stands is admirable and in line with BS 5306, but isn't an absolute - after all M&S never bothered and until recently didn't even use signs, relying on staff markers at ceiling level (red circle for call point, red rectangle for extinguishers).

The whole point of risk assessment is so you can adopt the precautions to meet the situation - after all BS5839 allows (agreed) variations.

As for call points as far as I see it doesn't matter if you take 200 weeks to go around them on the weekly test as the service engineers should have got around them all in a 52 week period over 4 or 2 visits anyway - as said it's to make sure the system works.

[Midland Retty]

Retters, retters if you would only materialise the visit to Retty Towers, I could explain so much to you. Weekly testing is more or less nothing to do with the condition of MCPs, it is primarily to make sure the system has not completely died.

Ah Sir Col even I know that - I didn't explain my point very well, and I partly misread NT's question too .  

Nevertheless the point of mentioning a larger building vs small demonstrates that it is not solely about testing the functionality of a call point, because clearly there is a huge disparity between the examples I gave  (In my example: one call point tested once every 100 weeks in the large building vs 1 call point tested once every 13 weeks in the small building)

But even so the test does also serve to determine if a call point works or not. Bear with me on this.
 
I also mentioned that the type (or use) of building, category of system, and sophisitication of the system etc would all have an obvious bearing (on whether the RP could consider a relaxation of weekly testing) .

If I have CIE which can indicate battery fault, mains fault, sounder fault as well as general fault, and I visually check it for faults daily does that not achieve the same thing as an MCP test?.

If I have category of fire alarm system which includes detection can I relax my weekly testing regime on the theory that I can tolerate the failure of an MCP and assume that a detector will activate instead ? And in the knowledge that in a bigger building down the road their hundred plus call points are not tested on such a regular basis as mine? In otherwords it we can assume its rare for a MCP to fail, otherwise why would the standard allow such disparity?

I'm thinking especially about our hapless landlords of HMOs and flats where daily / weekly checks in their properties simply don't get done. I was just considering the practicalities.

I'd argue so long as I have a system with a decent panel which can indicate all of the faults above, and someone (a trusted tenant for example) looks at that panel daily,and acts on any faults does it matter if I dont test my call points weekly? Don't know perhaps I'm way of mark here.

[colin todd]

Retters, you are scaring me. I may have to demote you to asistant assistant chief in my new brigade.  Think about it Retters. How do the fault monitoring circuits work, they need processors to operate, power to be supplied etc. If the system has totally failed, how can the failed system detect its own faults, when the fault monitoring circuits dont work.

Look at it this way.  You buy Mrs retty a new washing machine and put it in the cellar to make the uniform of my new private frs clean and sparkly.  Because you are a cheapscape you buy her a cheap and nasty one that is prone to failure. So you tie mrs retty to an old oak beam in the cellar and give her a cordless phone so she can get the service engineers every time it breaks down.  The reliability of the washing machine is not improved but its down time is minimised cos she will get it fixed every time it goes wrong. It is a monitored washing machine.  But then the power to retty towers ( a place i shall probably never visit alas) totally fails. The machine stops working but mrs retty doesnt know cos the lights have gone out and she cant see whether its working or not. And in any case, the cordless phone terminal unit has failed too, so she cant tell anyone its not working even if she knew.  The washing machine will sit there until you come home from work and go to carry out a manual check on mrs retty and the machine and find to your horror that you have no clean uniform.  just as well you didnt wait for a month to find out eh?

[Midland Retty]

Understood Sir Todd but it was my understanding, perhaps incorrectly, and remember I did say if it were a fairly sophisticated system that if there were a problem with fault monitoring circuits  then it would trigger some form of fault code / message / light back at the CIE

And clearly if there were no lights on the panel at all I'd assume the panel was dead and ask Mrs retty to call the engineer! No power Sir Col!

[kurnal]

But what will we do with the broken washing machine? Are there any parts we can use to fix the fire alarm panel?

Note to Retty
Old Col defends his fire alarms as fiercely as Sir Jim protects his graphics. Be warned.

[lancsfirepro]

Putting extinguishers on brackets and stands is admirable and in line with BS 5306, but isn't an absolute...

I'm not comfortable with going down the route of leaving it up to the fire risk assessor to decide whether the extinguishers are wall mounted or on stands etc.  The thing with wall mounting an extinguisher is that it then has its designated place - where they are sat on the floor I tend to notice that these are the places where they tend to get moved about or used more readily as door stops.  I prefer to use the thinking that BS5306 (parts 8 & 3) were created with a degree of risk assessment built in - so that after consideration it's recommended as being standard practice that they are mounted on brackets or stands.
The other thing to note is that when just stood on the floor they can get knocked over - especially CO2 extinguishers.  Anyone having had the pointy end of an extinguisher handle land on the top of their foot will tell you that it darn smarts.  Before anyone suggests that extinguishers on stands can get knocked over just as easily, I recommend you fit the bracket to the stand so that when the extinguisher is stood on the stand the bracket is the right height to locate in the hanging loop on the extinguisher to stop it falling. 
There's enough muppets doing a shoddy job of installing/maintaining extinguishers without giving them the option of not wall mounting them.