Fire Risk Assessment

Risk Assessment Guidance Update

The risk assessment guidance PAS 79 has recently been updated. Colin Todd explains

BSI British Standards has issued an updated version of PAS 79 Fire risk assessment. Guidance and a recommended methodology, to take account of the UK's new fire safety regimes.

The Publicly Available Specification (PAS) gives a nine-step structured approach and corresponding documentation for carrying out and documenting significant findings of fire risk assessments in buildings. The new 2007 version of PAS 79, now available from BSI, supersedes the 2005 edition and introduces the following main changes:

This article charts the history of PAS 79 and the reasons why the guidance was first produced, as well as explaining the revisions that feature in the new 2007 version.

Legislative background

Fire risk assessment is now the sole, underpinning for fire safety legislation in occupied buildings. Prior to December 1997, the fire safety legislation under which fire precautions were controlled on an ongoing basis took the form of a complex and disparate morass of primary and secondary legislation. The cornerstone of this jigsaw puzzle of around 150 pieces of legislation was, of course, the Fire Precautions Act 1971.

The situation was made more complex when, in 1997, Great Britain introduced the Fire Precautions (Workplace) Regulations, with guidance from the Government that could, at best, be described as sparse. The paucity of guidance was exacerbated by the absence of any definitive requirements, either in the legislation or the associated guidance, in what was to constitute the ‘suitable and sufficient' fire risk assessment required by the legislation.

For some years, many enforcing authorities failed to enforce vigorously the requirements of this legislation, including the requirement to carry out a fire risk assessment. In part, this situation arose from advice to enforcing authorities by the Government to adopt the ‘lighter touch' in enforcement.

It could be argued that this was not seriously detrimental to fire safety in workplaces. In general, the certification regime under the Fire Precautions Act formed a ‘safety net' in the case of premises for which the employer had failed to carry out the fire risk assessment.

Suitable and sufficient assessment

The situation described above resulted in ongoing uncertainty as to what really did constitute a suitable and sufficient fire risk assessment. What should be included in the fire risk assessment? How much detail should be recorded? To what extent were measures to prevent fire required to be considered?

Improved guidance was eventually produced by the Government in the form of Fire Safety – An Employers' Guide. However, this guidance was still not definitive on the subject of fire risk assessment. It adapted the five steps to risk assessment promulgated by the health and safety profession, but these did not fit perfectly to a fire risk assessment; the uncertainty continued.

The lack of definitive guidance on fire risk assessments arose, in part, from a desire on the part of Government to avoid being prescriptive. The thrust of the Workplace Regulations was non-prescriptive, and there was a clear policy to move away from what many had claimed to be the over-prescriptive approach adopted in previous legislation; this philosophy extended to the avoidance of any clear definition of the content and format of a suitable and sufficient fire risk assessment.

This led to difficulties for employers and their advisers. Many employers simply did not know where to begin. There was no specification for fire risk assessments, against which they could seek quotations from consultants. Moreover, the deliverables of each consultant would be likely to appear entirely different; each might or might not be suitable and sufficient, but who was to judge and how? Meanwhile, inspecting officers of enforcing authorities were not in a much better position, as they had little more guidance available to them than the employer.

Competence of assessors

The situation was exacerbated by an absence of benchmarks for the necessary competence of those who carry out fire risk assessments. This created further difficulties for employers. Should someone internally carry out the assessment, or should the employer engage consultants? If consultants were brought in, what level of competence should be demanded by the employer?

To assist employers in this respect, the Institution of Fire Engineers (IFE) developed a register of those who, using objective criteria, they deemed to be competent to carry out fire risk assessments. A number of other professional bodies have subsequently followed this lead and created similar registers.

It is a matter of public record that around 40% of applicants fail to achieve registration. This was of concern to the IFE since, very often, samples of applicants' fire risk assessments were not considered by the IFE to satisfy the requirements of legislation. This reinforced the need for appropriate guidance on fire risk assessment, as well as suggesting a need for benchmarks in respect of competence.

Why a PAS?

Unsurprisingly, the BSI had, during this period, received numerous enquires from the public as to whether they had produced relevant guidance on fire risk assessment. Unfortunately, no BSI guidance existed.

To start afresh and develop a full British Standard on the subject would have taken several years. In contrast, the need for guidance was pressing and was about to become more urgent with the future fundamental reshaping of fire safety legislation – which has now come about with the introduction of the Fire Safety Order in England and Wales, and similar legislative change in Scotland and, from next year, Northern Ireland.

BSI's first thought was to commission a textbook on the subject. However, a textbook would only have constituted one author's personal ideas on fire risk assessment. Not only would this have been unlikely to constitute a consensus within the profession, but it might have ended up as a prescriptive methodology and, hence, contrary to government policy.

In consultation with fire consultants, C S Todd & Associates Limited, it was decided to publish guidance in the form of a PAS. A PAS is a sponsored fast-track, published by BSI following consultation with key interested stakeholders and industry sector experts. The benefit of publishing guidance on fire risk assessment as a PAS was that it can be produced much quicker than a full British Standard, so satisfying the urgency of the requirement for guidance. However, unlike a book, the PAS would have some authority in view of consultation with, and comment by, stakeholders within the industry.

Producing the PAS

It was agreed that PAS 79 would be drafted by C S Todd & Associates. However, a wide range of stakeholders was defined to create a review group. This comprised a number of major end-users, fire consultants, the Fire Protection Association, trade associations and professional bodies (such as IFE, the Institute of Fire Prevention Officers and the Chief Fire Officers' Association (CFOA)). From these stakeholders, a smaller group was formed to act as a steering group to review the comments of the wider group. The document was thereby finalised and published as PAS 79: 2005.

A key feature of PAS 79 is that it is non-prescriptive. It does not, in any way, specify how the fire risk assessor should go about his business or even the format of the documented fire risk assessment. Instead, it sets out nine key steps that need to be carried out in assessing the fire risk in any building. There is, however, no suggestion that the format of the document should follow the nine steps. Indeed, PAS 79 openly acknowledges that there is no right or wrong way of carrying out, or documenting, a fire risk assessment.

In effect, the nine steps create a benchmark or framework for the suitable and sufficient fire risk assessment that legislation requires, enabling the fire risk assessor to adopt their own individual approach and their own format to documentation. It provides the employer or fire risk assessor with a specification against which any reasonable fire risk assessor should be able to quote, without necessarily having to modify their own approach. PAS 79 also suggests broad benchmarks for the competence of fire risk assessors; these are based on IFE policy on this matter.

One of the difficulties that many fire risk assessors appear to have is defining the scope of the fire risk assessment and a suitable manner for documenting the significant findings. This brings us back to the difficulties experienced by some applicants to the IFE Register. Some unsuccessful applicants simply let themselves down by their documentation. The view of the IFE was that, if these fire risk assessors were simply given guidance on approach and documentation, they would be perfectly competent to carry out fire risk assessments. Accordingly, the IFE strongly supported and encouraged the development of PAS 79.

For those who had difficulty in developing a suitable format for documentation of the significant findings, an annex to PAS 79 contains a proforma which, if completed by a competent person, should inexorably lead to a documented fire risk assessment that will comply with PAS 79. The proforma is also provided electronically to purchasers of PAS 79 in the form of a CD. Nevertheless, the annex with this proforma is ‘informative', rather than ‘normative'. This means that, following the principle of non-prescription, it is not necessary to use this proforma in order to comply with the recommendations of PAS 79. Rather, any format can be used for compliance, provided it follows the recommendations within the PAS, of which the informative annex does not form part. The informative annex is merely there as an example of a suitable format that can be used if the risk assessor does not wish to develop their own compliant format.

2007 version – what's new?

Obviously, there was a need for substantial revision of PAS 79 to take account of the changes in legislation introduced by the Fire Safety Order, etc. This is not a simple change, as three legislative regimes now exist, namely that in England and Wales, that in Scotland and the unchanged legislation in Northern Ireland (which will not change until next year). In order to cater for these three regimes, three different proformas are provided on the CD that now accompanies PAS 79, both for documenting a fire risk assessment and review of an existing fire risk assessment.

However, there is more to the revision than simply a tweaking of the legislation. The opportunity has been taken to examine, in full, all the previous commentary and recommendations and to amend or expand these when appropriate. For example, within the proforma, there was previously a single point relating to fire procedures. It is not possible to do justice to the broad subject of the emergency plan and the fire procedures it incorporates within a single point in the fire risk assessment. Accordingly, the original single point has been expanded into a number of different points, all of which would now need to be considered if the proforma in the informative annex is used.

The scope of the recommendations and the proforma has also been expanded to take into account expansion in the legislation to address, for example, dangerous substances and, in England and Wales, firefighters' switches for high-voltage discharge lighting.

The experience of users of PAS 79 has been taken into account, with improvements to address additional areas, or to address matters differently, where it was considered that there could be ambiguity or a shortfall in the level of consideration. An example relates to fire dampers. It is very difficult in a fire risk assessment to obtain relevant information, whether by inspection or questioning, on the provision of fire dampers in heating, ventilation and air-conditioning ductwork. However, especially in sleeping risk premises, the provision of these, and their method of actuation, will be critical to the safety of occupants. Accordingly, the recommendations and the model proforma now drive fire risk assessors to give specific consideration to fire dampers.

The amendments and additions to PAS 79 were significant enough that it was necessary for the new draft to undergo complete review by the original review group (with modifications and inclusion of some additional stakeholders). Once again, the comments of the review group were considered by a steering group comprising selected members of the review group. BSI and the authors were particularly grateful for the support, in this exercise, of CFOA. In particular, CFOA was content to acknowledge that PAS 79 does not conflict with the guidance supporting the new fire safety regimes produced by the relevant government departments, but that PAS 79 expands that guidance in respect of fire risk assessment, while the government guides provide greater detail on design of fire precautions. The format of the proforma contained in the annex is considered by CFOA to be one suitable format for recording the significant findings of a suitable and sufficient fire risk assessment, although many other formats are also acceptable.

In due course PAS 79 may be turned into a full British Standard. In the meantime, those with the need to carry out fire risk assessments, whether as employers or consultants, now have an up-to-date benchmark for a suitable and sufficient fire risk assessment that has a consensus among a broad range of stakeholders within the fire safety profession.

Article sourced from www.fp-fej.com
Colin Todd is technical author of PAS 79 and managing director of C S Todd & Associates Limited
This article is based on a version that was first published in the Institute of Fire Prevention Officers' publication, Fire Safety Professional
PAS 79: 2007: Fire risk assessment. Guidance and a recommended methodology is available from website: www.bsi-global.com/PAS79
Information on the IFE Register of Fire Risk Assessors and Auditors is available from website: www.ife.org.uk/frr

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