Had fire risk assessments completed on all my buildings this time last year by an external consultant. All action points (minor) have been completed satisfactorily. There are no changes to the building layouts or the function or tasks undertaken inside them. There are no changes to outside areas.

Annual review now due. Do I need to spend hundreds of pounds again this year on fire risk assessments by an external consultant or is there another way of recording that a review was undertaken and there were no changes. I am not qualified to carry out fire risk assessments myself.

It seems to me that if there are no changes then why spend hundreds of pounds.

Where do I stand and what is the law please?

Hi MrsSheila,

Legally the FRA's need to be reviewed by a competent person, so if you are not competent to do them yourself, then I think you are left with paying for an external consultant.

As you have said, you are not qualified to undertake them, so there is potential that you are not aware of any changes in the circumstances that a fire risk assessor would be.

There is nothing specific in law for 'annual reviews' of fire, or any other, risk assessments. Neither is there is little consensus of what a 'review' actually is, or should be.

Ian has nailed it in general terms if there are no changes; simply annotate "reviewed FRA on (date), no changes". That is the easiest to deal with.

There should be no need to engage an outsider to tell you what you already know. In fact, how would a consultant know what, if anything, has changed, without spending a disproportionate amount of time going through the original assessment findings. Which will take, and cost, almost the same as the original.

Who determined an annual review was required? Would it, by any chance, be the FRA consultancy?

Tick boxes are not my expectation of FRA findings from a specialist consultancy.

Why not determine (and state) that any relevant changes will prompt a review, and leave it at that.

Mrs Sheila, I'm not clear from the post, but I'm guessing that you are the responsible person.

I agree with the majority of posters.

If it was an in depth FRA that was completed, you would be in a position to review it, although with the caveat, as raised by David, if it was a tick box exercise it might be quite difficult to review.

I don't agree that you would need to get a consultant back in to review it. The ground work has been done and a good FRA will make it easy to be reviewed.

My view is that it would be the ideal world if everything stayed the same! However when there are significant changes then it would take a competent person to ensure that the additional or new protective measures required were adequate.

PAS 79 provides a simple template for FRA reviews which includes - checking that previous actions have been implemented and carrying forward those that have not as well as any new actions to address significant changes regarding - changes in the premises, use of premises, management, occupancy, any new legislation, fire hazards, fire protection measures, means of escape, FFE, evacuation procedures, etc, etc, etc.

Regarding frequency of reviews, we have had many discussions with the Fire Service and we review sleeping accommodation annually and all other educational building and offices every 2 - 3 years.

We also review all of our sleeping accommodation premises annual, purely on an organisational policy standard.

If my suspicions are correct, the OP may have sleeping accommodation premises.

Mrs Sheila, you coud pay me thousands of pounds to review them if you like but that would be wasting your money, IMO.

It would appear that all action items have been cleared and as you seem happy with the situation simply have a look around while reading through the assessments you have and sign off the assessments as reviewed and date them.

There is no set time for reviewing fra's this depends on the type of risk, some may need reviewing daily others may be two or three yearly.

Sometimes the fire risk assessor may state annually expecting a call to review them.

It is your choice but it appears that you could quite happily review yourself.

A couple of points worth noting from this thread, first, you may not be competent to carry out FRAs but does that also mean you are not competent to carry out a review? Given that there is likely to be no change within a year I think someone with a basic knowledge of FRAs could be competent to carry out a desktop review.

My the other point is the level of risk. If for argument's sake all the FRAs have come out a low risk then is there a need to review them all annually? I would argue not. That said, if the consequences of a fire are high risk - for example, a care home or similar, then there could be a good argument that even low risk FRAs need to be carried out on an annual basis. It's all about the risk.

Sorry Matthew, this 100% incorrect, a common misinterpretation and one (like compulsory annual reviews) that is often banded about by consultants to keep their workloads high.

The RP must appoint a competent person to apply the preventive and protective measures - ie those measures highlighted by the FRA. So training, installing and maintaining the fire detection and EL systems must be carried out by a competent person, but the FRA does not need to be.

This allows the RP of low risk SMEs to do their own FRA as part of the rationale of moving away from Fire Certificates was to reduce the burden on industry. Why do you think the Govt have spent tens of £1000s issuing their FS guidance documents? A Competent Person would have the necessary training and experience and have copies of ADB and BS9999 to hand so wouldn't necessarily need the guides.

Of course, the FRA produced must be suitable & sufficient - but how hard is this for a low risk small businessman who has to deal with other 'admin' such as HMRC returns, the VATman, Insurance companies and staff pensions?

Mrs Shiela

If you decide not to review your FRA yourself, I will undercut Firesafety101's criminally extortionate quote (post 13) and save you £££££s as he is not to be trusted :) :)

Seriously, with most low or medium risk premises, walking around with an existing FRA and recording your findings (even if zero) may well be sufficient

Good luck

Invictus, I was questioning why the FRA does not need to be completed by a competent person, which was stated by Mssy.

IMO the FRA needs to be done by a competent person, whether that is also the RP or not. But my understanding of what Mssy has said is that the person conducting/reviewing the FRA does not need to be competent

That might be correct but you started your response by saying "sorry Matthew, but this is a 100% incorrect" but it was your own statement in the first place in #3.

Mssy was quoting you!

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

Mssy is spot on, as usual.

You always know that he/she is giving good advice.

FS101,

In 19 I mentioned that I would not be happy an incompetent person doing a review of the FRA.

And at the bottom I also say that personally I would rather an incompetent person did a review of the Emergency lighting checks (effectively flicking a switch) than reviewing the FRA! This was in response to a previous comment from another user.

My point was that IMO an incompetent person is less likely to do harm by reviewing EL, that reviewing a FRA!

Of course they have to be competent, but the level of competence required for a review is very different from the level of competence required for the initial assessment, or at least it is in fairly simple premises.

I've mentioned what we do with our retail premises here; we are going to do the same with our (mostly very straightforward) office premises.

But at my last place we had care homes and hospices which were forever changing the use and purpose of rooms and so on. One of my team felt that we couldn't do 'reviews' as such as the risks were high enough, and the constant change was significant enough to require a fresh FSRA every year or so. I was undecided, but his arguments weren't easily gainsaid.

So where you have vulnerable people sleeping in, other high risk activities (DSEAR stuff, hot works and the like) you might well want a specialist fire risk assessor. Otherwise you can give somebody some training and a simple well designed tool. Both those people can be competent, but competence depends on context as much as on personal qualities,

John

Would I allow them to complete a full RA review whilst incompetent? NO.

Would I allow them to complete parts of it, I.e. testing the emergency lighting? YES.

I think you are clearly missing the point!

I was saying that I would prefer someone to review a RA for EL, than review a FRA. There are plenty more that can go wrong with a review of the FRA, than the EL RA. That is not me saying I would allow it, that is saying than IMO I would rather them perform a RA review on something like EL than a FRA.

Thanks everyone - most informative as always.

In Scotland:

Regulation 17 of The Fire Safety (Scotland) Regulations 2006 mirrors the H&S Management Regulations, including:

Safety assistance
17.—(1) The person with duties under section 53 or 54 must, subject to paragraphs (5) and (6),
nominate one or more competent persons to assist him or her in undertaking the measures
necessary to comply with the Chapter 1 duties.

And s.53 and 54 Chapter 1 duties of Fire (Scotland) Act 2005 include:

Duties of employers to employees

(1) Each employer shall ensure, so far as is reasonably practicable, the safety of the employer's employees in respect of harm caused by fire in the workplace.

(2)Each employer shall—

(a) carry out an assessment of the workplace for the purpose of identifying any risks to the safety of the employer's employees in respect of harm caused by fire in the workplace;

(b) take in relation to the workplace such of the fire safety measures as are necessary to enable the employer to comply with the duty imposed by subsection (1).

(3)Where under subsection (2)(a) an employer carries out an assessment, the employer shall—

(a)in accordance with regulations under section 57,REVIEW the assessment...........

That's because we spend most of our time arson about up here, you'd never tell the difference.

Good thread.