Frequency of review period for Fire Risk Assessments

[Firescot]

I was recently asked to carry out a review of a large night club in Glasgow by a Company on a sub contract basis.

Just before I was about to carry this out, I was informed that it had been cancelled.

The last Fire Risk Assessment was carried out approximately two years ago.
 
A Fire Officer from the Enforcing Authority had visited between the time the review was booked and me carrying it out.

The Officer told the owner of the night club that a review only needed to be carried out once every 5 years.

The owner was then furious at this Company telling him he should review his fire risk assessment after only two years and obviously seen them as taking him for a ride!

There are guidelines within Scottish Guides and Legislation though it is still. unambiguous as it mainly just states they should be carried out regularly.

Due to the type of premises this is and the possible condition and age of the people frequenting it, i find the information supplied by the Fire Officer very disappointing indeed.

If anyone is aware of any guidance stating nightclubs only require to be reviewed in Scotland once every five years, please enlighten me.

[Dinnertime Dave]

The FRA should be reviewed when -

material alterations take place
there is a significant change
there is a reason to suspect that the original fire risk assessment is no longer valid.

Have any of these things happened? If not, why do I need to pay somebody to review it for me?

[Mike Buckley]

The only Guidance I have found comes in a document from CFOA entitled 'Collected Perceived Insights into and Application of the RRO (etc) for the Benefit of Enforcing Authorities.

On page 33 it states:

Any fire risk assessment must be reviewed by the responsible person regularly so as to keep it up to date. There is no definition of regularly but annually is generally accepted to be best practice.

However as in the FSO there is no mention of who should carry out the Review, it can easily be the RP who just looks at the FRA and records what steps have been taken to address the Action Plan from the original FRA.

The general practice seems to be that a full FRA is carried out every 5 years and in the intervening years it is reviewed on an annual basis i.e. looked at, has anything changed and what update what has been done. However all this will be subject to Risk Assessment, for example I am dealing with a large complex listed building that has a large number of tenants and the local FA has requested a full FRA be carried out annually. Similarly I know a chain of Hotels who have a full FRA every three years and an annual review. It will depend on the perceived risk.

At the end of the day it is down to the RP who will carry the can and the RP must decide how frequently to carry out an FRA and how frequently to review it, obviously based on advice received.

[William 29]

Every 12 months would have been my recommendation given the building type and depending on what the last FRA said? Have all the SF's been actioned then?

I wonder what audit frequency and audit score was recorded by the FSO? Bet its not on a 5 year audit?

[Phoenix]

The FRA should be reviewed when -

material alterations take place
there is a significant change
there is a reason to suspect that the original fire risk assessment is no longer valid.

Have any of these things happened? If not, why do I need to pay somebody to review it for me?

This list of three possible occurrences is valid but not complete.  If these three items were sufficient then we would be accepting that nothing ever routinely goes wrong in these premises.  But all fire risk assessors know that it is very rare that they come away from an inspection without having made some recommendations to bring the premises to a more acceptable level.  Things do routinely go wrong with the fire safety elements in a building so the above list has to be supplemented with 'regular' routine re-inspections.

This is a nightclub we're talking about here.  High life risk premises.  You can never cut corners with nightclubs.  Every year somewhere in the world there is a large scale tragedy in a nightclub, let's keep them out of the UK.

The five year gap between FRAs is nonsense, much too long for these types of buildings.

Any fire risk assessment must be reviewed by the responsible person regularly so as to keep it up to date. There is no definition of regularly but annually is generally accepted to be best practice.

The general practice seems to be that a full FRA is carried out every 5 years and in the intervening years it is reviewed on an annual basis i.e. looked at, has anything changed and what update what has been done.

As for this 'review', what is that?  Is it a fire risk assessment or isn't it?  I know a lot of people do 'reviews' but what is the difference between them and full FRAs?  I know that if you have already inspected a building the previous year then you are familiar with it and don't have to put as much effort into the inspection but I would argue that you should still class it as a fire risk assessment and not a mere, undefined 'review'. 

It cannot be denied that a satisfactory 'review' implies a satisfactory building.  Therefore, if you conduct a 'review' you cannot leave any stone unturned otherwise it is a waste of time.  It's like having a fire resisting door in a wall made of hardboard, it's incomplete and useless.  Yes, I agree that the 'stones' you have to turn may be easier to turn or, indeed, you may actually know what is under them without turning them but they still have to be considered and they still contribute to the overall level of safety and therefore to the 'review' process. 

I think there may be a marketing element to offering 'reviews' as clients may be more willing to subscribe to cheaper annual reviews than to what are perceived as more expensive full inspections - just speculating here, I don't do marketing.

If the 'review' you're referring to, Mike, is more a matter of assessing, maybe annually, whether or not a fire risk assessment is required then that's a strange beast.  How can you judge if a fire risk assessment is required without full knowledge of what the process entails?  You can't, so they can only be undertaken by competent fire risk assessors.  Ok, so now we have a fire risk assessor on site.  To assess whether or not a fire risk assessment is necessary he has to check certain things.  Now, making these checks will be easier than was the full FRA the first time he did it and he may be able to work down some sort of checklist but the point is, this is not a 'review', it is a fire risk assessment.

Anyway, back to the nightclub.  General default re-inspection period should be annual.  Inherent mitigating circumstances or proven track record of effective management might stretch that period to two or three years maximum.  Let's face it, some of these places should be inspected every couple of months.

 

[Martin]

Assume original fire risk assessment was thorough and covered everything with control measures which were very specific and detailed. RP reads through assessment after a year and knows nothing has changed and ticks and dates review box.

RP should also be checking the control measures are still in place. EG For a nightclub are relevant staff properly trained and briefed. The assessment will have said as part of control measures training was needed. The review will continue the exsiting requirement for trainingg as part of control measures. (Remember this was a good thorough "suitable and sufficient" fire risk assesment in th first place.) Why would an RP need to pay for outside assistance to say my activities haven't changed and the risks haven't changed therefore the risk assessmnet needs no alterations.

If the RP doesn't implement the findings of the RA and it all goes wrong the prosecution won't be for want of a suitable and sufficient assessment.

The RRO is criminal legislation with strict liability criteria. The phrase in the RRO about review is "regularly so as to keep it up to date." If an RP decided on 5 years intervals but could show they operated a long term business with little or no change, unless there is reason to consider the RA is out of date 5 years may well be regular enough. A small traditional shop may fit this sort of description.  (Note this is the regular review. An "irregular"  review may be triggered by any reason to think the assesment is no longer adequate.)

[Mike Buckley]

Yes Phoenix isn't it wonderful when the legislation bandies terms about without defining them!

In my opinion a review of the Fire Risk Assessment consists of looking at the premises to see if there have been any significant changes, going through the Action Plan to determine what has been done and what has not been done and why hasn't it been done.

At its most basic it is getting the FRA down off the top shelf, blowing the dust off it and reading it. This should trigger some actions and possibly remind people of things that should have been done, such as the dry riser needs testing!

It should also raise the question as to whether a full FRA should be undertaken, for example if the use of an area has been changed that will increase the likelihood of a fire or escape routes have been changed etc.

In the modern commercial world fire safety is well down the list of priorities and a review should refocus on the issues.

In my opinion the difference between a Fire Risk Assessment and a Review is that for a FRA you walk in with a blank piece of paper and start from there. For a review you walk in with a copy of the existing FRA and check what it says.

[Phoenix]

In my opinion the difference between a Fire Risk Assessment and a Review is that for a FRA you walk in with a blank piece of paper and start from there. For a review you walk in with a copy of the existing FRA and check what it says.

OK.  We'll probably agree to differ here.  I would say both were fire risk assessments but the latter one is easier to do than the former.  I'm not going to get hung up on semantics.

At its most basic it is getting the FRA down off the top shelf, blowing the dust off it and reading it. This should trigger some actions and possibly remind people of things that should have been done, such as the dry riser needs testing!

What you're saying here is in line with my thoughts.  The RP has fire safety somewhere near the bottom of his/her priority list so (relating to the original query) relying on them to maintain the highest fire safety standards without outside motivation for five years puts me in mind of kurnal's avatar.

Stu

[kurnal]

In my opinion the difference between a Fire Risk Assessment and a Review is that for a FRA you walk in with a blank piece of paper and start from there. For a review you walk in with a copy of the existing FRA and check what it says.

That type of review never works for me Mike. If the initial assessment was not done by myself I have to carry out a full survey in order to evaluate the previous report to check it was suitable and sufficient. And if it was done by me I still sometimes spot something I got wrong or overlooked last time! 

[Firescot]

Hi folks!

Great to see so many replies to my post so far and thank you.

The Scottish Government have issued various guidance documents and the one that applies to this is the PRACTICAL FIRE SAFETY GUIDANCE FOR PLACES OF ENTERTAINMENT AND ASSEMBLY.

It offers the following information regarding reviews of the fire risk assessment:

A review of the fire safety risk assessment should be carried out regularly. If the findings of the fire safety risk assessment are considered to be no longer valid or there has been a significant change in the matters to which it relates, such as a change to the premises that has affected the risk or the fire safety measures, the assessment should be reviewed.

 Other such changes that might prompt a review include:
 A change in the number of people present or the characteristics of the occupants including the presence of people with some form of disability;
 Changes to work procedures, including the introduction of new equipment;
 Alterations to the building, including the internal layout;
 Significant changes to furniture and fixings;
 Significant changes to displays, quantities of stock or stage scenery;
 The introduction or increase in the storage of dangerous substances; or
 Becoming aware of shortcomings in fire safety measures or potential improvements.

 The potential risk of any proposed change should be considered before the change is introduced. If a change introduces new hazards consider the fire risk and, if significant, do whatever is needed to keep the fire risk under control. In any case the fire safety risk assessment should be kept under review to make sure that the fire safety measures remain adequate.

 If a fire or near miss occurs, this could indicate that the existing assessment may be inadequate and a re-assessment should be carried out. Identify the cause of any incident and then review and, if necessary, revise the outcome of the fire safety risk assessment in light of this experience. If the Fire and Rescue Service has attended a fire in the premises, their findings may help inform a review of the fire safety risk assessment.

My assessment of this is that the fire risk assessment is a live, living document and any material changes in the premises should prompt the Duty Holder to review it.

A review of the fire safety risk assessment should be carried out regularly?, is the critical statement here. Although the term regular is not clearly defined, from my experience and knowledge, the risk within the building should determine how often it is reviewed.

In this case, (a large city centre nightclub), it is vital that robust management procedures and good passive and active fire safety measures are in place to ensure all persons can be evacuated safely.

 I would consider the risk to be quite a high life risk due to the numbers, age and condition of the persons resorting, and recommend a professional review is carried out annually or at least bi- annually.
   
I would not expect a local enforcing officer to tell them a review every five years is all thats required!

Hugh

[Phoenix]

Hi Hugh,

You're absolutely right.  For a nightclub, once every five years is not 'regular', it's 'once in a blue moon'.  I've inspected quite a few nightclubs which haven't gone on to exist for five years (not because of my onerous lists of remedial actions I should point out), and it would be quite unusual if the same management was in place after five years.

Incidentally, bi-annual means twice a year, biennial is once every two years (gardening knowledge - Foxgloves are biennial).

Stu

[lyledunn]

I think quinquennial ( non-gardening term) reviews for such places are bonkers. I inspect the electrical and fire safety services in such places and often find rapid deterioration and poor procedures. When it comes to recommending a re-inspection period, it is my judgement as an inspector that is important, not some generic recommendation made in whatever guidance.
The problem is that the IOs from the FRS  have brass buckles on freshly pressed uniforms, as far as the responsible person is concerned, that seems to make any thing that falls out of their mouths much more likely to be treated as gospel!

[AnthonyB]

I have come across a few FRS that have used annual for review.

Reviewing the existing FRA is, in my eye, a health check:
- Have you changed the premises since it was done (as often alterations are done without thinking about the FRA
- Have you changed workplace processes, layout, staffing, numbers and materials (etc, etc) such as to alter the potential risk
- Are the general fire precautions you said you had in the original FRA still there and still subject to the maintenance regime the FRA stated (& in good order).

The result may be:
- No further action, review again in 12 months
- Correct some deficiencies that have been observed (e.g. wedged doors, missed service visit), review in 12 months
- Full new FRA due to material changes.

I've come across this approach in the paperwork of a few nationals, especially in the retail sector, whilst others will redo the lot. It's also common in some nationals where the FRAs are third party, they review internally and only use the third party again if a full new assessment is required.

[Davo]

I used to carry out reviews of my FRAs to see if our Estates had done their works and get a feel for how well the place was managed, management changes so often!

davo

and yes Prof, I used to spot stuff I missed the first time, sometimes I could miss the bl**ding obvious

[lingmoor]

Ok hardly a nightclub! but the Department of Health NHS Firecode Part K states that " ...Whilst there is no maximum period between assessments, it is recommended that the review period should not exceed 12 months"

So every 12 months I do 'em... all 53...good job an all, the things I find!