Prefix: Emergency routes and exits 14.—(1) Where necessary

[Magic]

In the RRO quite a few of the regulations are prefixed with the words Where Necessary. (as my subject)

But not sure how this is implemented, as the first one states 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.

But does the prefix go along with all following regulations, as this wouldn't make sense, so (d) emergency doors must open in the direction of escape; this shouldn't be "where necessary" surely this is a must i would think, and similar applies to others in the category. Like the below.

g) emergency routes and exits must be indicated by signs; and

(h) emergency routes and exits requiring illumination must be provided with emergency lighting of adequate intensity in the case of failure of their normal lighting.

 

Also does anyone know if call points should have signage, this is a bit of a grey area to me.

 

Any help 

Thanks.

Mick

[AnthonyB]

Where necessary is a reflection that specific provisions are determined by Fire Risk Assessment.

Exit doors don't (& never have) had to open in the direction of escape unless likely to be used by 60 or more persons - this has formed a part of fire safety guidance for a very long time.

Call point signage, like some other fire safety signage, isn't explicit in the Order, however some slack in the specific detail is filled by the Health & Safety (Safety Signs & Signals) Regulations 1996 which also covers fire safety signs, but even this isn't definitive on these signs. Strictly speaking they are not required as a matter of course based on the way the law is drafted because the actual call point is required to be red with a pictorial symbol under EN54 the fire alarm component construction standard so in effect signs itself - in theory only if obstructed or hidden or requiring location in a large open area would it need additional signage to ensure the fire alarm is readily usable. It's likely this is poor drafting of the legislation (it's full of poor writing) as in other EU countries (who adopted similar legislation as the Fire Safety Order continues the UK's earlier implementation of an EU directive for worker fire safety via the Fire Precautions (Workplace) Regulations) mostly routinely sign their call points.

What is more common here is to place Fire Action Notices next to call points as a continuation of the practice that used to be a legal requirement under Fire Certification via the Fire Precautions Act, although even this technically isn't mandatory.

[Magic]

Hi Anthony,

 

thanks so much of a grey area, gets very complicated. I have always been informed exits must open in direction of travel.

 

Mick

[Hayfever]

On 31/10/2022 at 22:23, AnthonyB said:

What is more common here is to place Fire Action Notices next to call points as a continuation of the practice that used to be a legal requirement under Fire Certification via the Fire Precautions Act, although even this technically isn't mandatory.

We use a rather more pragmatic approach to fire action notices (FAN)

FANs by a final exit will rarely be read during business as usual and frankly when the final exit is in use during an evacuation, its a bit too late.

We do place FANs by manual call points (including final exits), but frankly they are there to appease panicky fire safety inspecting officers. In addition, we also place them at tea points where staff gather and controversially at eye level (when sitting) on the back of toilet cubicle doors.

The last example may sounds a bit silly/jokey, but it is the location  where you have a captive audience who is unintentionally hungry to read something during their stay, as opposed to adjacent to a door to a staircase where nobody hangs around. 

[AnthonyB]

On 08/11/2022 at 10:49, Hayfever said:

We use a rather more pragmatic approach to fire action notices (FAN)

FANs by a final exit will rarely be read during business as usual and frankly when the final exit is in use during an evacuation, its a bit too late.

We do place FANs by manual call points (including final exits), but frankly they are there to appease panicky fire safety inspecting officers. In addition, we also place them at tea points where staff gather and controversially at eye level (when sitting) on the back of toilet cubicle doors.

The last example may sounds a bit silly/jokey, but it is the location  where you have a captive audience who is unintentionally hungry to read something during their stay, as opposed to adjacent to a door to a staircase where nobody hangs around. 

The beauty of the current legislation is that that is completely acceptable, not like the old days of more rigidity.

[Aps48]

On 31/10/2022 at 10:37, Magic said:

In the RRO quite a few of the regulations are prefixed with the words Where Necessary. (as my subject)

But not sure how this is implemented, as the first one states 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.

But does the prefix go along with all following regulations, as this wouldn't make sense, so (d) emergency doors must open in the direction of escape; this shouldn't be "where necessary" surely this is a must i would think, and similar applies to others in the category. Like the below.

g) emergency routes and exits must be indicated by signs; and

(h) emergency routes and exits requiring illumination must be provided with emergency lighting of adequate intensity in the case of failure of their normal lighting.

 

Also does anyone know if call points should have signage, this is a bit of a grey area to me.

 

Any help 

Thanks.

Mick

I find this aspect is greatly misunderstood on a regular basis. People read all the following

(d)emergency doors must open in the direction of escape;

(e)sliding or revolving doors must not be used for exits specifically intended as emergency exits;

(f)emergency doors must not be so locked or fastened that they cannot be easily and immediately opened by any person who may require to use them in an emergency;

(g)emergency routes and exits must be indicated by signs; and

(h)emergency routes and exits requiring illumination must be provided with emergency lighting of adequate intensity in the case of failure of their normal lighting.

and believe they are all a "MUST" and either don't read or they disregard the beginning bit "where necessary". If everything was just a "must" then a fire risk assessment wouldn't really be an assessment, it would just be a tick box exercise, either it is or it isn't compliant, where as the "where necessary", as has been stated, comes from an individuals assessment.

Take (f)emergency doors must not be so locked or fastened that they cannot be easily and immediately opened by any person who may require to use them in an emergency, for instance. For the majority of buildings his would be true, but, for Care homes that have residents with Dementia or special schools where pupils have a high risk of flight OR schools that adjoin a busy road with no barrier from final exit doors, then having doors that can be opened by ANYONE at anytime can be very dangerous. All that information that has to be considered can only come from an individual assessment of the building and apply where it is necessary.

That's why no 2 FRA's are the same, there is so much variance to take into consideration.