01 August 2006
Dave Sibert

There has been heightened interest in the subject of fire safety and precautions recently as we approach the October implementation of the Regulatory Reform (Fire Safety) Order 2005 (FSO) - interest sustained by several delays in the FSO's implementation. The renewed attention paid to fire risk assessment can only be a good thing, but all the excitement about the new regime should not create the impression that it will reinvent the wheel.

According to the Regulatory Reform Act 2001, a Regulatory Reform Order cannot remove necessary "protections", and any "new burdens" which it imposes must be "proportionate". As a result of these restrictions, the FSO introduces nothing fundamentally new. If a business is complying with current fire safety legislation, it will be complying with the Order when it takes effect. If a business is concerned that it will not be able to comply with the FSO when it comes in, then it is not complying with fire safety legislation now. This means the points below about fire risk assessment apply equally to current as well as future legislative controls.

The most crucial point is that fire risk assessment is an identical process to health and safety risk assessment. And yet many people, even those with years of experience in health and safety, have great difficulty applying risk assessment principles to fire safety issues.

Responsible and competent

Under the present legislation, the requirement to have an up-to-date fire risk assessment comes from the Management of Health and Safety at Work Regulations 1999. Consequently, the assessment must be carried out by the employer. Under the FSO, the responsibility will be moved to the "responsible person", that is, the person "in control of the workplace".

In either case, the fire risk assessment must be "suitable and sufficient". To produce a suitable and sufficient piece of work, a person must have "sufficient training and experience or knowledge and other qualities". That is, they must be "competent".

What everyone wants to know is whether or not they are deemed competent to carry out a fire risk assessment. Unfortunately, the only person who can tell you for sure is the judge who tries the case after one of your buildings catches fire. Having said that, it would be a good start if you take whatever fire risk assessment tool you use, and compare it against the diagram on page 16. Your knowledge of fire may be limited, but there is no excuse not to apply proper risk assessment methodology to the process.

It is worth restating that fire risk assessment should be carried out in exactly the same way as a health and safety risk assessment; the only difference is that instead of looking for causes of slips, trips and falls, you are looking for causes of fires and explosions.

• Sources of ignition and fuel: to be competent to recognise a trip hazard usually requires little training. But most people will not know that a static discharge from the human body will ignite petrol, while a burning cigarette end will not, nor how likely a toaster is to start a fire in a kitchen. To produce a fire risk assessment that is suitable and sufficient while not excessive, you need a good understanding of the mechanisms of ignition and combustion.
• People at risk: the two sides of a risk assessment are risk and hazard. Here again, with most health and safety risk assessments, we are often only concerned with events which could injure one or two people. With a fire risk assessment, we may need to think about smoke filling a space occupied by tens or hundreds of people. Suddenly, it is no longer enough to know what the direct effect of the event will be on an individual. To be competent, a person needs to take account of group behaviour, and the complex nature of human behaviour in fire.
• Degree of risk: to assess the degree of risk faced by people, a competent person needs an understanding of fire growth, fire spread, and the effects of smoke and heat. They also have to understand the contribution which would be made by fire protection and control systems installed in the building, their limitations and potential causes of failure. Would fire compartment walls be effective at containing heat and smoke? Are fire doors properly maintained and likely to work? Is the fire detection system going to be effective?

So to recap, to be a competent fire risk assessor, a person needs to know about risk assessment methodology, ignition, fire development, human behaviour and fire safety systems. Of course, the depth of knowledge which a person would need in these areas depends completely on what is being risk assessed. Almost anyone would be competent to carry out a fire risk assessment of a small fishmongers, but you would probably need letters after your name to be deemed competent to assess a large shopping complex. If you feel you are deficient in the areas outlined, you need training before carrying out the assessment or to appoint someone who is already competent to do it for you.

Continuous inconvenience

Let's say I operate a building site where employees work on roofs. I have carried out a risk assessment, and provided guard rails and harnesses. Next year, I will have another look round the building site to review the assessment. Is that good enough, or should I make sure that my staff are actually wearing their harnesses on a day-to-day basis? Clearly, the answer is that only regular checking is acceptable.

Many firms carry out a fire risk assessment once a year (suitable and sufficient or otherwise), then never think about it again for the next 12 months. Why does this happen? The blame lies with the Fire Precautions Act 1971. Under the Act, the fire officer would walk round the workplace once a year to inspect it against the fire certificate. The concept of an annual inspection has been so ingrained into UK industry that even with the introduction of the risk assessment approach - which came in with the Fire Precautions (Workplace) Regulations 1997 - the yearly inspection has remained.

Much of the guidance relating to fire risk assessment describes the occasions that should trigger a review of the assessment: changes of staff, changes in processes, and so on, with an annual review if there are no other changes. People take this guidance too literally, and fire safety checking becomes an annual inconvenience.

In fact, just like any other health and safety risk management measures, fire safety should be a continuous inconvenience. Although the overarching fire risk assessment should be fully revisited at specific intervals, the workplace needs monitoring continuously to make sure that no one has introduced new risks. Control measures implemented as a result of the assessment must be audited monthly, weekly, daily, to ensure that they are going to work if needed.

Your fire risk assessment is a search for sources of fuel and ignition, and for people at risk. It is then an assessment of the magnitude of the danger they face. This assessment should be reviewed as appropriate.

Once you have completed your risk assessment, you should eliminate or reduce the risk wherever possible, and then install appropriate protection measures to deal with residual risks. These control measures must be monitored and audited as often as once a day or more.

If you carry out your fire risk assessments by using a checklist which asks "Are fire exit routes kept clear?", you are probably missing the point. Fire exit routes are a control measure which have been provided because your fire risk assessment said that they were needed to address the residual risks of fire. Whether or not they are kept clear is a monitoring process which needs to be carried out continuously - not once a year.

If you can take this distinction on board, then you have successfully broken free of the Fire Precautions Act 1971, and you are well on your way to competence in fire risk assessment.

Dave Sibert is senior fire engineer at the Fire Protection Association (FPA). www.thefpa.co.uk

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Fire, Management skills, Qualifications, Risk assessment, Training, Risk assessment, Article, Training