Clive Raybould From FSTC discusses the Fire safety Order and how to comply
A recent government review found that although there were some teething problems, in general the legislation was bedding in well. However, it has also been estimated that approximately 60% of workplaces (especially SME’s) are still not aware of the implications of this law and that they have still not carried out a fire risk assessment.
If we step back for a moment and reconsider what did this change in law bring about:- It amalgamated various fire safety laws and created a legislative ‘One Stop Shop’ for fire safety law. More importantly it shifted the responsibility for fire safety in buildings totally onto the newly defined ‘Responsible Person’. In the business world, this in general relates to the Employer, Director, Manager or Owner.
It is vital therefore that Employers/Managers etc take ownership of fire safety issues within their premises. We should aim to have a fire safe working environment with good management practices and controls, with fire safety conscious staff. Management also need to recognise the shift in enforcement styles that have drifted in alongside this new legislation. The Fire and Rescue Service no longer come out to carry out a routine inspection, they inspect premises now using a similar methodology to the HSE, where they will conduct an audit of your management systems and practices and if failings are present they will take informal or formal enforcement action against you. (This could range from a verbal comment, issuing a notice of deficiencies, issuing an alterations, enforcement, or even a prohibition notice. If circumstances are warranted, then legal action can also be taken in the courts in addition to the issuing of notices).
One of the growth areas of enforcement is the ‘Post Fire Incident’ enforcement action. This has recently been graphically highlighted by the legal case against fashion retailer by London Fire Brigade. Following a fire which started in a 2nd Floor store room in the Oxford Street store (suspected arson – not proven), where no one died, no one was injured, but there were fire safety failings, New Look have been fined £400,000 with the addition of £136,052 in costs. This case came about as a direct result of the fire incident and a series of post fire audits which were then carried out.
Incidents such as this demonstrate how vital it is to ensure that your organisation is fully compliant with the FSO. The first step to undertake, is to carry out a suitable and sufficient fire risk assessment which will then highlight the ‘Preventive and Protective Measures’ or ‘General Fire Precautions’ as outlined in the FSO that have to be taken. It is worth therefore considering these legal words to see what they really mean so that you understand what has to be done to ensure compliance!
The first thing to state, is that the ‘General Fire Precautions’ and the ‘Preventive and Protective Measures’ which are both referred to in the legislation are in fact one and the same thing! It is easier to think of them as two separate factors, firstly ‘Preventive Measures’ and secondly ‘Protective Measures’.
Secured exit rear solid surface fabrication shop
Preventive Measures – These can again be subdivided into three distinct areas:-
Fire Prevention – Measures in place to prevent a fire from starting. This entails looking at the combustible materials present and the potential for ignition sources to be introduced. This is the ‘hazard spotting process’ and must cover both accidental fires and the potential for arson. Arson is still the largest single cause of fire (41% of all fires) and your management system must consider your vulnerability to arson and your defensive measures such as general security measures, security fences, security lighting and most importantly the separation or preferably removal of any combustible items from the near vicinity of the premises. It is worth verifying if your insurance company specify minimum separation distances for combustibles to your buildings. Any storage within this distance may invalidate any insurance claim should it be involved in a fire. Electrical equipment is generally the second main cause of fire and you should have robust policies for installation and use of such equipment. Any process which involves fuels or heat should be analysed to ascertain if the hazards produced are acceptable or not. Your management procedures for fire prevention should therefore cover factors such as: Security issues, Electrical testing, Smoking policies, Control of contractors, Hot work permits and maintenance issues as a minimum.
Slot above electric tray
2 – Fire Spread – Measures in place to prevent fire spread. This can be as simple as ensuring that fire doors are closed, that the self closers are working correctly and that the doors are not wedged open. It may also include checking that the fire resistant structure is intact. (Notorious issues are holes in the fire structure above false ceilings where services have been installed). This factor may also include such actions as ensuring that the air handling systems shut down on the fire alarm and that fire dampers close to limit fire spread. Fire spread also has to be considered from one occupancy (or building) to another. In addition to fire stopping, smoke stopping may be required so as to limit smoke spread and thereby ensuring safe escape routes for people.
3 – Mitigation – Measures in place to mitigate the effects of the fire. This may include consideration of the effects that a fire may have on neighbouring premises and/or the local community in addition to the people in the premises. It can also be applied to environmental issues and the potential for pollution as a direct effect of any fire. For example the type of drainage on the site and the water pollution threat from water runoff from any fire may need to be looked at. This point may be satisfied by the type of information on the drainage system that you provide for the attending fire and rescue service, but in industrial settings where pollutants may be present provision of equipment for use by the fire and rescue service may also need to be considered.
Corridor fire door with space above tray on top of red ceiling
These measures can be sub divided into six distinct areas.
1 – Means of Escape – This is unfortunately the more technical side of fire safety. In simple language, this is about making sure that if there is a fire that people can safely get out. You have to consider the number of escape routes, the location of exit doors and how far you have to walk to get to them. In larger premises with more than 60 people present then the widths of the exit routes and the doors also has to be considered. The method of opening fire exits (E.g. Panic bar) and the type and location of fire exit signage is also important. Other than in small single storey buildings, it also usually necessary to build the structure that surrounds the exit routes (especially staircases) with fire resistant materials so that people if necessary can walk down past the floor that’s on fire. This all sounds rather daunting, but if your building has been recently built or altered and all work went through building control, then means of escape facilities should already be in place unless you have altered the internal layout to give issues. One final factor to consider when looking at means of escape from fire is disabilities. It is now commonplace to have the potential for people with various disabilities at any floor level in a building due to access rights. The simple approach to this is to look at your building and assess if you could have any individual who could not respond to the alarm, or evacuate the building without assistance. Anyone who you allow into your building, it is your responsibility to provide evacuation systems for (without external assistance from the emergency services). Once you have analysed the problem you can develop a management system to give assistance. This may include specialist equipment and Personal Emergency Evacuation Plans (PEEPS). Management needs to ensure that all of these factors are in place and that they can be used effectively, both inside and outside the premises.
2 – Securing Means of Escape – This strange title actually means that you have to make sure that the means of escape is available and can be used at all times that it is needed. Security measures such as locking doors will give a conflict here and you need to ensure that any out of business hours security measures that are in place are removed during the working day. You may have security measures in place during the working day, such as electronic locking and redlum bolts. Both of these systems can cause serious issues and must be assessed correctly, work correctly and staff must be trained in their use. Dependent upon the use of the building these type of devices may be questioned, especially if the public are present. Simple steps such as ensuring escape routes are unobstructed and available and that any exit doors can easily be opened also fall under this heading. Dependent upon hours of work and natural lighting levels, then emergency lighting may also be required. The simple question to ask, is how will people get out if the lights fail? How good is your emergency lighting? Do a simple test by turning off the lighting circuits during the hours of darkness and try to follow the escape routes to safety.
3 – Fighting Fires – You have to have a means for fighting fire on the premises. This generally equates to fire extinguishers. Are your extinguishers the correct type for the type of fires you could expect to get. Do you have enough extinguishers (minimum 1 extinguisher for every 200 sq m of floor space). Are the extinguishers located so they are visible and accessible. Who do you want to use your extinguishers and have you made them competent to do so.
4 – Fire Detection and Warning – How do you raise an alarm in your premises and is it suitable. Most buildings have electronic fire alarms. You need to check that call points are visible and accessible and it is also worth verifying that there is a call point by every door out of the building (fire exit or not). Can the alarm be heard and how will people respond to it? What actions do you need to take once an alarm has been raised, especially in light of the new fire and rescue services ‘Call Challenge’ systems, where you may be asked to confirm if there is a fire, before the fire appliances are sent out to you! You may have or need fire detection systems for life safety and/or property protection. Are they the correct type and have you done everything that is reasonable to reduce false alarms.
5 – Actions in Event of Fire – The simple question to ask yourself is ‘What do I want people in this building to do if we have a fire’. You probably want the majority of people to just evacuate, but others will have specific roles to undertake. How do you want the evacuation to be managed (Fire Marshals?), who needs to do what and have you made them competent to do so. For example, have you set up a response team that will check the building to confirm if there is a fire or not, so that you can confirm this to the fire and rescue service and get fire appliances to attend quickly.
6 – Instruction and Training – All staff should be given instruction on fire safety measures in the building so that they can work, react to any fire threat and evacuate safely. This may include specific instructions on exit devices such as electronic locking. It is generally accepted that you should give all staff information on the fire extinguishers, but make people who you want to use them competent to do so. The simple approach to this subject, is to ask yourself what do you want people to do in the event of a fire, and have you given them sufficient information and training to do so competently. Training should include fire evacuation drills where a fire is simulated so that an exit route is not available. Consideration should also be given to visitors, contractors and out of core hours workers.
Maintenance – Having done the fire risk assessment and highlighted (and put in place) the above measures as necessary, the second step is then to ensure that sufficient maintenance takes place to keep up the standard that has been set. Any equipment (E.g. extinguishers, alarms, detectors, emergency lighting, self closers, door opening devices), the building fabric (fire resistant structure, fire doors) and any component part of the fire safety system must be maintained and tested to ensure that it is in good working order. It is vital that evidence is available to demonstrate this maintenance. Most organisations fall down on this side of things and they do not fully understand the level of maintenance and testing that is required. As an example: If you have electronic locking, you need to confirm every week that each individual electronic lock has unlocked when the fire alarm was tested. I know to buildings with a large number of these locks installed, which then becomes a huge management task to undertake.
Management – As stated right at the start of this article, the FSO has pushed the responsibility for fire safety and fire safety management totally onto the organisation and its management. To demonstrate compliance with the FSO you need to show that you understand the fire safety issues in your premises and more importantly that you are in control and are actively managing fire safety issues on a daily basis. Part of the management system is the need to review and react to potential or actual changes, so that the fire risk assessment can be revised if necessary.
This article can only give a brief outline of the issues involved as each premise is different. It is intended that future articles will be produced with regards to some of the specific points which have been raised in this overview.
Clive Raybould M.I.Fire.E. – Fire Safety Consultant
Clive Raybould worked as a Fire Officer in the West Midlands Fire Service for 30 years, where he specialised in fire safety and fire safety training. He now owns his own company ‘Fire Safety Training Consultancy Ltd’ and operates as a fire safety consultant. He frequently carries out fire safety training at all levels and undertakes fire risk assessments of his clients properties. He advises companies on management systems and as a consultant has designed and implemented fire safety management and fire evacuation systems in various buildings. Clive can be contacted via the following routes: