Fire Action Notices - A Legal Requirement?????

[Hayfever]

I am struggling to find any regulatory requirement for 'Fire Action Notices'

I find the whole concept of installing them by manual call points impractical as most MCPs are on the approach to staircases (or within staircases), in corridors, or at final exits - not the best place for staff or anyone to stop and read them at their leisure - especially during an evacuation!!

I believe these FAN locations are a legacy from Fire Certification - or the guides that supported the Fire Precautions Act.

I am not anti FANs, but have adopted a more pragmatic approach and place FANs in lifts, above urinals and on the back of toilet doors - places where by necessity - people linger and often want something to read!!!

We have had two fire safety inspectors comment on the lack of FANs in their traditional locations at our premises - and have received a Notice of Fire Safety Deficiency from one authority which we will ignore until such time the fire service concerned point us towards the regulation they want to enforce (they have failed to reply to two e-mails requesting that info)

I would appreciate your views

[Tom Sutton]

The old blue guide for the FPA says you need them but not where they should be located it just says in conspicuous places and so they cannot be defaced.

Article 11 says, The RP must make arrangements for the effective planning, organisation, control, monitoring and review of the preventive and protective measures and if you employ five or more it must be recorded.

If you look up article 2 the definition of preventive and protective measures it says general fire precautions.

If you look up article 4 general fire precautions it says (f) measures in relation to the arrangements for action to be taken in the event of fire on the premises.

If you look up article 8 it says must take such general fire precautions for employees and relevant persons.

So you could make an augment that fire action notices are required by the RR(FS)O but I cannot find where they should be located, in any of the guidance, in my opinion it is up to risk assessment which is basically what you are doing.

[Hayfever]

Thanks Tom

It all sounds a bit vague and round the houses doesn't it? Thanks for your views as it seems what we are doing is appropriate & compliant

Hypothetically speaking: If I have my procedures, FRA, and policy available to staff on the intranet (recorded). And my staff are trained periodically as req by Article 21 and any visitors will be accompanied so do not need any guidance - then I am covered I would argue.

I also wonder whether FANs could be included in Article 15(1)(a) in that to 'give effect' (see below) one needs to communicate the procedures to staff and others???

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;

But again, its not really clear!

Thanks

[Tom Sutton]

I am afraid it is all about interpretation and you need to check every word to know what the meaning of the phrase is. Round the houses is a good description, because other people will come up with differing interpretations and you need to be ready no matter what is thrown at you.

In my day everything was prescriptive and you could give black/white answers, even so there were areas of grey. But now it is risk assessment, consequently the legislation is all about "IF NECESSARY" so any decision have to be vindicated by experience and knowledge, very little you will get, straight forward clear black/white answers, and interpretation is important.

Take article 15 it is about procedures for serious and imminent danger and for danger areas, could a corridor in an office block fall into this description?

What I am certain of is FAN’s are required and should be located in conspicuous places, not only at fire points, and you need to be able to explain where and why, which you seem to be able to.

[Guest Magic]

Hi 

I have just started a new role as a facilities officer, and part of this role is compliance. Tom you have been the best person i have found giving advice and guidance on any forum. Just to say though LOL the wording is "Where Necessary". But that is the whole issue for me to open to interpretation, especially in relation to fire. That's why i much prefer dealing with legionella, really straight forward must do this, must not do that.

Not sure if you would know Tom but have been trying to find, how often a Fire Door needs to be inspected, this is just be a competent person not a fire safety officer or outside agency. And cannot find anywhere as far as i am aware this is every six months, and more often depending on foot fall and use. But what really annoys me is having to pay for British Standards, you don't know where can get for free do you. Would you agree also that BS are not the law to follow, but guidance.?

 

Thanks Stay Safe 

 

Magic

[AnthonyB]

British Standards are not law (unless of course a statute specifically requires conformity to them) but are often used as benchmarks to judge what is suitable. Compliance with a BS implies (but does not guarantee) compliance whereas not following it requires you to demonstrate why what you are doing instead is still safe (which is sometimes possible).

For example if you just did basic in house checks every week or month and a thorough check say just once a year and all your doors were in good order you are unlikely to face enforcement action even if you aren't following the BS.

This may however change for buildings containing two or more dwellings as the guidance (& the BS it refers to) is being given back door statutory status by changes in the Fire Safety Act.