FRAs on empty property?

[William 29]

Can an FRA be enforced on an empty property? I am aware that any fire safety provisions would need to be maintained, fire alarm, emergency lighting, sprinklers etc. But what about the FRA itself as it is likely to say very little. What Article ref would be used?

Thanks

[AnthonyB]

The Enforcer's guide says it can - one of the reasons they included owners as RP's was to catch empty properties.

So article 9 comes into play,  plus any other relevant articles deemed not to be complied with relevant to the risk. Relevant persons are not just those lawfully on the premises (but interesting not trespassers unlike Occupiers Liability) but those in the vicinity that may be affected by fire so even if a building is empty there could be persons at risk to consider.

Whether you could actually require a written record would no doubt fall to whether the criteria in Article 9(6) were met.

Whether a lack of an FRA in an empty building would meet a fire service's threshold for enforcement is another matter.

[William 29]

Thanks Anthony.
I was coming from a client's view where we are now in a very nervous place post Grenfell and they have empty buildings and are asking for FRAs. My view is we can do them but they are not likely to say very much. Also under the BAFE SP205 scheme you shouldn't really issue a BAFE Cert with the FRA on an empty building, BAFE rules, not mine as its a life safety scheme.

[Messy]

Then don't issue a BAFE Cert and record why in the FRA

After all its a nice to have and not a need to have

[AnthonyB]

Whilst we do do specific FRAs on empty buildings where a client insists on it, usually due to the minimal output of an FRA in these situations we can cover the essential FSO requirements as an extended section in the H&S Liability Audits that we provide for empty sites.

As you allude to as there isn't much content so it seems wrong for most sites for the client to have to pay for separate reports unless there is something that would trigger a real need, which the H&S staff would pick up in their visit and recommend appropriately.

[Fishy]

The FSO makes no distinction between occupied and unoccupied (empty) 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...".  Whether it needs to be written or not depends upon  how many persons the RP employs.

So... I guess the answer to the OP is "Yes"?

[nearlythere]

I suppose the main issue would be the effect that an outbreak of fire in an unoccupied property could have on others in the vicinity e.g. next door or even in the wider community.