... so, let's begin this article with some extraordinary facts - there currently is no statutory control or licence over Fire Risk Assessors! ... anyone can be one! ... anyone can prepare a Fire Risk Assessment upon which others may have to trust their lives! ~ "that's insane isn't it?" ...
The Institute of Construction Management on 23 November 2018 launched the National CDM Competence Registry™® in the Skills Hub at London Build 2018 in London Olympia [reported in an earlier blog article]- in this article David Jones explores issues around the uncertain competence of those who may currently assess FIRE RISKS in buildings and the real and certain danger nightmare scenario for those who have to rely upon questionably defective assessments!
Since the launch event David Jones - Director of Education & Training at ICM has received the shocking and chilling reported revelation that nearly 50 English councils have actually used unregistered fire risk assessors to check if their buildings are safe, [research by Luke Barratt - business reporter at Inside Housing] ...
... while the law does not require fire risk assessors to be registered or meet any professional standards, guidance from the Fire Risk Assessment Competency Council (FRACC) advises building owners to use fire risk assessors listed on one of eight registers run by third-party accreditation bodies. "whilst acknowledging any registration that sets professional standards and guidance is essential but, having eight competing registers to choose from may actually create some uncertainty as to what is best?" suggests David Jones ...
One hundred and twenty-eight councils responded to Freedom of Information requests about their fire risk assessors, with 46 saying they had used at least one unregistered assessor since 2010. Of these, 23 said that none of the assessors they had used since 2010 were registered. A further 56 did not know whether their assessors were registered, and only 26 said all their assessors were registered.
David Jones has managed a number of large in-house property and construction teams of professional officers across three London local authorities and is personally shocked and appalled at the revelation! "as the truth of what caused the sad disaster at Grenfell Tower unfolds in the Inquiry - even though Phase 2 has yet to be started - we've heard enough! - robust immediate action MUST be taken NOW!" says David Jones ...
... "this isn't rocket science!" is an opener I often lead on when explaining the science and basics of 'Fire' when training folks to the appointed role of a Responsible Person under the Regulatory Reform (Fire Safety) Order 2005 which is the current law - "it's all basic secondary school stuff really - but, sadly, many of those who should know and profess to know simply don't!" says David Jones .. let's explore ~
What is Fire?:
Fire is simply the visible effect of the process of combustion - a chemical reaction that involves the process of burning - and, it is a special type of chemical reaction that occurs between oxygen in the air and some sort of fuel. The products from the chemical reaction are completely different from the starting material. There are only three things to understand - and by removing any one no combustion can occur at all ...
The fuel must be heated to its ignition temperature for combustion to occur. The reaction will keep going as long as there is enough heat, fuel and oxygen - the three things! This is known as the fire triangle ...
Combustion is when fuel reacts with oxygen to release heat energy. Combustion can be slow or fast depending on the amount of oxygen available. Combustion that results in a flame is very fast and is called burning. Combustion can only occur between gases.
Fuels can be solids, liquids or gases. During the chemical reaction that produces fire, fuel is heated to such an extent that (if not already a gas) it releases gases from its surface.
Only gases can react in combustion. Gases are made up of molecules (groups of atoms). When these gases are hot enough, the molecules in the gases break apart and fragments of molecules rejoin with oxygen from the air to make new product molecules – water molecules (H2O) and carbon dioxide molecules (CO2) – and other products if burning is not complete.
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Oddly there is no legislative requirement for the fire risk assessment to be carried out by a competent person. It is said that this is to avoid an implication that every duty holder under the legislation needs to employ the services of a fire safety specialist, such as a consultant, to carry out their fire risk assessment.
For small, simple premises, it is often the duty holder that carries out the fire risk assessment. Arguably, it is reasonable to assume, in these premises, the duty holder is probably the best person to do so because of their intimate knowledge of the premises and the activities therein - however, even those duty holders must have a sufficient level of understanding to be able to safely undertake such task themselves! Guidance to support those wishing to carry out the fire risk assessment themselves has been made available by the Government. The Fire Protection Association has published its fire risk assessment guidance booklet which outlines the principal duties of the responsible person/dutyholder under existing UK fire legislation. It guides through the fire risk assessment process, offering examples of potential sources of ignition, the people at risk, and how to assess existing fire safety measures. In most circumstances it will be necessary for whoever is preparing the fire risk assessment to record the findings of the risk assessment for which a template has also been made available - details are on the booklet which can be accessed by CLICKING HERE.
However, for many premises, the duty holder seeks the services of an external consultant (‘a fire risk assessor’). In the case of larger, more complex or high risk premises, this is often appropriate, as the task might well be beyond the ability of the duty holder.
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Some members of the business community and sector have suggested that it would be helpful for those who want to use the services of a commercial fire risk assessor to be able to access information on those with an appropriate level of competency in fire risk assessment to help them comply with the legislation. There has also been growing concern regarding the competence of those who provide these fire risk assessments on a commercial basis (i.e. for a fee).
Data from the English Fire and Rescue Service suggests that the main compliance failure leading to enforcement action is a failure by duty holders to carry out a suitable and sufficient fire risk assessment. This is coupled with the emergence of inadequate fire risk assessments for premises that have suffered multiple fatality fires.
As a result of these concerns, the Fire Risk Assessment Competency Council, which comprises a broad group of relevant stakeholders (listed as participants), emerged from the fire sector with the encouragement of Government. Its objective has been to establish agreed, industry-wide, criteria against which the competence of a fire risk assessor can be judged.
David Jones confirms the National CDM Competence Registry™® will include Fire Risk Assessors [at all levels] and will use these criteria to register accreditation from third party certification. While David Jones currently accepts that it is unlikely that third party certification of this nature will become mandatory under legislation, Government does seem to acknowledge the benefits to duty holders of third party certification of fire protection products and services as a means of guiding and assisting in compliance with legislation. This includes fire risk assessment services and, having a national unified formula for competency that all can understand, compare, and benchmark against applied across the property and construction sector will better serve appropriate appointments are made ... so, let's explore in context ~
It is generally accepted a person is regarded as competent where they have sufficient training and experience or knowledge and other expert qualities to enable them to properly implement and undertake their role.
In the case of simple premises, where the fire risk assessor might, for example, be an employee of the occupier, it is possible that the following attributes of a fire risk assessor might be sufficient in conjunction with a study of suitable guidance documents. But, even in such a simple premises, any fire risk assessor will need:-
a) An clear understanding of relevant current best fire safety practices in premises of the type in question; b) A thorough awareness of the limitations of the fire risk assessor's own experience and knowledge; c) A willingness and ability to supplement existing experience and knowledge, when necessary, by being able to realise inadequacies and obtain external help, support and advice.
Complex premises will require a higher level of knowledge, understanding and, preferably, experience on the part of the fire risk assessor. Indeed, when Government decides to set up the new Joint Competence Authority those persons who undertake the new role of a Building Safety Manager on high-rise residential buildings [HRRBs] - defined as higher than 18 metres - will need to an appropriate level of competence covering the Regulatory Reform (Fire Safety) Orders; the Building Regulations; and the CDM Regulations ... in addition, such persons will need suitable soft skills in appropriate and effective communication to be the hub contact for lessees, tenants and residents to deal effectively with user concerns ...
For such premises, there will be a need for the specific applied knowledge and skills of an appropriately qualified specialist. In such cases, evidence of specialist training and experience, or membership of a professional body, or certification by a third party certification body, may assist in demonstrating competence. In general, other than in the case of simple, low risk premises, fire risk assessors, particularly those offering their services on a commercial basis, need an appropriate knowledge of:
Competence does not necessarily depend on the possession of specific qualifications, although such qualifications might contribute to the demonstration of competence and in the ICM's registration process. In context, knowledge can be obtained by academic study, training, working alongside others, short courses, continuing professional development or any combination of these.
Education is likely to involve formal education of a relatively academic nature, often culminating in a qualification. Training involves training of a practical nature, often given on the job.
It is not implied that education, training and experience in the principles of fire safety need each be extensive, provided that the combination of each results in adequate knowledge. Moreover, a high level in respect of any one of these might compensate for a lower level in another. It is essential that the level of competence be sufficient to allow the fire risk assessor to identify correctly the significant risks (especially combined risks) and to draw up a list of appropriate actions to address them.
London Fire Brigade believes that following a few simple steps often can ensure a person has a suitable and sufficient risk assessment and that people will be better protected from fire. Employers or occupiers or have some managerial responsibility over any non-domestic premises, then you will are probably legally obliged – as per the requirements of the Regulatory Reform (Fire Safety) Order 2005 – to conduct a fire-risk assessment. Even if you do appoint an external fire-risk assessor you, as the responsible person, can still be held accountable if mistakes are made. Although you are not expected to be an expert in fire safety, you should make reasonable checks to ensure that they are adequately qualified and experienced.
In small, low-risk premises you may be able to do the fire-risk assessment yourself, but if not and you are looking to employ someone else than it is wise to follow these steps:
1. Ensure they are on a professional register that and that they meet the competency criteria established by the Fire Risk Assessment Competency Council
2. Check that they have experience of undertaking fire-risk assessments for your kind of business and premises
3. Request references from previous clients in premises of your type
4. Ensure that the scope of the work you want carried out is agreed in writing
5. Ensure that you provide the assessor with access to all areas and information
6. Obtain alternative comparable quotes
7. Ask for proof that they have sufficient insurances
8. Keep records of the steps you took in selecting your fire risk
