I have to say that I'd approach this a different way?
We do have established means of dealing with this issue in the UK - staff registers, roll calls, fire wardens & sweeps etc. You say that the application of these is not 'possible'? I'd counter that it's always possible! It might be that it's not practicable (though I can't imagine why); it might be that the current management arrangements don't support it (change the management arrangements); it might be that it's simply unpalatable to those managing the premises (the worst reason not to implement them)? Lone working isn't automatically acceptable, for example.
Of course, I don't know the premises; I don't know the management arrangements nor how likely the occupants are to follow instructions / standard operating procedures, so I cannot possibly state whether the solutions we know and accept could be practicably applied. All I can say that what you've described as the current arrangements sound chaotic, & I don't understand why they must be like this? There are potential general health & safety issues with what you've described, never mind fire safety issues.
The only time I've come across anything similar is with military facilities where 'the normal rules don't apply' for various reasons! In this case I've found that the military staff who manage those facilities are typically extremely pro-active and are normally able to come up with workable solutions themselves, if you tell them what the basic fire safety objectives are - and are pretty good at enforcing them!
I don't want to lecture - but I genuinely cannot understand how the building can be safely managed as you describe. Perhaps if you give us more info on precisely why the current management arrangements have to be as they are, then we could explore further?
...there is no specific requirement in law to account for people in a building following an evacuation. So could the control measures detailed in my OP (in effect creating a safe person concept) ever be compliant?
I'm still mystified as to why the management of a building has to be as chaotic as you describe - it doesn't appear that further illumination is likely so I'll not continue to ask!
Those of us who've been around in the industry a while will almost inevitably have dealt with the '
show me where in the legislation it says I have to do this... question a number of times.
The truth is, when it comes to complying with the Law, the legislation doesn't have to be prescriptive as to what it practically requires, because it doesn't stand alone. If and when court action ensues, the measure of what complies with the law will take great account of relevant published industry guidance, and 'on-the-ground' good practice - often as advised by 'Expert' witnesses. The practical result of these in our day-to-day work is that we need to understand the relevant standards, guidance and good practice. We don't
have to comply with them, but if we don't we ought to be able to describe (in court if necessary) why it was not necessary, appropriate or practicable to follow that guidance and good practice, and also to state how an equivalent level of fire safety has been achieved by other means. '
Don't want to';
'Can't afford to';
'Would interfere with my business...' are amongst the worst excuses I've heard over the years - there have been many others.
The reason we put in place means to establish if a building has been evacuated in case of fire is so that
a) those managing the building know all their people are safe; and
b) so that when the fire brigade turn up and ask if there are people still in the building, someone present is able to tell them with some confidence whether there are or not. If they cannot, then they're potentially causing the Brigade to put people in harm's way unnecessarily. I would
never endorse this - I'm not a lawyer, but I would be concerned that this fails to comply with the Law as I understand it. Even if it were to comply with the Law, I would find it both morally and professionally unacceptable.
I'll climb down off my soapbox now!
