Matthew - My source is the Regulatory Reform (Fire Safety) Order 2005 and from conversations with a former colleague who was involved in compiling the Order
Article 3 -
Defines what is meant by the term 'Responsible Person'. There is no requirement in this article for the RP to be competent set out in this Article
Article 8 -
States that the RP take such general fire precautions as will ensure, so far as is reasonably practicable. There is no requirement in this article for the RP to be competent set out in this Article
Article 9 -
States the RP must make a suitable and sufficient assessment of the risks to which relevant persons are exposed for the purpose of identifying the general fire precautions he needs to take. Again, there is no requirement in this article for the RP to be competent set out in this Article
Article 18-
States the RP must ...... appoint one or more COMPETENT PERSONS (my capitals) to assist him in undertaking the preventive and protective measures*.
*Just to be clear; Article 2 defines "preventive and protective measures” as the measures which have been identified by the responsible person in consequence of a risk assessment as the general fire precautions he needs to take to comply with the requirements and prohibitions imposed on him by or under this Order
(in other words, competent persons are bought in after the FRA has been completed to deliver the findings)
Article 18 goes on.........
A person is to be regarded as competent for the purposes of this article where he has sufficient training and experience or knowledge and other qualities to enable him properly to assist in undertaking the preventive and protective measures.
Just to repeat, the RR(FS)O was designed to allow owners (RPs) of small low risk businesses to complete their own FRAs and the Govt provides easy to rad guidance for the general public so this can happen.
If the RP had to be competent, then Mr & Mrs Smith at the local corner shop would have to get a consultant in. But the RRO allows them to complete the FRA, but:
1) The FRA must be suitable & sufficient, and;
2) Anyone bought in as a result of the FRA (fire alarm engineer, emergency lighting electrician, fire trainer etc etc) must be competent
Hope this makes a bit more sense
http://www.legislation.g.../2005/1541/contents/made