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Posted By Richie H Much to my surprise whilst on a recent Auditors Course the Tutor / facilitator suggested that fire drills are not always required and gave examples of new build schools, office blocks etc....
My first response was .... well i was shocked he was suggesting such a thing .... surely we all need training etc... then his explanation was along the lines of 'business risk management' / time spent carrying out drills against the already control measures (fire detection / fire fighting) .. i suppose its the old addage costs v risk? I must state that he was only referring to new builds / suitable number of easily accessable exits etc etc..... But what about training our staff i ask ???
His response was fire drills are not really suitable because everyone usually knows they are a drill and as such dont react as they should so the training is really not that worthwhile in many cases (low risk environments).
I thought i would put this suggestion to the forum where we are abundant with Safety Professionals for your thoughts!
Cheers, Richie
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Posted By Charley Farley-Trelawney Under current legislation there is a requirement to conduct fire evacuation drills at least twice per annum, this is further bolstered by the need to produce FRA's, it would be difficult to justify a S&S FRA could be produced that did not include a plethora of reference points to ACOP’s, legislation etc that state a needs far in excess of a basic fire drill.
They go far and beyond the basic guidance, ACOP’s, legislation for a fire drill.
The Management of Health and Safety at Work Regulations 1999 (as amended) require that employees must be given adequate health and safety training at induction and, as appropriate, subsequent safety training at regular intervals.
The Regulations also oblige employers to ensure that all employees are instructed:
Regarding fire procedures The arrangements for fire fighting The fire precautions required to comply with the Fire Precautions (Workplace Regulations 1997)
Section 6 of the Fire Precautions Act 1971 empowers (but does not actually require) the fire authority to impose such conditions as the fire authority considers necessary in the circumstances to ensure that:
Persons employed to work in the premises receive appropriate instruction or training in what to do in case of fire, and that records are kept of instruction or training given for that purpose.
Most certificates require that instruction be provided by a competent person to ensure that all staff are instructed at least annually. Some certificates stipulate that this is performed bi-annually and every three months in respect of night staff in sleeping risks.
Such is the centrality of employee training for what to do in the event of a fire that it is one of the three ’interim duties’ imposed by the Fire Precautions Act (as amended), pending response by a fire authority to an application for a fire certificate.
Section 2 of the Health and Safety at Work Act 1974 imposes a general duty on employers to provide instruction and training to ensure, as far as reasonably practicable, the health and safety of employees.
There are changes to consider that will come into force either later this year or early 2007; I refer specifically to the Regulatory Reform (Fire Safety) Order.
I hope this is of help to you but should you require comprehensive information do not hesitate to contact me.
CFT
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Posted By Is Kismet Under current legislation there is a requirement to conduct fire evacuation drills at least twice per annum
Could you advise where this requirement is please?
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Posted By Glyn Atkinson I am speechless, and hope that this tutor comes out of his cocoon into the real world where people and their actions matter.
Even if the requirement was not legal, then surely there is a high moral requirement to ensure that all staff, especially in a strange new environment know how the alarm sounds , and how to react to it.
The only full and proven way is to hold a practice drill.
Let's hope that this chap is never caught in a practice or real fire situation, eh???
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Posted By IanD Like the other response, can you be specific where it states that two fire drills are required. I can not find this.
I have examined our fire certificates and in the appendix “Fire drills and evacuation” it states employees must be trained in the fire drill and evacuation procedure etc
I am thinking of taking an alternative approach, rather than carry out a fire drill, I am looking at forming a register (to record the training) and taking small groups of employees out of the workplace and walking through the egress routes to the assembly points, where the muster recording procedure will be explained. This will record that the "training" has been done and will cause minimum disruption to production, sales, customer services, as well as our neighbours
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Posted By jackdaw I agree that there isn't a requirement to have two fire drills. Our fire certificate states that a drill must be carried out at least annually.
I do agree that there is a requirement to carry out a fire drill - can't quote legislation apart from the requirement stated in our fire certificate.
Under guidance published for the Regulatory Reform (Fire Safety) Order 2005 - I'm looking at the one for factories - there is a specific requirement in the guidance for at least one fire drill to be carried out each year.
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Posted By Is Kismet IanD
Excellent. Sometimes I think our profession needs to be more proactive and think about it instead of just following accepted practice. In our case we have branches with perhaps 5 or 6 people on each branch, and carry out regular briefings with the aid of a dedicated Toolbox Talk and a walk through.
Charley
I would appreciate an answer to your statement ref two drills are mandatory, but also what does S&S mean?
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Posted By Malcolm Hogarth It is always a bit risky quoting 'Legislation states' etc as there is a risk that one is then required to qualify it. Perhaps CFT could point us in the direction of the legislation he referred to.
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Posted By Robert K Lewis Section 4.4 on page 35 of the new guidance for offices requires that it (training etc) "be tested by drills". Further at section 7 on page 105 it also requires "Recording and training of relevant people and fire evacuation drills". To my simple mind this means that evacuation drills must be done. The frequency is however one for your Fire Risk Assessment.
If this is a reputable individual or training organisation involved here and they have IOSH accreditation of any form can I suggest you contact the Grange asap and discuss this. If there are other acredditations involved the relevant bodies also need to be contacted. This is a very serious lapse and the consequences could be large.
Bob
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Posted By Malcolm Hogarth Bob,
Is 'guidance for offices' legislation?
As I inferred in my previous response it is sometimes easy to quote what appears to be legislation but may not actually be so. Some time ago I had a lengthy tirade from a delivery driver about manual handling where he quoted legislation at me that I had never come across. He then went on to say what a useless so and so I must be if I didn't know health and safety legislation. After a bit of research it turned out that he was actually quoting an industry Code of Practice!
Malcolm
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Posted By jackdaw Do people agree that published guidance is there to demonstrate how the requirements of the legislation can be met?
If the guidance talks about fire drills, and you do not do fire drills, how are you going to show that you have fulfilled the requirements of the legislation?
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Posted By Jonathan Hall The excellent "Fire Safety: an Employer's Guide" (which hopefully will get reissued with the new Regualtions), states that:
"training should be repeated once or twice a year ... training should preferably include practical exercies, e.g., fire drills)" (p.26 of the 1999 edition).
Usually, the specific information will be detailed in the fire certificate: the number of times that people have to have a drill depend on the risk, etc. When Fire Certificates are completely replaced by fire risk assessments, then the competent person assessing the site will make that decision rather than being enshrined in a regulatory document.
However, for most premises, I can't see it being easy to justify a risk assessment which states that no fire drill are necessary.
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Posted By J Knight We do always need to be clear about what is legislation and what is not; I am quite sure that Bob has not confused the two when he offered statements from guidance in support of fire drills. The nub of the question about the need to do fire drills is in jackdaw's comment 'if we don't do drills what else are we doing?'
However, having said this, when talking about the law it always helps to read it; the RR(FS)O says:
The responsible person must—
(a) establish and, where necessary, give effect to appropriate procedures, including safety drills, to be followed in the event of serious and imminent danger to relevant persons;
So the law says we have to do drills 'where necessary' (try and imagine where it is 'not necessary' in order to fully undrstand this); frequency is set by risk assessment; risk assessment has an implied clause that 'best practice' will be expected in order to mount a succesful defence. Best practice is found, among other places, in industry and government guidance documents. If you therefore choose to ignore guidance docs you have to be be prepared to justify this in court,
John
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Posted By Ron Hunter I get out quite a bit, reasonable social life, etc (even for a safety bod). and in all my years I've never come across or heard of a fire drill in (e.g.) a restaurant, cinema, multi-storey car park or a supermarket(to name but a few). I suggest that there is merit in what that tutor/lecturer said, but he/she didn't pick particulary good examples. In an office environment, yes, the risk is low; however if people aren't drilled there is an increased risk of panic and consequent injury in the event of a 'real' emergency. I would support the argument against conducting such drills in the type of premises I mention above. Anyone out there done a Fire Risk Assessment for a Cinema, car park, etc?
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Posted By Robert K Lewis I am well aware of the status of the documents. Don't forget that these guidance documents are tied to the Fire Safety Order and as such if you do not follow them in making a fire risk assessment then you will have to show it was not resonably practicable to do so. Further you will need to demonstrate that your system is better or equivalent. Not an easy thing to do.
No theoretical training can provide a practical measure of how a procedure or plan will work - it needs to be tested in operation to iron out the flaws and make it second nature to staff. I still stand by the point that a trainer who doesn't see the need for practical operation is seriously flawed.
Bob
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Posted By J Knight Bob,
Absolutely; as I said, I was quite sure you know the difference; my comments were directed at posters wondering why you had quoted guidance in response to a question about the law.
I get people in my organisation saying 'it's only guidance' as an excuse for inaction; its never that simple.
As a further point, if the need for drills 'where necessary' is actually stated in the legislation this gives a measure of just how important the legislature considers them to be,
John
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Posted By Robert K Lewis JK
Message not intended for you. Others seem to think as you state that it is only guidance and thus of no real impact. I like you worry about such an attitude.
Bob
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Posted By Tabs Richie - your title asks if we "need" fire drills.
It is a very simple matter to resolve your question. Go and speak to a few people you have little or no interaction with on a daily basis (reduces their likelihood of trying hard to please you) and ask them to tell you their main and alternative escape routes. Ask them where their assembly point is, and ask them how they raise concerns that a colleague is missing from the assembly point.
If they can answer those questions to your satisfaction, you might be able to say you don't need them. My money is going to be on a set of answers that will make you want to do a drill very soon.
In my expeience, we all need fire drills and it is not just a legal argument, it is a prctical observation.
Sophisticated fire detection does not help people find their way out of a burning building.
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Posted By Richie H Hi again, Please dont think that i agree with the statement of the tutor, as i most certainly do not! I think that many students on courses believe that what the tutor says is gospel and most appear affraid to challenge. I did challenge his comments and he did back up his argument with examples of restaurants, shops, malls, etc and even some newer shcools (apparently). We departed agreeing to disagree hence i thought i would post the topic on this site. The responses are exactly what i expected....... but it is always good to challenge the norm hey?
Thanks to date for your comments, very interesting reading... S&S means suitable & suffiicient (i hope)!
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Posted By Malcolm Hogarth Bob,
If not intended for JK then who? - be brave.
For my own part I was seeking to open some debate about quoting legislation without stating what the specific legislation was. I am sure the majority of contributors are well aware of the status of Guidance notes, Codes of Practice etc and would wholeheartidly (sp?)agree with the bulk of the contributions to this thread. I am not quite sure what to make of your comments about 'attitude' but I will not take offence. (Thick skin, broad shoulders and all that)
Malcolm
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Posted By Simon Ayee Have a look at the fire guides on the DCLG website http://www.dclg.gov.uk/index.asp?id=1162101Training - In small premises this may be no more than showing new staff the fire exits and giving basic training on what to do if there is a fire. In larger premises with a high staff turnover and many shift patterns, the organisation of fire safety training will need to be planned. Most of the published guides state that training should be be tested by fire drills and that drills "should be carried out at least annually or as determined by your fire risk assessment. If you have a high staff turnover, you may need to carry them out more often." Guide 8 for Theatres & cinemas states monthly fire drills. Whilst drills test employee training it also mentions that "Some cinemas and theatres have found it helpful to employ a ‘rent-a-crowd’ to add realism to drills." It is sensible that if you have an emergency plan you need to test it (whether or not you use a rent-a-crowd) and the testing regime should be proportionate to the risk. Simon
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Posted By Booney Is Kismet
I believe S & S is suitable and sufficient
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Posted By Arran Linton - Smith Ron,
I have been in a large supermarket just before Christmas when the fire alarm went off. As I was at a checkout near the front door, I thought it would be interesting to observe what the reaction of the staff was.
I suspect you will not be surprised to hear that they did not react to the fire alarm in any way and there was no attempt to clear the store.
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Posted By Ali New fire legislation is based around..."Risk assessment", which must come as a surprise to many of us ! However, the long awaited guidance is out and ready to download at: www.firesafetyguides.communities.gov.uk Ali
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Posted By J Knight Don't get too excited folks, only some of teh guides are ready; Healthcare, for example, is not,
John
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Posted By Is Kismet Thanks Booney. Can anybody else answer for Charley ref mandatory twice a year fire drills?
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Posted By Salus Hi all, I think the requirement is for insurance purposes. Insurance companies normally ask for this to be carried out.
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Posted By Ron Hunter Hi Aaron,
Like you I have been in a supermarket when the alarm went off. I was physically stopped by a member of staff from leaving via a 'break glass' fire door and directed towards the main door.There was no attempt by staff to clear the premises. Pleased to report it was a false alarm!
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Posted By Red Ones The responses on shops are not surprising, though remain disappointing to me.
I arrange aminimum of 2 full evacuations for a shopping centre each year. I am still routinely disappointed by the number of retailers who do nothing and continue to go about their daily business even though the alarms are sounding. You must remember that in a shopping centre the alarm may not originate in the shop, so the source of alarm is unknown to the retailer!
I do think they are necessary. You can design the greatest building in the world, but you cannot design the human factor out. I was recently evacuated from a large tower block in the city and one thing that could not be designed out of the building was the tendency for the occupants to spill out in to the road and block access for the tenders!
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Posted By Martin Taylor In my opinion the primary purpose of a fire drill is to check that all arrangements for fire evacuation work in practice. It is not a primary function of training - it can't be ! 1 or 2 drills a year can not train ALL employees nor visitors.
Training of all employees and familiarisation of visitors is key to making sure that people know the procedure when the alarm sounds and this must be done on induction but beyond informing people of the fire alarm tone - followed by regular test sounding of the alarm - the nearest point of escapt - the muster point etc. So when the alarm sounds people know the procedure - I am at a loss to see what additional training an actual drill would provide.
If you operate a site which has very infrequent false alarms then a drill will be required to verify that the planned evacuation measures apply but - as in our case - false alarms are not uncommon a procedure can be established where on every evacuation a repot is compiled of what worked and where there were problems. This is much better than an arranged evacuation where everybody is prepared.
Martin Taylor
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Posted By Is Kismet By doing it Martin. You can push as much theory as you like into people, but it only becomes effective by doing it. And by doing it you are training them.
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Posted By J Knight Hi Folks,
On Charley's view onm frequency; frequnecy of fire training and practice is set by three things; one is Risk Assessment, one is relevant guidance, and the third is the feedback and findings from previous fire training and practice.
The guidance in Residential Care for example, is Firecode HTM84; this gave a frequency of 2x per annum In Hospitals it is Firecode HTM8x; these suggest annual evacutaion practices. So there's nothing actually in statute about frequency, but there is authoritative guidance,
John
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Posted By Ashley Wood Ummmm... What can I say that has not already been said? This person needs a sharp lesson in life from a fire fighters perspective!
Practise, Practise, Practise regardless of whether it is organised or not is essential. It identifies weaknesses in the evacuation plans, it enables people to interact with each other, it makes them familiar with the building, it gives them confidence, etc., etc. People become very complacent when it comes down to there working environment and need to be 'drilled.'
Regarding legislation, the RR(FS)O states that fire drills must be carried out. I always recommend every 6 months, regardless. As the old adage says 'practise makes perfect.'
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Posted By Richie H Ashley,
You will be pleased to know that i agree with your policy - training / practice etc and recommend 6 monthly drills as a minimum! Dont always have to listen to those more experienced H&S Practicioners....
RIchie
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Posted By Stupendous Man Just to add a few comments to this thread (and perhaps act as devils advocate in a few!):-
As professionals, we need to be careful that we use the correct terminology, particularly when referring to regulations, ACoPs and guidance.
Quoting legislation off the top of ones head is not recommended - one of the reasons why I am against closed-book exams such as NEBOSH. In the workplace, we have reference material available - use it! I once worked under a very experienced H&S manager, now a chartered member, who regularly quoted legislation without referring to the 'book', and was inaccurate around 75% of the time. To put in another context, is anyone so sure of their surroundings and driving ability that they drive with their eyes closed?
I have come across many people who automatically think that every activation of the fire alarm is a drill and take no notice. As such, there is merit in having no drills - everyone will take the activation seriously, follow human instinct, and get out!
Getting back to the initial question though - Employers should have the option of taking account of their fire risk assessment alongside those for other threats and then decide on an appropriate evacuation testing regime according to what they see as the highest risk (which may not be fire).
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Posted By shaun mckeever The original question was 'do we always need fire drills'.
I have lifted this from the RRO which comes into force in October:-
Procedures for serious and imminent danger and for danger areas 15. —(1) The responsible person must—
(a) establish and, where necessary, give effect to appropriate procedures, including safety drills, to be followed in the event of serious and imminent danger to relevant persons;
I think this should bury any doubts for the future.
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Posted By Bob Shillabeer Hi All, I've read this thread with some interest and some alarm at the level of opinion that exists. We all need to read the guyidance published in support of the Regulatory Reform (Fire Safety) Order 2005; it is very good (if not entirely new) and states where necessary. This is an important phrase; use your Fire Risk Assessment to determine if this type of action is needed! In a previous life I was employed as an operations manager by British Rail which had certain types of building that fire drills were impracticable because of the nature of activity undertaken there e.g Signal Centres controlling many miles of railsway and moving trains. The way we managed this was regular tests of individual understanding of the evacuation process. I know this is not ideal but it keeps them aware of the drill. Other industries have simular difficulty e.g. Airports with air traffic control towers, etc.
As to the need for fore drills it is quite clear that were practicable and necessary they should be undertaken on a regular basis end of news - you can't demonstrate adequate testing of both procedures and the understanding of training.
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Posted By henrys Shaun,
I totally agree with the requirement for fire drills, for all the reasons quoted.
However the section that you have just reproduced does say "where necessary", so I'm sure it will not bury the argument.
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Posted By Sheila EJ Keogh To Is Kismet,
Would suggest that "S&S" means "Suitable and Sufficient" as defined in the ACoP to the MHSWR (Management of h&S at Work Regs).
Sheila
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Posted By Bob Shillabeer Where necessary is the term used extensively in both the Fire Safety Order and the guidance and means just that where necessary for example if the premises has only two or three persons working there a fire drill is probably not necessary, but where say 200 people work in premises that are quite complex or wide spread then clearly they would be necessary. The risk assessment should identify what level of fire drills are needed; that's the thing about the RRFSO it does not set out details of what to do but places a resposibility to use professional judgement often called professional fire safety judgement by those involved with fire such as fire brigades and fire inspectors.
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