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#1 Posted : 26 November 2006 20:46:00(UTC)
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Posted By shaun mckeever I have been tasked with the evaluation of fire risk assessments for a large property management organisation who have a large number of tenants (all commercial premises). Any reader on this forum will know that I hold fairly strong views about fire risk assessments. I have seen some very good templates and some downright awful ones. I want/need to be as impartial as I possibly can. I would like to invite members of the forum to express their views on what constitutes a 'suitable and sufficient' fire risk assessment; for example should an emergency plan accompany the fire risk assesment; should the risk assessment include what control measures are in place; should the assessment include the risks created by other organisations if they have a potential impact on your safety. I know only the courts at the end of the day can decide if a fire risk assessment is 'suitable and sufficient', but I would be interested in the views of readersof this forum.
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#2 Posted : 26 November 2006 21:56:00(UTC)
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Posted By Derek Housley Hi Shaun, A Suitable and sufficient Fire Risk Assessment would very much depend on the premises, use, size, occupancy. British Standard PAS 79 is a good starting point, but in some cases it would go into too much detail, in other cases it would need to be expanded upon. As you are aware the thrust of the fire risk assessments, is to drive down risk, and my expectation is as they are reviewed and revised they will become expanded, and cover areas where they have previousley light on detail. There is a danger of the false perception "the bigger the better" and risk assessments becoming a photo-copying exercise. Record the signicant findings, act upon them, and share them with the buildings users. In this way the Risk Assessment will contribute to driving risk of fire ALARP. Follow on risk assessments reviews will know doubt pick up other issues as all risk assessments do, when the building use changes. Derek
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#3 Posted : 26 November 2006 22:06:00(UTC)
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Posted By paulfriend Why are you seeking the views of this forum ? Your question seems very loaded ?
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#4 Posted : 26 November 2006 22:41:00(UTC)
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Posted By shaun mckeever Paul at some point in the future a judge will make a decision as to what constitutes 'suitable and sufficient'. Nobody I speak to is clear as to what defines a 'suitable and sufficient' FRA. I myself hold very strong views, perhaps too strong views. What I am looking for is reasoned argument as to what would define a suitable and sufficient FRA. I can foresee me rejecting a fire risk assessment carried out by a tenant and then being challenged as to why I rejected it. I feel if I reject a FRA I will be able to support my decision, but the tenant may feel I am being unreasonable. What I want to do is take a reasoned approach rather than be biased because of my strong views. I am prepared to listen to what others think on this forum.
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#5 Posted : 26 November 2006 22:55:00(UTC)
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Posted By paulfriend Shaun, I have seen many of your responses on fire risk assessment issues over time and you do hold strong views and you clearly have in depth expertise on fire safety issues. So do you have an open mind on this issue-given your strong views ? Paul
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#6 Posted : 27 November 2006 01:04:00(UTC)
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Posted By shaun mckeever Try me!
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#7 Posted : 27 November 2006 07:58:00(UTC)
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Posted By Peter Leese If you look up a couple (or more) LFA sites you'll find risk assessment forms in abundance. If I were defending a client who had been told his/her assessment was inadequate I would put forward in evidence a number of those LFA forms. The court would be told the forms represented the required standard to be achieved. From the competence point of view I would quote DTI evidence saying that in general achieving fire safety is common sense, as long as assessors put aside enough time to work through the various steps. And that in more complicated premsises more expert help may be needed. To your specific questions: Providing an emergency plan is not part of the risk assessment, providing the plan would be a requirement of the risk assessment. No forms I have ever seen from an LFA consider the neighbouring premises as a source of fire. A risk assessment is not complete if it doesn't contain details of the existing control measures?
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#8 Posted : 27 November 2006 07:59:00(UTC)
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Posted By Phillipe Hi Shaun The whole FRA process is a difficult one. A point has been made that sometimes the bigger the organisation the better they are done. I would say that this statement may be true to a certain degree, however in some cases this does not hold any validity. I would expect, whether rightly or wrongly I don't know, that a large organisation will be more pre-disposed to "funding" a suitable and sufficient FRA than perhaps a smaller, business, i.e. fabrication work shop in rural Derbyshire for instance, who may be ignorant of the law change (not in all cases I hasten to add). In my experience working for a large organisation we seem to be more prone to FO inpections in the first place, therefor we get on and do the assessment. The point you raised regarding emergency plan being part of the assessment is a good one. In my opinion it is a integral part of the FRA and should be included. I have developed my template for the FRA which includes a final section that requires the EP to be inserted at the rear of the document. This shows that it has been thought about as part of the holistic approach to managing fire safety within the demise of the building to which it applies. The EP is also attached to staff notice boards along with other relevant H&S information. It would be interesting to see what does constitute a suitable and sufficient FRA should one come before the "beak" but until that happens I suppose we are all in the dark. I have had quotes ranging from £100,000 to £180,000 to conduct FRA for our premises, from a number of consultants. To me, that does seem an awful lot of money for what is largely seen by many people as a paper exercise without any immediate payback. It is not like our insurers are going to reduce their premium based on the fact that we have complied with a piece of legislation, and given the fire safety record of our business, with the notable exception of one arson attack 4 years ago, it is hard to justify that kind of spend. Having said that, we are more or less compliant with the new legislation or certainly in the spirit of the legislation at least. Phil
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#9 Posted : 27 November 2006 16:36:00(UTC)
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Posted By Ashley Wood Hi Phil, I know we have spoken in the past about fire risk assessments but the figures you mentioned are huge. Was it a miss print or did you actually mean 100k -180k? If you did then I think you are correct to criticise. Why not break your property portfolio down into regions and ask for tenders for each region? Specify the guidance format that you want to be followed i.e pas79 etc. That will at least keep the reports similar. Some consultancies are charging crazy prices. This could be caused by a great many factors such as 'to much work' so they price it not to win, if they do win then its a big bonus, overconfidence in their market position i.e the big fire consultancies or it could be down to the good old fashioned 'greed' factor! All the best Ashley
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#10 Posted : 28 November 2006 23:27:00(UTC)
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Posted By shaun mckeever OK Peter, I don't think it is so much about the templates that can be found in abundance. The guidance notes issued by DeCLoG gives sample risk assessments. The problem is that people are filling them in without really knowing what they are filling in. As a simple example that I often come across in the buildings managed by my client, tenants are ticking the box that says 'fire doors are kept shut'. When I look at the doors they are often not fire doors or have added door furniture such as digital locks which render the doors no longer compliant with the requirements for fire doors. When I see this should I reject the fra because clearly the assessor does not know what they are looking for in a fire door and therefore cannot be considered to be competent or am I being too harsh? The premises do not have to be complicated for simple items like this to be overlooked. You are right achieving fire safety is common sense, but if it is common sense why are there approximately 600 deaths and 14000 injuries from fire each year. Insurance losses run into billions. I know fire authorities are rejecting fire risk assessments unless they are accompanied by an emergency plan. LFA forms may not specifically address risks created by others but they do generally have a section that allows for other considerations. PAS 79 certainly does. Let me give another example. If a ground floor tenant are a laboratory using acetone (many laboratories do) and they have a tendency to wedge open the fire door onto the staircase then the occupants above the ground floor are being placed at risk. My view is that this must be included in the fra of each of the tenants above the ground floor. You cannot be suggesting that it be ignored. I agree with the control measures bit. Phil, we seem to agree with respect to the emergency plan. As far as the quotes you have had I wouldn't know because I don't know what was quoted for but I imagine that it is like most other things, you get what you pay for. Do you want the Rolls Royce or do you want the Skoda! I know that I have saved an organisation £250k. The client in this case paid for a 'cheaper' consultant who made a recommendation. The cost of the recommendation was £300k. I was asked for a second opinion and although the first consultant was right there was an alternative solution which only cost £50k. So sometimes you get what you pay for! Bit disappointing that no-one else is contributing. I am sure some of the assessments I will be evaluating will have been written by readers of this forum. I'm sure if I reject them something will be said then.
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#11 Posted : 29 November 2006 08:56:00(UTC)
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Posted By Peter Leese Shaun, don't be surprised if people don't contribute. Many don't want to be shot down in flames (intended). Hope you don't mind me saying so but the strong (what I would call aggressive) tone puts people off. For example, I didn't say I didn't take external factors into account, I said I haven't seen an LFA form that takes them into account. You've immediately challenged me on that point, as though I'm saying the same thing. I'll close the door behind me.
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#12 Posted : 29 November 2006 09:42:00(UTC)
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Posted By Charley Farley-Trelawney Shaun You start by saying you have been tasked with the evaluation of FRA's for a management company. Is this to go in and look at the existing FRA's (created by others)and make suitable recommendations to either improve or update. Was the original FRA part of a survey that now requires action to be taken and you to create a working FRA/Log/Procedures system? Be interested to know before commenting further. CFT
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#13 Posted : 29 November 2006 11:33:00(UTC)
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Posted By Phillipe Ashley Just noticed your contribution. That was not as missprint with regard to the 180k cost. That was from a couple of consultancies we spoke to. The assessments we have done internally, have been generally well received by the a number of Fire Officers who have expressed an interest in looking at them. Shaun The emergency plan as far as I am concerned is a integral part of the assessment. It fits in well with the arrangments element of the assessment. Phil
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#14 Posted : 29 November 2006 12:28:00(UTC)
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Posted By Jim Walker I think we need to decide if we are protecting occupants and fire fighters or buildings. I always on training when fire is discussed and using extinguishers are concern say "get out and let the building burn, as its is unimportant". Of course. its always best to prevent the fire in the first place where possible.
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#15 Posted : 29 November 2006 13:26:00(UTC)
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Posted By Steve Conway In helping to decide how we proceeded with our fire risk assessment I found the following audit checklist from the Chief Fire Officers Association useful - http://www.cfoa.org.uk/c...=47&aid=2564&st=&oaid=-1 Steve
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#16 Posted : 29 November 2006 18:42:00(UTC)
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Posted By Pugwash Shaun My view is that your approach is pretty unreasonable. You are going completely over the top and trying to gold-plate the regulations. We are effectively replacing fire certificates with self assessment. If the building occupier can achieve, through his risk assessment, at least the standards of fire safety which the fire service achieved through their regime of certification and inspections then we have succeeded. I have accompanied many fire service officers on their inspections of premises (both under fire certificates and under the risk assessments from the Workplace Regulations) and never have I seen one who picks up on the sorts of issues which you are raising. They look for the simple stuff (do the fire doors close rather than whether they meet a particular standard). I have also brought in fire safety consultants/engineers to advise on specific problems and then I have seen them tackle your sorts of issues (and we expected them to given the high days rates they were on). You clearly know what you are doing but there are just not enough people in the UK with your level of experience to carry out all the risk assessments which are required. Therefore it is unreasonable to expect the standards which you are looking for. With the new legislation the Government are looking to maintain current standards of fire safety and then perhaps steadily improve them. They are not looking to bring about a step change improvement overnight. The danger however is that standards might slip from current levels so it will be interesting to see how the fire services carry out their inspections under the new legislation.
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#17 Posted : 29 November 2006 19:45:00(UTC)
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Posted By Crim Shaun, I think we have "locked horns" before. Not this time I hope? My view of the required risk assessment is as per my guidance document as issued by HM Government and purchased from the Dept of Communities. The sample fire safety risk assessment they use is based on the 5 point plan that I'm sure you are already familiar with. The guide is aimed at a "responsible person to help them carry out a fire risk assessment in less complex offices and shops". Other guides are available to cover the other types of premises. It goes on to say that more complex premises will probably need to be assessed by a person who has comprehensive training or experience in fire risk assessment. I would suggest that more complex premises would mean multiple occupancy or more than a couple of floors where means of escape may be complicated. There will be other examples I'm sure? I consider myself to have that comprehensive training and experience but have never looked beyond the guide when carrying out a fire risk assessment. As far as I am concerned if we 1. identify the hazards, 2. then the people at risk, 3. then evaluate, remove/reduce and protect from the risks, 4. then record, plan train etc. 5. then review at regular intervals that is all we need to do. We are not members of the building control department, nor are we members of the local authority fire services who are supposed to be experts in their respective fields. Health and Safety in general and Risk Assessments in particular are aimed at protecting persons from harm, not preventing property damage. Fire damage will depend upon the type of fire, the integrity of the building and the actions/commands of the first fire officer to attend. My advice to you is to ensure the occupants are looked after and safe and they can escape from the premises safely and then call the fire service. "Get out, stay out, call the brigade out". The risk assessment should include an emergency plan if one has been provided, if not it should be a recommendation, Existing control; measures should be included, The assessment should take into account risks posed by other organisations if they could have an impact, A long winded reply to your initial question but one I feel necessary to assist you in your task. I would be happy to have a look at some of the assessments if you would like a view from me, just email and I will be happy to help.
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#18 Posted : 29 November 2006 20:43:00(UTC)
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Posted By Crim Shaun, A thought has just struck me - self regulation replaces certification therefore premises that used to have a certificate were inspected by fire officers so the building would be as per their requirements. Newer buldings are built according to high specifications therefore building integrity should be no problem? That leaves those smaller premises i.e. offices and shops, that were not certificated but due to their smaller size should not present us too many difficulties where fire assessment is concerned.
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#19 Posted : 30 November 2006 16:07:00(UTC)
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Posted By Peter Leese I'm in agreement with the last few postings and especially Crim's. I can't remember the exact words of a contributor in response to a similar thread started by Shaun but they were to the effect that if we move risk assessments out of the reach of the ordinary person then we move H&S out of reach also. Which is another idea I subscribe to. Surely it wasn't the intention that FRAs have to be carried out by experts? Although a professional fire consultant might subscribe to that! Common sense - Shaun you quote or at least indicated that the lack of common sense was the major cause of fires. Would you care to come up with some statistics in the office/commercial services environments that would support that view?
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#20 Posted : 08 December 2006 18:18:00(UTC)
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Posted By shaun mckeever Sorry, I've been a bit busy lately and have not been able to respond. The issue has become a bit irrelevant now because I have resigned to take up a new post but I will read through the responses and try and reply. Peter, a bit surprised that I have come across agressive, I'll try and mellow a bit - I'm quite friendly and approachable really. CFT - you are right it is/was about going in and looking at tenants FRA's and feeding back to the landlord the adequacy of the assessments. The landlord wants to make sure that tenants are not putting at risk the occupants, firefighters or asset. Jim, I think it is all of those, occupants firefighters and building. I think there is a level of reasonableness with respect to tackling fires. I'm sure most people would not turn their backs on a small flickering flame but they would on a raging inferno. Somewhere between the two comes a point when you will turn your back. Pugwash, thanks for your views. I hope I am not going over the top. I am putting forward many years of fire enginnering experience together with 20 years firefighting experience. Fire certification was effective for the buildings they applied to but many of the earlier certificates are not worth the paper they are written on. Many do not reflect the current building arrangements and as technology has progressed there has been some realisation that, for example, fire doors with 1" fire stops were not that effective. When I was an inspecting fire officer it took me a good two years before I had any real knowledge of my trade. You will find many fire officers are very inexperienced and do not compare with a professional fire consultant, on the other hand there are many very good, very experienced fire officers. These generally become the best fire consultants (hrrrmph!). I am not looking for the standards that I may set, I know that is high, however I would expect them to have read the published guidance and apply that standard at the very least. What I don't like is shop managers who have been dumped on by their head office. My goal would have been to make sure that those who do carry out their own FRA's are familiar with the published guidance, that is both Part 1 and Part 2.
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#21 Posted : 09 December 2006 00:41:00(UTC)
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Posted By Ken Taylor Shaun, the answer is 'Yes' to the inclusion of the items you put forward in your posting. I also think it useful for the risk assessor to record information in response to posed questions rather than following the simple tick-box route - so that upon reading the document you will know such things as: the name of the fire controller/warden(s); what the fire action plan says; where and how the fire procedures are displayed/made known; where the assembly point is; the date of last fire training; when the extinguishers were last serviced; when the last fire drill was held; whether AFD is installed; when the electrical installation was last checked; etc, etc. This has the effect of getting the assessor to look into each aspect of fire risk and control, to make enquiries and to keep records up to date - in addition to listing the significant fire risk areas and activities, of course.
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#22 Posted : 09 December 2006 22:17:00(UTC)
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Posted By Red Ones This is a question I am currently asking myself. As the representative of the Landlord I need to reasure the Landlord that the tenants are doing their bit. HOWEVER I have no legal standing to accept or reject an assessment, I can only guide / advise and the tenant is free to ignore if they so choose. I can ask to see, I can demand to see the FRA however I cannot state that it is definitely insufficient, I can ASK that they consider additional items. I am in fear of demanding a sufficient FRA and then leading myself to demanding to see Emergency Light check records, Sprinkler test records, Fire Alram test records, service agreement etc - All stuff that they should be doing and so long as I periodically remind Tenants then I am fulfilling my responsibility and showing due diligence. I am increasingly coming to the conclusion that my role is to do what the FO used to do - check that Fire Exits are clear, signage is correct that Extinguishers are maintained etc. Then to ASK "Do you have a FRA, where is it?" But to leave the question there and only probe further if I suspect something is amiss. I too hold very strong views on FRA and Fire Safety, however, the more I think about it the more I think it can set a precedent whereby as Landlord I end up taking on all the responsibility that the Tenants should have.
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#23 Posted : 10 December 2006 11:01:00(UTC)
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Posted By Crim Hi Red Ones, I fully understand your plight. I act as advisor to clients mainly in the construction trade, and others beside, and recently experienced some of those clients not taking heed of my advice and guidance. I became very frustrated by this and decided to drop the main "offenders" and this gave me less stress. I now have less work/income but don't get so frustrated. I have recently carried out FRA's under the new regime, as one off's for new clients and have left them with the responsibility for taking the recommended actions. If they wish me to revise the assessments after 1 year they have my contact details.
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