At what point should the fire risk assessment of a new facility be carried out?

[SeaBass]

Thank you Mr T. You have reinforced my thoughts on the matter. But the various postings in this thread, and particularly Wee Brian highlighting paragraph 2.40 of the ADB guidance, shows what confusion there is, about what should be  a very clear and simple procedural matter. It is inconsistencies such as this that lead to confusion and cause RPs to question the advice and guidance that they receive from their consultants.

And as for you Mike Buckley, when has 'going off topic' ever been a risk on Firenet? it's an absolute dead certainty with CT and his English Ff paranoia and dewy eyed memories of Scotland.  Just look at this thread, I ask about intervals between occupancy and the FRA taking place, and we've covered second hand car sales men, broken promises, English Vs ,Scottish National traits, the assessment of vacant premises, pre occupancy appraisals (They aren't, and can not be, fire risk assessments in the terms of the FSO) and........... Now I'm doing it!

[colin todd]

I don't think its that far off topic.  The point is you might get assurance from the FRS that its ok not to have a day 1 FRA, but you cannot trust that guidance (in England).  I was merely using analogies better to advise SeaTreble.

And if the all powerful wise and wonderful Mod will let me digress (just a tiny bit) in responding to Buckers, its true that the Campbells were the instruments of the dastardly deed, but King William signed the order (not the fire safety order, you understand) and Colonel Hill gave the instruction.  He was from Kent and he did prevaricate a bit (somewhat like Kent do today in response to AFAs).  But two soldiers had the balls to break their swords and not carry out an order they knew was wrong, which the officers of a North West FRS did not have, as in my anecdote.  It was held in the court martial that a soldier does not have to follow an illegal order.  It took over 200 years for the rest of Europe to come to the same conclusion at Nuremberg.

[SeaBass]

I give in!

[colin todd]

But I did give you the answer to your question, oh Marine Life one.

[Fishy]

Is it not unlikely that relevant persons would be put at risk in an unoccupied building?

We were criticized during a BAFE audit for issuing BAFE certs on unoccupied and buildings under construction.

It may have been better to say the RRFSO may apply but the FRA would not be required until the building is occupied?

The FSO makes no distinction between occupied and unoccupied buildings, and even if it's a building site it is also covered under that Order. The 'relevant persons' might include (for example) maintainers, or estate agents and the people they're showing around, and may also include persons in neighbouring properties, one of the definitions of "relevant person" being: "...any person in the immediate vicinity of the premises who is at risk from a fire on the premises..."  Whilst we've not been informed precisely what BAFE's criticism was based upon, I see no justification for it?  If it was because they believe that the FSO doesn't apply in those situations, it might say more about them than it says about you!

Back OT, whilst we generally only deal with the design and construction stages we always make a recommendation in our fire strategies that the relevant RPs conduct a "pre-occupancy fire risk assessment".  Whilst you arguably can't complete a fire risk assessment before the building is in use, nothing to say that the process can't start before you actually occupy that premises (you could check commissioning certificates, for example).