The Responsible Person’s duty is to make sure that a suitable and sufficient fire risk assessment is implemented, and that there are adequate fire safety measures in place. Examples of this include having suitable evacuation procedures, control measures for those more likely to be at risk in the event of a fire, to maintain fire detection and alarm systems, as well as fire fighting equipment i.e. fire extinguishers, sprinklers and suppression systems etc.
Guidance
British Standards such as BS 9999 (Fire safety in the design, management and use of buildings. Code of practice) and BS 9997 (Fire risk management systems. Requirements with guidance for use) both make recommendation for an organisation to implement a robust fire safety management system. Essentially, this should include all company policies, as well as site-specific roles, responsibilities, procedures, arrangements, monitoring, maintenance, testing and reviews that take place in relation to fire safety. This will help you demonstrate effective processes and compliance regarding fire safety, as well as combining all fire-related documentation into one accessible document. BS 9997 applies the ‘plan, do, check, act’ model to implementing, maintaining and improving a fire safety management system. This principle reflects that of the HSG65 management of general health and safety.
Where to start?
Firstly, you need to fully understand your organisation to determine and identify external and internal issues (both positive and negative) that may arise, and how these may impact your approach to achieving the intended results of your fire safety management system. Once identified, these should be documented, monitored and reviewed. This should include the following:
- Identify the links between your fire safety policy, your objectives and tolerance to risk;
- Consider issues arising from legal, technological, competitive, market, cultural, social and economic environments; and
- Establish who the relevant interested parties are and the requirements of each i.e. local authority, HSE, contractors, insurers, visitors, customers and shareholders.
Next, you need to determine the scope of your fire safety management system. Consider if this will include the whole of the organisation, specific and identified functions or sections of the organisation, or one of more functions across a group of organisations. When defining the scope of the fire safety management system, you should also document any exclusions; for example, the scope may extend to all properties where the organisation has direct control but does not include those that are leased to third parties or tenants.
1. Plan – establish the objectives and processes necessary to deliver results in accordance with your fire policy
The fire safety management system objectives may include life safety, property protection, business continuity and the environment. It is important that your objectives are:
- Consistent with your fire safety policy;
- Measurable;
- Considering applicable requirements;
- Monitored;
- Communicated; and
- Regularly updated.
When planning how to achieve your objectives, its important to document what will be done, what resources will be required (including technical expertise), who will be responsible, when it will be completed and how the results will be evaluated.
What should be included in a fire risk management system and the corresponding Article in the RRFSO?
- Resources and authority (Article 8 and Article 11);
- Competence/Fire safety training (Article 21);
- Communication (Article 8 and Article 11);
- Control of work on site (Article 9 and Article 20);
- Maintenance and testing (Article 17);
- Fire Risk Assessment (Article 9); and
- Emergency planning (Article 15).
2. Do – implement the processes
At this stage, you should be implementing the plan (including all those areas bullet pointed above) and making decisions regarding the preventative and protective measures that are required.
- Resources and authority (Article 8 and Article 11):
Whilst the appointed Responsible Person has the overall authority and responsibility of the fire safety management system, every person in the workplace must take account of their own health and safety as well as the health and safety of others.
- Competence/Fire safety training (Article 21):
All persons carrying out work under your organisation’s control should be made aware of the fire policy, relevant objectives set, their contribution to achieving these objectives, the implications of not complying with the fire safety management system requirements and any risks associated with them doing the work. Additional training will be required for appointed persons, which should be sufficiently detailed, to enable them to understand their role in the management of fire safety.
- Communication (Article 8 and Article 11):
What is being communicated? Who is doing the communication? With whom? How are they communicating? And how often?
An example of external communication would be sharing the significant findings of the fire risk assessment with tenants and listening to their fire safety concerns and documenting them in tenants’ meetings, as an example.
- Control of works (Article 9 and Article 20):
All proposed works, which fall into the scope of the fire safety management system, should be suitably risk assessed e.g. permit to work systems, and additional control measures implemented where necessary e.g. repair works to IT cabling through compartments.
- Maintenance and testing (Article 17):
Pro-active management, such as frequent inspections and checks of the workplace, demonstrates good fire safety control. You should plan, document, implement and manage the processes for maintenance and testing of the life and fire safety systems you have in place to make sure that they operate correctly in the event of fire.
- Fire risk assessment (Article 9):
Unlike the Health and Safety at Work Act section 2(3), Article 9 of the RRFSO requires Responsible Persons to have a written fire risk assessment regardless of how many employees they have. A fire risk assessment is a method to help determine the chance of a fire occurring in the workplace, and the severity of harm that may arise if a fire were to occur. This is accomplished by looking at the factors in your work activities and workplace, which could cause harm and who could be harmed. From this assessment precautions can be determined to make sure that risks are reduced to prevent fire from occurring. Fire risk assessments should be regularly reviewed to make sure they are accurate and up to date.
- Emergency planning (Article 15):
Emergency planning in respect of a fire safety management system should aim to produce methods for identifying and responding to major incidents, where the scale of disruption is greater than normal. This should include who, what, when, where, why and how? Is there a fire attack plan? How do we liaise with the emergency services? Is there a post-incident plan? And what is the contingency plan in place?
3. Check - monitor and measure processes against fire policy, strategic objectives, and legal and other requirements, and report the results
Performance must be continuously measured to make sure that what is being done is sufficient, and that you are compliant with relevant legislation. This can be achieved via management reviews, internal audits, or external independent audits. Performance must also be measured so that you can assess how well you are meeting the aims set out in your company policy. This is where you need to determine what needs to be monitored and measured (e.g. incidence of false alarms, competence, emergency evacuation drills, response to incidents and your fire risk assessment), as well as what methods will be used for monitoring (e.g. review of documentation, statistical trends, benchmarking against other organisations, or changes in legislation).
4. Act - take actions to improve fire risk management performance continually
This is where you will review your performance. At this stage you should be able to demonstrate continual improvement of the suitability, adequacy and effectiveness of your fire safety management system.
This guide is of a general nature; specific advice can be obtained from Assurity Consulting. Assurity Consulting is the UK's leading independent compliance consultancy specialising in workplace health, safety and environmental solutions. We have over 35 years' experience of helping customers of all sizes, from across all sectors, manage their compliance responsibilities, making sure that their organisation is compliant, their employees are safe, their processes are cost effective and their management team is in control.