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Posted

Just a quickie about testing fire alarms in commercial premises:  From a fire risk assessors perspective, is it a statutory requirement for a client to test the fire alarm (emergency lights, ventilation systems, automatic door closers, etc.) or a recommendation based on the relevant British Standard?

This might be hair-splitting or just plain pedantic, but my thoughts are it's not illegal not to do it (although the outcome of not doing so may become a legal matter)

Thank you.

Posted

It's a legal requirement in Article 17, there needs to be a suitable system of maintenance, not just that the precautions are in working order. You will get enforcement action if you fail to do it and you will get convicted if there are prosecutions for non compliance.

What is more flexible is the 'suitable system'. By default it's the British Standards (as that's what enforcers and magistrates will use for reference) but it's true there is wiggle room - e.g. Sainsbury only test fire alarms monthly rather than weekly (still daily for visual checks and 6 monthly for servicing). However they had to go to a lot of effort & some expense to put a case together that was acceptable to their enforcement Primary Authority.

Posted

Thank you.  Sorry for my delayed response - I didn't receive notification that you'd responded!

The Sainsbury's case you mentioned would indicate it can't be a statutory requirement, or they would/could have been prosecuted, even if they did put a case together to prove an acceptable alternative - therefore an assessor could only recommend they did it properly, not require them to do it properly?  I think!

Thanks again ?

Posted

It's not that clear cut - the default system of maintenance is weekly testing plus 6 monthly servicing set by the benchmark. If you don't test at all that's a clear breach of Article 17 and an easy prosecution. If you do it but not weekly the onus is on the Responsible Person to prove it still meets the functional requirements of Article 17. Sainsbury's did this by analysing inspection, test and servicing information for every single store of every size over a year or two (not a little undertaking!). They were able to prove statistically that the vast majority of faults in systems were uncovered on the daily recorded visual inspection by the manager or as part of the more detailed checks & tests during the 6 monthly service and very few of the faults only came to light during the weekly test. This information was accepted by their Primary Authority (UK wide organisations can, for a fee, select a single fire service as their gatekeeper for enforcement and advice to ensure consistency of enforcement across their properties)

The onus is on the Responsible Person to prove they can do something other than the benchmark and this requires their competent person to be on board - unless they put the case forward and it stands up then they would be expected to comply with the benchmark and would get enforced against if they do otherwise.

It's quite possible to put cases to vary from the standards together, I've done it several times, just has to be done properly.

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