The Regulatory Reform Fire Safety Order (RRFSO) and Healthcare guidance document – Llandrindod Wells 10 May 2006

Prof David Charters, PhD, CEng, FIFireEDirector of Fire Engineering

Presented by Nigel SmithiesDirector BRE Fire & Security

REFORM OF GENERAL FIRE SAFETY LAW

The Regulatory Reform (Fire Safety) Order 2005

Andy Jack

Head of Fire Safety Legislation Branch

REFORM OF GENERAL FIRE SAFETY LAW

The Regulatory Reform (Fire Safety) Order 2005

Andy Jack

Head of Fire Safety Legislation Branch

WHY REFORM?

Fire laws developed over time

Piecemeal development

Often resulting from large tragic fires

Fire laws developed over time

Piecemeal development

Often resulting from large tragic fires

RESULT OF PIECEMEAL DEVELOPMENT

Many pieces of legislation apply at the same time, with different enforcers

The morass of law is difficult to understand

Many pieces of legislation apply at the same time, with different enforcers

The morass of law is difficult to understand

WHAT DOES THE REFORM MEAN?

Consolidated law with fewer enforcers

Key tool for business and enforcers to prevent fires and save lives

Elevates prevention to the same level as protection

Consolidated law with fewer enforcers

Key tool for business and enforcers to prevent fires and save lives

Elevates prevention to the same level as protection

WHO IS RESPONSIBLE

Employers (where there is one)

Occupiers (includes the self employed)

Owners

Others where they have a contract or tenancy that gives them a degree of control over

safety issues (so included contractors who install and maintain fire protection measures)

Employers (where there is one)

Occupiers (includes the self employed)

Owners

Others where they have a contract or tenancy that gives them a degree of control over

safety issues (so included contractors who install and maintain fire protection measures)

NOT NEW - RIA

General requirement for risk assessment since 1992

Fire specific requirement for employers since 1997

Fire specific law over-rides other non-fire specific law (e.g. conditions of licence).

Risk based fire precautions over-ride set fire conditions (e.g. fire regs over-rode a fire

certificate)

General requirement for risk assessment since 1992

Fire specific requirement for employers since 1997

Fire specific law over-rides other non-fire specific law (e.g. conditions of licence).

Risk based fire precautions over-ride set fire conditions (e.g. fire regs over-rode a fire

certificate)

Publicity for the RRFSO

• Series of Road Shows has just come to an end.• Main publicity Starts ~16 weeks prior to commencement

date ie ~ June 2006.– A3 flier to all employers in England and Wales is first

phase (1Million +) – this may be sufficient guidance for small premises.

– Web– Advertisements in the press.– Advertisements on local radio.– On-line pre-ordering for the guides.

Overview

• Background to the RRO• Guidance documents• Fire risk assessment process• Healthcare guide• Summary

Introduction

• A fire risk assessment must be carried out. If you employ five or more people etc you must record significant findings actions to be taken etc

• This is different from carrying out a fire precautions survey of your building.

• The fire risk to people must be reduced to as low as reasonably practicable

• Not just accidental fires - the risk of Arson is to be taken into account

• Enforced, primarily, by the Fire & Rescue Service -Penalty – up to two years imprisonment

Fire risks in different occupancies

Occupancy Casualties/year

Casualties/occupant.year

Probability of casualty/year

Dwellings 6287 1.1 x 10-3 1 in 910

Hotels 98 2.5 x 10-4 1 in 4,000

Banks…etc 44 1.6 x 10-5 1 in 63,000

Public administration 194 1.4 x 10-4 1 in 7,100

Schools 43 4.1 x 10-6 1 in 240,000

Further Education 10 1.2 x 10-5 1 in 83,000

NHS 43 3.4 x 10-5 1 in 29,000

Background• Regulatory Reform (Fire Safety) Order (RRO) will

consolidate existing fire safety legislation, the person responsible for premises is under duty to take general fire precautions and to undertake a fire safety risk assessment to safeguard safety of all people in case of fire at all times

• Same duty imposed on employers by the Fire Precautions (Workplace) Regulations 1997

• Duty under the Order will be extended beyond workplaces to include the majority of premises to which people have access

• Order will be supported by a suite of eleven guidance documents for the majority of premises under which the order applies

RRO (Fire Safety) Guides

Guide Use

Fire safety in offices and shops All offices and retail premises

Fire safety in factories and warehouses All factories and warehouse storage premises

Fire safety in premises providing sleeping accommodation

All places where sleeping accommodation is provided, except hospitals, care homes, places of custody and single private dwellings

Fire safety in premises providing residential care

Suitable for all residential and nursing homes

Fire safety in educational premises Teaching establishments ranging from crèches through to universities

Fire safety in small and medium places of assembly

Public houses, clubs, restaurants and cafés, village halls, community centres, libraries, marquees, churches and other places of worship or study accommodating up to 300 people

Fire safety in large places of assembly Suitable for premises where more than 300 people could gather, eg shopping centres, large nightclubs, exhibition and conference centres, sports stadia, marquees,museums, libraries, churches, cathedrals and other places of worship or study

Fire safety in theatres and cinemas Suitable for all theatres and cinemas

Fire safety at outdoor events Suitable for all open air events, eg theme parks, zoos, music concerts, sporting events, fairgrounds and county fairs

Fire safety in healthcare premises All healthcare premises

Fire safety in the transport network Suitable for all transportation terminals and interchanges, tunnels and sub-surface railways.

Guidance documents

Guidance documents

• Primarily aimed at the lay person, although can be used by enforcers

• Guidance documents to be published prior to order coming into effect

• Documents to be based on a template document (Offices and Shops)– Part 1 Fire risk assessment (5 Step process)– Part 2 Further information on fire risk assessment and

fire precautions– Appendices, providing further technical information– 120 pages

Offices and Shops

Means of escape:• Number of people• Mobility Impaired People• Protected corridor• Exit widths/stair capacity• Number of escape routes/exits• Travel distance• Lighting/signage

Evacuation strategy:• Total simultaneous/phased• Self evacuation• Protected routes

Patient care areas

Means of escape:• Number of patients• Dependency of patients• Number of staff• Sub-/compartmentation• Height above ground• Number of escape routes/exits• Travel distance• Lighting/signage

Evacuation strategy:• Progressive Horizontal Evacuation• Staff assisted (bed) evacuation• Protected refuge areas

Evacuation

Offices and shops:• Total simultaneous/phased• Self evacuation• Protected routes

Hospitals:• Progressive Horizontal Evacuation• Staff assisted (bed) evacuation• Protected/refuge areas

Part 1

Preface:• Not prescriptive standards, but guidance• Other fire risk assessment methods may be equally valid• Other arrangements acceptable subject to equivalency• Recent buildings acceptable subject to maintenance• Not for use in designing new buildings or alternations• Can be used to develop a fire strategy

Who should use the guide?

• Employers• Managers• Responsible persons• Occupiers• Employees• Owners of premises and• Enforcers.

• Less complex premises - no formal training or experience

• More complex premises - comprehensive training & experience

Responsible person

• Responsible person – responsible for complying:– Employer or – Other person having control:

• Occupier or • Owner

• ‘…requires fire precautions to be put in place “where necessary” and to the extent that it is reasonable and practicable in the circumstances of the case.’

• ‘…must carry out a fire risk assessment…of all “relevant persons”.’

• Expected to work together if there is more than one.

Other duties under the order

Include:– Appoint ‘competent person’ to implement fire safety measures– Provide information to employees about risks and safeguards– Consult employees or their elected representatives– Provide parents with information on risks before employing a child– Inform non-employees about risks and fire safety procedures– Cooperate with all responsible persons in a premises– Provide an employer working in your premises with information– Provide others employees with instructions and information– If not an employer, ensure compliance in areas for which you have control– Consider the presence of dangerous substances and risk to persons– Establish suitable means for contacting the emergency services– Provide information, instruction and training to employees– Provide maintenance of fire-fighting, AFD, means of escape…etc– Employees cooperate

What is a fire risk assessment?

• Aims are:– Identify fire hazards in the premises– To reduce the risk of those hazards causing harm to as low as

reasonably practicable– To decide which physical fire precautions and management policies are

necessary to ensure the safety of people in your building if a fire does start

• Definitions:– Hazard: Anything that has the potential to cause

harm.– Risk: The change, high, normal or low, of harm

occurring.– Responsible person: Someone who has control of the premises– Competent person: “Someone with enough training

and experience or knowledge and other qualities.”

5 Step processStep 1 Identify fire

hazards

Step 2 Identify people at risk

Step 3 Evaluate, remove, reduce and protect

Preventative measuresEvaluate the risk

Remove or reduce hazardsRemove or reduce the risks

to people

Protective measuresDetection and warning

Fire fightingEscape routes & Lighting

Signs and noticesMaintenance

Step 4 Record, plan, instruct, inform and train

Record significant findings and actions Prepare an emergency planInform relevant people…etc

Provide training

Step 5 ReviewKeep assessment under review

Revise where necessary

Step 1 Identify fire hazards

Checklists:

• Fuels

• Ignition sources

• Oxygen

Much of fire risk assessment is common sense ! Eg Minimising hidden risks such as poor fire stopping

Step 2 Identify people at risk

Including:• Patients, employees, visitors, contractors …etcEspecially:• Employees who work alone• People who are in isolated areas of the building• People who are unfamiliar with the premises• Patients who are dependent on staff• Others who may be mobility impaired or disabled• People who are not able to leave the premises quickly

Step 3 Evaluate the risks and take action

• Evaluate the risks of a fire starting

• Evaluate the risk to people from a fire starting somewhere in the building

• Remove or reduce the hazards that may cause a fire

• Remove or reduce risks to people from a fire

• Installation testing and maintenance

Step 4 Record, plan, instruct, inform and train

• Record significant findings and action

• Prepare an emergency plan• Inform, instruct, cooperate and

coordinate• Fire safety training

Step 1 Significant findings of firehazards

Step 2 People who are at riskfrom thehazards

Step 3 Remove or reduce the risk andcontrol measures to protect againstany residual risks

Step 4 Further action neededTrain, inform, instruct and coordinate

Deep fat fryer in staff changekitchen

Patients and staff

Safety lid fitted, and fire blanket provided

Staff not allowed to use fat fryer until safetytraining given.

High levels ofsmoking inbedrooms.

Patients and staff

Automatic water fire suppression system installed in bedrooms.

System maintained andtested.

Step 5 Review

• Changes in work processes (including equipment)• Alterations to the building (including internal layout)• Substantial changes to furniture and fixings• Change to storage of hazardous substances• Failure of the fire precautions eg AFD, a fire door• Significant changes to stock quantities• The presence of people with different or specific disability

(including change of ward type)

Part 2 Further information on fire risk assessment and fire precautions

Literature review of source and reference documents:• Guides will make reference to other publications• Part 2 is 80 pages• Relevant guidance which will become defunct with the

introduction of the RRO will be reviewed with salient and relevant points incorporated:– Home Office guides– HTM 86

Part 2 Further guidance on…Sections:

1 Fire risks and prevention measures2 Fire detection and warning systems3 Fire-fighting equipment and facilities4 Escape routes5 Escape route lighting6 Signs and notices7 Recording , planning, informing and training

AppendicesA Review checklistB Fire resisting separation, fire doors and door fasteningsC Historic buildingsD GlossaryE Nucleus fire precautions

References

Examples – Further guidance

1.13 Restricting the spread of fire and smoke:“To reduce the risk to people if there is a fire, you need to consider how to control or restrict the spread of fire and smoke”

Textiles and furniture“Information on textiles and furniture is available in FIRECODE HTM 05-03 Operational Requirements, Section 3 ‘Textiles and furnishings’.”“The use of flame-retardant bedding, upholstered furniture and soft furnishings will substantially reduce the fire risk “

HTM 86 Fire risk assessment in hospitals:“Acceptable (SHTM 85 Standard)

The hazard is acceptable, if more than 75 % of all items of textiles and furniture achieve the standard required in HTM 87, and there is an agreed policy of planned replacement and maintenance to comply with HTM 87 ‘Textiles and furniture’.”

• .

Examples – Further guidance

1.16 Arson:• Outside well lit/secure perimeter fence, if practical• Secure entry points, as appropriate• Regularly remove combustible waste• No skips adjacent to the building• Encourage staff to challenge people acting suspiciously• Remove automatic entry rights to previous staff• Ensure that security and fire alarm are monitored/actioned• Secure flammable liquids against use by intruders• Fit secure metal letter boxes…etc

Examples – Further guidance

1.17 People especially at risk:• Those at high risk include patients who have low mobility, alertness or

responsiveness, eg:– Those who cannot walk, either with or without assistance;– Those with learning difficulties;– Those who suffer from mental illness.

• Those at even higher risk include patients whose clinical treatment and/or condition creates a high dependency on clinical staff, eg:

– Intensive therapy units;– Special care baby units;– Operating departments.

Examples – Further guidance

4 Further guidance on escape routes:High risk features:

• Patient dependency• Height above ground• Adjacent to high fire load departments• Poor overall management of the premises• Low numbers of trained staff on duty• Large protected areas• Poor fire resisting separation• Escape routes are long and poorly defined• Smoking is not controlled…etc

Medium and low risk features also listed.

Example - Further guidance

4.2 Typical building examples:• Ground to second floor premises with high risk patients:

– High level of observation or;– High standard of detection and alarm system or;– High number of staff on duty or;– An automatic suppression system or;– A combination of:

• Short travel distances and;• A high degree of refuge and;• Escape lighting throughout the ward and;• Escape bed-lifts

• …etc

Summary

• Regulatory Reform Order (Fire Safety) on the statute books (2005)

• 11 New guidance documents to be published soon• Healthcare guide:

– Extensive– More fundamental approach, particularly to fire hazards– Fire precautions ‘consistent’ with HTM 86 standards

• Expected to come into force October 2006

• Registers, training, schemes: IFE, ABE, BRE…www.ife.org.uk www.abe.org.uk www.bre.co.uk

Figure 1 - Full-scale test rig for hospital ward smoke damper tests

side elevation

plan view

7.3m

2.9m

to main extract fanintumescent damper

supply fan

extract ducting supply ducting

door bedbed

patientchairs

window

bedsidelocker

bedsidelocker

patient'slockers

visitor'schairs

patient'schairs

patient'schairs

bedsidelocker

visitor'schairs

window

5.7m

7.3m

bed bed

bedbed

intumescent damper

supply fan

patient'slocker

patient'slocker

supplybranch

mainsupplyduct

extract duct

plasticvisitor'schairs

plasticvisitor'schairs

ignition source

ignition source

smokedetectors

smokedetectors