Rank: Forum user 
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A Project Manager I'm working with is insisting on locating a Cylinder Store, (and Gas Distribution system) for a new laboratory outside (which is good) but on a Fire Escape Route. The escape route is designed for 4 different factory units and 4 different companies. The different companies do not know of the plans.
I have spoken with the BCGA Technical Manager and read CP4 & CP44. As far as I can see you cannot site a Cylinder Store on a Fire Escape Route. The PM is going ahead with the installation.
I seem to be banging my head against a brick wall here and I'm hoping someone can point me in the direction of a solution or at least some evidence to support my advice in the way of court action.
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Rank: Forum user
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Its your fire risk assessor that you need to speak with. You dont say what gasses it is thats being stored and the hazards they represent. Essentially though, any problem with the store itself (fire/leak etc) and you have removed the means of escape for anyone using this route.
Fire escape routes must have reduced sources of fire/explosion, so putting this store within it would be the opposite. The ACOPs (HSG 39 & 139) regarding storage of compressed gases will give you all you need to know, although you say you have read these already. It may even be wise to speak with your insurers as well.
You are correct, this is not a positive move!
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Rank: Forum user
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I carried out the FRA and pointed it from the outset. The gases are inert, I hate being the "you can't put that there" type of guy but its a fire escape route and I can't see a way around it.
I've asked for a written justification from the PM and evidence the insurers are happy. Neither have been forthcoming.
Interestingly a specialist gas system design/installer (I won't mention them), not only said it OK where it is (its also less than 3 metres from the property boundary) and explained in great detail how an ACOP doesn't stand up in a court of law!!!!! Please!!!!
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Rank: Super forum user 
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FSO 2005 quoted below and also remeber it is a legal requirement to discuss with any other interested parties who can be effected by thai, i.e. the other companies. Yoy also have the requirements of Article 9 and article 11 and Article 12 Elimination or reduction of risks from dangerous substances
Emergency routes and exits
14.—(1) Where necessary in order to safeguard the safety of relevant persons, the responsible person must ensure that routes to emergency exits from premises and the exits themselves are kept clear at all times.
(2) The following requirements must be complied with in respect of premises where necessary (whether due to the features of the premises, the activity carried on there, any hazard present or any other relevant circumstances) in order to safeguard the safety of relevant persons—
(a)emergency routes and exits must lead as directly as possible to a place of safety;
(b)in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible;
(c)the number, distribution and dimensions of emergency routes and exits must be adequate having regard to the use, equipment and dimensions of the premises and the maximum number of persons who may be present there at any one time
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Rank: Super forum user
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Are the gas cylinders actually 'on' the fire escape route and really obstructing/limiting the width & availability of the fire escape route?
Or are the cylinders simply immediatley adjacent to the fire escape route? You have said they are inert gases. Presumably they are secured/chained etc so won't get pushed over etc to obstruct the fire escape route?
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 1 user thanked Ian Bell2 for this useful post.
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Rank: Forum user
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Yes the Cylinders are on the fire escape route for 4 different companies/units.
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Rank: Super forum user
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Hold your ground then
Get the PM to confirm your fire RA and get him to justify why he doesn't accept it. Pointing out #4, that what he is proposing is illegal.
Add the finding to your site risk register.
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Rank: Forum user
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Thanks. I might be having a crisis of confidence but it is illegal isn't it?
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Rank: Super forum user
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Yes illegal - if it is accepted by your company/all concerned that the route is an 'official' fire escape route (signed/marked etc) indicated on building plans etc. Is the fire route floor/route highlighted with floor paint etc?
Assuming, there is no alternative fire escape route or can the route be altered to go around the gas cylinders to a small degree?
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Rank: Super forum user
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Sometimes you do have to be 'you can't put that/do that' person.
There are some things that are not open to debate.
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Rank: New forum user
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thank you so much for all this info, its helps a lot !
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Rank: Super forum user
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...mmmm...the words are important here...if you are using a properly constructed cylinder storage which does not block a fire escape route and stores anylitical gases such as Argon, Nitrogen etc ...it isn't illegal.. CP 44 is a code of practice it isn't a legal document...and by the sounds of things the storage complies to the distances etc...you say all is inert so why would you define it as high risk on the escape route...unless they were going to trip over them?...I would just get your facts straight before doing battle...the storage of inert cylinders close to a fire evacuation route in the open air does not increase the fire risk to that route...only when the cylinders are in the fire themselves...an open cylinder cage might not be appropriate but the wall construction may need some thinking about...
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1 user thanked stevedm for this useful post.
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Rank: Super forum user
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I'm with stevedm on this... Four businesses using a shared escape route... I'm thinking a courtyard with an arched entry lane, or perhaps a quad with a single road access..? What happens if a van goes on on fir in this access? Or the local yobs build a pyre of pallets on fire? Presumably there are alternative routes to the 'place of safety'? Has the 'place of safety' been defined? To all those saying "you can't do that there 'ere" I would ask.. Have you ever compiled fra for a courtyard of shared occupancy?
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Rank: Super forum user
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#12 & 13 = hence why I specifically asked the question at #5 and the answer received at #6 We are always limited by the forum by responding to text based questions/decriptions and the information given. Nevertheless, it is without question illegal to block a recognised fire escape route. From the information given, its sounds to be an illegal situation.
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Rank: Forum user
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Thank you for your replies.
Just to update everyone, we've had a second opinion from a Fire Risk Assessor. He says it's fine as there are two exits from the building, one at the front, one at the back. The one at the back has the Cylinder store and Manifolds placed directly on the fire escape route. I disagree but there you go. Problem solved, if you don't like the answer, get someone who can give you the answer you are looking for. Just to elaborate, the cylinder store is obstructing, not blocking a Fire Escape Route. It's not only a store but part of a designed system and is less than 3 metres from the boundary of the property (BCGA CP 4). I'm pretty sure an ACOP has special legal standing.
Edited by user 09 March 2020 14:24:47(UTC)
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Rank: Super forum user
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I read that as - the escape route 'at the back' is permanently obstructed by the gas cylinders - so you really only have 1 fire escape from the building that is unobstructed.
What is the travel distance to use the front fire escape? How many people could use the remaining fire escape route?
A drawing would be very helpful on this occasion. Does what you have left, meet Building Regs or BS9999?
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Rank: Forum user
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BS9999
43.2 Escape routes In order to ensure that escape routes are available for use at all times
when the building is occupied:
a) all escape routes, including refuges, should be maintained free
from obstruction;
b) goods, materials, unwanted furniture, etc., should not be stored
within escape routes. Any obstruction should be removed
immediately
There you have it!
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Rank: Super forum user
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BS9999 is not a retrospective document so might apply. Just use the FSO 2005.
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Rank: Super forum user
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I refer back to my comment at #9 - if the fire escape route has been formally accepted by the building/site plans etc, then the other fire risk assessor simply can't ignore and risk assess the issue away.
Unless he makes alternative/proposes an alternative fire escape route to give the same level of fire escape options.
As ever with these things gather your evidence - either from building plans, previous assessments etc and present to the site manager. Depends how much you want to continue to escalate the issue? Is the/are the building office blocks or is the work in the various buildings higher risk?
Enter your concerns on your site risk register.
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Rank: Super forum user
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Originally Posted by: Ian Bell2  I refer back to my comment at #9 - if the fire escape route has been formally accepted by the building/site plans etc, then the other fire risk assessor simply can't ignore and risk assess the issue away.
Unless he makes alternative/proposes an alternative fire escape route to give the same level of fire escape options.
As ever with these things gather your evidence - either from building plans, previous assessments etc and present to the site manager. Depends how much you want to continue to escalate the issue? Is the/are the building office blocks or is the work in the various buildings higher risk?
Enter your concerns on your site risk register.
FSO 2005 tells you that is is a legal requirement to keep escape routes free at all times.
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Rank: Super forum user 
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You seem to indicate this is also a fire escape route for other businesses, they may be interested in what your company are going to do ? I have been watching this and at one point you state this store will be within 3m of boundary, but I take it not up to the boundary. So, is there still enough room for people to get past? Could a protective wall be built to separate? Little confused if it actually fully blocks or if there was a wide walking area which is reduced, not cut off completely. Would, what is left, be considered wide enough for the potential use /quantity of people. There appears to be confusion over the exact set up. Has this assessor put their recommendation in writing and their name to it?
Chris
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Rank: Super forum user 
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Ask the local FRS for their take on it? We still have advisors in the FRS in Wales who will assist, two of them recntly did a talk at the locl IOSH branch meeting.
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