Tamper Tags. Do they need to be replaced at every service?

[nim]

Could the manufacturer?s instructions and BS5306-3 indirectly be considered as a statutory requirement for safety critical service actions?

Customer has complained about changing tamper tags saying:

?there is no legislation stating it is compulsory to change or replace tamper tags, certainly not for a visual test or if the person in charge of the extinguisher does not wish to have them changed.?

And

?a tamper tag is not compulsory in an office setting but is advisable on extinguishers in communal areas and stairwells and also prohibits the risk of pranks within the office. He (the Fire Officer) confirmed that tags will only be replaced if they are taken away to be re-pressured or inspected for rust.?

And

?there is no legal requirement to have tamper/security tags on fire extinguisher
It is down to the person who own the extinguishers to stop them being discharged and causing damage and also the cost of refilling(this could be expensive dependant on the type of extinguisher?

And

?....it is simply just part of a good practice to do so as it is one way of demonstrating a service has been done. Nevertheless, a label on the cylinder, a log book or an invoice are suitable indicators and sufficient evidence to demonstrate a record of service has been maintained. Therefore, it was not necessary for you to change all the tamper tags,?

We now know that some or all these words have come from a Fire Officer. Unless the Fire Officer is not competent and or he is lost in ?where necessary? the only thing I can think of is the customer because of the response told the Fire Officer that this was a visual inspection which it wasn?t. It was the annual Basic Service, the first time we had been to this site and now we wonder why (we know why) XYZ Fire did not go back and service this year?

We have quoted BS but been told it is BS.

As far as I am aware the manufacturer?s instructions and BS5306-3 are considered best practice, would be referred to by those that enforce statute and BS5306-3 is quoted in the Guidance Notes which are issued by the Secretary of State which are directly linked to legislation (RR (FS) O 2005).

Could the manufacturer?s instructions and BS5306-3 indirectly be considered as a statutory requirement for safety critical service actions?

I would consider changing the tamper tag along with a number of other service actions as a safety critical service action.  It ensures the pin isn?t damaged and can be removed if the extinguisher was required.

The safety pin is pulled, the tamper tag breaks, the safety pin is replaced and the tamper tag replaced. Our TT?s are yearly colour coded and branded as well. Would we leave a tamper tag unbroken, coloured differently and branded with another companies name? No. So do we leave the TT off and not replace it? The colour and the branding are in theory cosmetic until Fire Officer inspects extinguishers and notices XYZ Fire Tamper tags when ABCD Fire serviced recently and decides to prosecute.

The legislation bit may have originally been brought up by the customer and the Fire Officer could have expanded upon it. We are in the process of approaching the Fire Officer.

Although we think we know what we want to say are there any suggestions what we should say? I?m thinking 10 heads are better than one.

Thanks in advance.

[AnthonyB]

Stories of such customers do the rounds in the trade, often the opinion is walk away and let them use a ragger (or no one at all) until it all goes wrong as it isn't worth the effort.

There needs to be a suitable system of maintenance and the extinguishers need to be:
? In an efficient state;
? In efficient working order; and
? In good repair

(So says the FSO & Enforcers Guidance)

A suitable system of maintenance is BS5306-3 which requires the pin to be removed and replaced, secured with a tamper seal - or where the pin itself incorporates anti-tamper properties (Chubb Euro & FX clip & disc, Ceo-Deux cartridge valve clip & disc) the whole assembly (now broken) replaced. The Enforcement Guidance states where a British Standard exists for a fire precaution it is reasonable to require that be used for maintenance.

An alternative argument could be that the manufacturer provides suitable guidance for maintenance that whilst not to a British Standard will ensure that the equipment meets the three point test - however in relation to normal extinguishers every service manual I've seen still requires pin removal, tag breaking and subsequent replacement so that wouldn't work.

The visual inspection is the users job - any service firm using a visual check as a Basic Service would be potentially negligent. How can the user tell if an extinguisher may have been tampered with (& fail the three part legal test) without a tamper seal, particularly with CO2 and cartridge extinguishers.

If a customer doesn't want you to service properly and you don't just walk, I'd be tempted to just fill in 'Not Maintained' each year on the label and report.

And as for Fire Officers, did they put it in writing? (of course not!) If you know 100% this is from one perhaps you should escalate it.

Perhaps they want the service standard carried out here.....https://www.gov.im/lib/news/oft/servicingofporta.xml

It's always important to try and educate clients, particularly where they have been led astray by others, but there is a minority who just won't listen (usually where it saves them a few quid and hassle)

[kurnal]

Not many make it to the annual service as most are so frangible that they fall apart just looking at them. So the contractor gives the client a bunch of spares that rather defeats the point.

Tamper seals are essential on CO2 extinguishers as the only obvious indicator of possible problems.

[lancsfirepro]

As the chaps have already said, removing the pin and re-fitting an indicating device is part of the service (and commissioning) schedule as per BS5306-3:2009.  The standard states 'Reassemble the extinguisher in accordance with the instructions of the extinguisher manufacturer. Replace with new any safety clip and indicating device designed to show whether the extinguisher might have been operated.'  Interestingly enough, as per EN3, the requirement for an indicating device is quite vague and need not be a plastic tag; it can be a piece of wire if you like.  However, the force to remove the safety pin must be between 20-100N (2-10kg).

I would make two comments... Firstly, if the client won't let you replace the tag, mark the extinguisher as 'non-maintained' as Anthony has rightly said.  Secondly, in all my years in this business, I never once had a client prevent us from replacing the tags on an extinguisher; I'm guessing here, but are you one of those companies that charges the client for separate spares?  i.e. o-rings, gauge stickers, tamper tags?  If so, there's your problem right there.

[Fishy]

if the client requires that you maintain in conformance with the British Standard, then you have to do what the normative parts of the standard say.

If they have some other maintenance regime that they require you to undertake that involves non-replacement of tags (and you're happy that it's safe) then that's fine - what you can't do, though, is to assure that it's in accordance with the BS and neither can they.

There's nothing (in theory) to prevent anyone coming up with a different extinguisher maintenance regime if they are happy it achieves a level of safety equivalent to that in national guidance in their particular environment.  Some big infrastructure managers do this - they have their own internal standards that instruct you to ignore certain recommendations in the BSs (because they don't believe they're appropriate in their case).  You conduct the work to their standards, declare this and you don't claim that you're working to the BS - not a problem.

So, if you're happy that you can maintain the extinguishers to an acceptable level of safety without replacing the tags (and I'm not saying that this is necessarily the case - it's just to illustrate the point), then legally that's fine for you and the client.  What neither of you could do, though, is claim that they're being maintained in accordance with the BS, and you should both be prepared to explain why this is OK (in court if necessary)...

...which (to me) is a risk that doesn't seem to be proportionate to the cost of a few plastic tags, does it?

[nim]

Thanks all for your replies.

I appreciate we all charge differently when we service extinguishers. Yes we do charge for tamper tags. This job was in Central London. Parking is a problem for us all but when you have to pay ?11.50 Congestion Charge and ?6 an hour for parking  and you have done ?50 a day just in parking and CC then someone has to pay for it. We are talking about a firm of solicitor who are a stones throw from the Royal Courts of Justice and Lincolns Inns Fields who at a guess most probably charge in the hundreds for an hour?s labour.

Although our disagreement is with the customer and to be honest,  to us  the issue isn?t about the cost our real issue is with the Fire Officer basically telling the customer they can pick and choose how we service the extinguishers and  there is no recognised way to service extinguishers and then expect a certificate saying the extinguishers have been maintained to BS5306-3.

Fishy. Agreed we can maintain to the customer?s specifications and we do and  where we service, supply a report with costs and the customer accepts or rejects will be to the maintenance to the customer?s specifications.

The customer never raised the issue until we had left site and with hindsight were most probably a bit sneaky. I have a feeling they have been here before and although we didn?t give it much thought at the time have you  ever been  to a site and seen 4-5 labels over the last 4-5 years and maybe smelt a rat.

As I see it Not Maintained is not an option as it only applies where the competent person does not have the parts  to carry out the maintenance and the only service action left is Condemned.

If we were discussing a non safety critical service action then I could understand but pulling the pin in my opinion is a  safety critical service action. Yes we could do a visual but we would get slaughtered if it went to court and the extinguisher didn?t work because the pin was bent and XYZ Fires tamper tags were still on the extinguishers.

[Davo]

nim

colour changes are great as the service sticker is often stuck out of sight and unhinging the b8ggers to check is a pain.
I don't disagree with what you say apart from the last bit- don't forget the service is only good at the time, pins can be bent half an hour later when eg moving furniture or vandalism

davo

[nim]

don't forget the service is only good at the time, pins can be bent half an hour later when eg moving furniture or vandalism

davo

Agreed but with another companies TT's still in place would leave us wide open and we definitely couldn't blame vandalism or carelessness even if it did happen after the service.

[nearlythere]

I have a level scepticism rightly or wrongly about some aspects of annual checks and pulling a pin to see if it will pull out when it can be clearly obvious to many that there is no rational or obvious reason Why it won't. If the pin is straight, free from corrosion and still has the tag intact is it likely from what you can see that it will not withdraw.
Why not momentarily operate the equipment as well as there is more likely to be a defect in the inner mechanism which cannot not be seen and can go undiscovered for up to 5 years, and 10 in some cases. Just a quick half second squirt adding up to 2 secs in total between discharge tests ain't going to make much of a difference to the extinguisher duration. Maybe not powder though which maybe shouldn't be there anyway.

[lancsfirepro]

If the handles of an extinguisher receive a knock on the top, this can be enough to bend the pin (with little to no apparent damage) sufficiently to make withdrawal difficult.   Its not that easy to see a bent pin when it passes through the handles.  Have you received any training at all in servicing fire extinguishers?

[Mike Buckley]

I cannot help bu feel you have made a rod for your own back by charging for the tamper tags as a separate item. If they are part of the service regime just include them in the price of the service. As far as the other bits are concerned such as the o rings etc. then obviously they would have to be replaced as and when they fail and a separate charge should be made.

Parts that need to be changed as part of an extended service should be included in the cost of the extended service.

I am not sure about the actual cost of an individual tamper tag but if it is challenged when included in the service the answer would easily be 'Okay you don't want the tags changed. It will reduce the overall bill by ?0.20!'

And no I do not service fire extinguishers before the question is asked!

[lancsfirepro]

Work on 2-3p per tag Mike.  
We price for the service, which is mainly our time, consumables are negligible.  From my experience, clients do not like it when they are charged for bits and bobs.

[Mike Buckley]

My point exactly!

[AnthonyB]

"Just give it a squirt every year" 

And yes it is possible to have bent/damaged/jammed pins that are only found on attempts to remove.....

Whilst BS5306-8 is full of "by the trade for the trade" stuff, part 3 has largely remained a 'pure' document based on solid fact and experience that has been amassed over the decades (I have servicing information from over 50 years ago and several basic principles remain). If followed as written it doesn't sell new equipment unnecessarily - that's down to cheap imports and corner cutting by firms who don't train and equip staff to open up & recharge extinguishers anymore.

Whilst there are some charging practices that extract a lot of money out of customers that's nothing to do with the servicing standards.

A greater problem is the fact that, partly due to multitasking and the growth of do it all FM,  the industry is full of firms and individuals who do not service extinguishers properly and do not know how to deliver risk appropriate guidance on the selection & provision of extinguishers and are pushing out those that are proficient. In some cases sites might as well have P50 extinguishers as some service firms would not carry out equal or better checks if the sites had normal kit.

[nearlythere]

And there was me thinking that this forum was about offering views and opinion which could well go against the rub of current thinking. Clearly not so. Probably best just leave it to the pontificator to get on with it.