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#41 Posted : 21 June 2007 21:26:00(UTC)
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Posted By shaun mckeever
No
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#42 Posted : 22 June 2007 11:13:00(UTC)
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Posted By Robert K Lewis
What is really amazing here is that the design code of practice to the Fire Precautions Act 1971 was very clear concerning the need for fire doors, in premises of this type,of at least 30 minutes in all premises except for individual private dwellings.

FRAs were not intended to reduce these standards but must equal or exceed. The standard to be achieved is related to the spread of fire and not the means of escape per se although they are inter-related.

Bob
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#43 Posted : 22 June 2007 11:22:00(UTC)
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Posted By Crim
I have a personal concern about the competency of some people undertaking fire risk assessments who do not have the necessary knowledge. There is another post to do with fire risk assessment today that reinforces my concern.

While I realise that people need to start somewhere and to be assisted through the process initially, we are talking about life safety here and that is something not to be treated lightly.

I just wonder how best to ensure that fire risk assessments are carried out correctly and produce the desired result in every case?

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#44 Posted : 22 June 2007 15:23:00(UTC)
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Posted By Rob Randall
Hi Bob

what is really amazing to me is that nobody has yet been able to supply me with chapter and verse. BS5588, so far as I am aware, does not cover sleeping accommodation (unless you can tell me otherwise and point me in the right direction) and I would be grateful for the reference.

As to your comment Crim about the competence of people doing fire risk assessments I will assume you have written without thinking too deeply. You don't know me nor do you have any idea of how well qualified and experienced I am so you should think twice before making allegations.

The post was originally about whether or not the building standards should be applied retrospectively despite other controls being in place. I have said quite unequivocally that 30-minute FR doors is the norm and I have no problem with that. The point is I am not asking whether or not FR doors should be fitted but whether or not the FRS can compel a building owner to do so unless they have a serious concern for life safety. I don't think the circumstances I have outlined constitute a serious risk.
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#45 Posted : 22 June 2007 15:53:00(UTC)
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Posted By Crim
Bob,

My comment was made because I really do have a concern about unqualified people undertaking fire risk assessments.

I often get questioned to assist people who have taken on the responsibility for a Fire Risk Assessment and who think they can "get away with it".

With regard to your competency, you are right I don't know anything about you hence the comment was not directed at you personally, however "If the cap fits ......"

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#46 Posted : 22 June 2007 16:01:00(UTC)
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Posted By Adrian Watson
Rob,

As previously stated the FA cannot require you to upgrade fire precautions to current building standards unless they are of the opinion that there is a serious risk of injury or death from fire.

Regards Adrian
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#47 Posted : 22 June 2007 16:42:00(UTC)
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Posted By Robert K Lewis
Rob

Under FPA 1971 and its associated code they should already have been fitted and were not therefore it is proper to insist they comply with the standards of the day.

There is from the other point of view no chapter and verse that permits any risk assessment to reduce the requirements of design codes of practice. There is no such ability in the RRO, it repealed and replaced the FPA but assumes that up to that date the FPA etc requirements were followed. It is not a case of retrospective application but one of insisting that the standards are met unless equal or better spread of fire precautions can be demonstrated.

Thus the 30 min door requirement has been overlooked for a period during which they should have complied, The RRO now requires that the assessment recognises that 30 min spread of fire protection has to be achieved - the only question is how. Fires may not be expected and all ignition sources controlled but even then they can happen, after all you still have power supply to the room. If a resident does breach your rules and smokes, then sets fire to the bedroom what is to limit the spread of flame? It is too late to discipline him/her when they and several others are dead.

The fire authority do not need chapter and verse to instruct work - you need chapter and verse to prove the instruction has been matched or equalled in another at least equivalent way. Can you demonstrate 30 minute fire spread resistance? If not the assessment is deficient.

Bob
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#48 Posted : 22 June 2007 18:35:00(UTC)
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Posted By Rob Randall
Hi Bob,

you have mentioned the FPA 1971 and its "associated code of practice" several times but can you give me a reference e.g. a page or paragraph number that specifies FR doors in non-domestic sleeping accommodation. I have trawled my resources but am unable to find any such reference.

regards,

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#49 Posted : 23 June 2007 00:42:00(UTC)
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Posted By Ken Taylor
Aren't the FRS saying that they consider the controls for the fr of the doors as per your risk assessment to be inadequate? Considering the nature of the occupancy and the information supplied, I am also inclined to that opinion and would certainly prefer to see min 1/2hr fr.
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#50 Posted : 23 June 2007 09:17:00(UTC)
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Posted By Adrian Watson
There seems to be two schools of thought here:

1. The first school is of opinion that the appropriate standards (in this case Building Regs) should be met.

2. The second school is of the opinion that the measures are determined by the level of risk.

I am of the second school. I believe the appropriate tests are to meet the test of reasonable practicability are:

a. Is there a risk from fire? If no - stop; If yes go to next question.

b. What are the appropriate measures / standards to prevent or eliminate that risk. Is it grossly disproportionate to take the measures? If no - take the measures; If yes go to next question.

c. What are the appropriate measures / steps to reduce the residual risk. Is it grossly disproportionate to take the measures? If no - implement that standard; If yes go to next question.

d. What are the appropriate measures / steps to manage the residual risk. Is it grossly disproportionate to take the measures? If no - implement that standard; If yes stop.

Regards Adrian

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#51 Posted : 23 June 2007 11:41:00(UTC)
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Posted By GT
Rob,
Sorry, but I wasn't inferring that you were anything other than professional. But even professionals get heated at times especially in this wide open game of safety interpretations.

Can you confirm if this is a domestic dwelling or is it a commercial business in the name of "a house in multiple occupation" run by your client for profit?

Regards

GT
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#52 Posted : 05 July 2007 10:13:00(UTC)
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Posted By Rob Randall
Hi all,

you may like to know that my approach to this matter has been vindicated. The LAFB concerned have now agreed to remove the requirement for 30-minute FR doors because thay have accepted that the other control measures already in place have reduced the risk to an acceptable level.

Cheers
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#53 Posted : 05 July 2007 11:01:00(UTC)
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Posted By shaun mckeever
Good. Well done!

It goes to show that you know your building and circumstances better than we do.

Regards
Shaun
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#54 Posted : 05 July 2007 11:07:00(UTC)
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Posted By Crim
Rob,

Good result for you!

It just confirms my belief that every fire brigade has different interpretations and follow their own "rules", also in spite of those of us who are quite well up on fire regs. and happy to give guidance - as Shaun said you know your building better than any of us.

Well done.



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#55 Posted : 05 July 2007 19:50:00(UTC)
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Posted By pluto
Rob

I am glad that the FRS has accepted your argument that in this case, the combination of additional measures compensated for the lack of certified FR doors.
Not all FRS inspectors are code huggers!

I would be interested in why they changed their mind? Was it just a more experienced officer who could juggle all the bits and come up with the appropriate decision?
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#56 Posted : 05 July 2007 22:31:00(UTC)
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Posted By Rob Randall
Hi Pluto,

I think the reason that they changed their mind was twofold. I wrote a long and very detailed letter quoting the appropriate government guidance on HMO's and pointing out the fact that it does not mention any requirement for FR doors (at least in the Scottish guidance). I also mentioned the fact that all of the available guidance points to the need for risk assessment and does not call for the willy nilly implementation of the current Building Standards.

The other factor was that the enforcing officer referred the matter, as you suggested, to a more senior colleague who perhaps was more experienced and maybe more aware of the potential political fall out.

Regards,

Rob
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