The Secret Risk Assessor - August 2020

Various leading fire safety organisations wrote to the Government resulting in James Brokenshire, the Minister of State for Security, writing a letter to the Fire Industry Association to confirm the key worker status of individuals working within the fire industry.

Brokenshire observed: “With regards to school places, the guidance published by the Department for Education advises schools that they should continue to offer provision to the children of critical workers. I would expect schools to consider staff in essential roles in the fire industry to be critical workers.”

Having continued to undertake fire risk assessments in a variety of building types over the last few months, I thought I would address a question I’ve been asked on more than one occasion of late: “Can we turn a blind eye to some non-conformities due to the COVID-19 pandemic?” In my humble opinion, the short answer is ‘No’.

We should, however, exercise a degree of common sense in recording our findings. We can make reference to certain things that may not comply with British Standards or approved guidance without requiring a recommendation to be made, providing the control measures or the reasoning around the non-conformity are referenced and deemed suitable and sufficient. Let’s look at some examples to highlight this point.

Routine maintenance

“Do we have to undertake our routine fire equipment planned preventative maintenance?” There may be a little leeway for some such maintenance if the building is empty and no staff or contractors remain on site at all. However, if a skeleton crew of staff remain, or if engineers are undertaking other routine maintenance of building systems, then a certain number of key checks should still be completed.

Examples of key routines that should continue are the fire alarm testing, emergency lighting maintenance and fire extinguisher servicing, etc. If the building is occupied by anybody at all, or if there’s a chance that people may temporarily be on site then these checks would still be a key requirement.  

However, I would not be overly concerned if the kitchen suppression system maintenance visit was postponed due to the catering facilities having been placed out of use during lockdown in, for example, a hotel environment. In this case, my fire risk assessment would state the fact that the servicing hadn’t been done and explain both the reason why and that it should be undertaken prior to reopening. I would not ‘turn a blind eye’, but would not raise a significant finding either.

Similarly, I would have no concern with Portable Appliance Testing being postponed. However, the lightning protection system should continue to be maintained. In my opinion, the closure of the building will result in a lower risk posed by the use of portable appliances, but the risk posed by lightning doesn’t lessen because the building’s empty. It’s all about applying a degree of that mythical attribute called ‘common sense’.

Fire doors

“Can we wedge open our fire doors to restrict the risk of COVID-19 spread via the touching of door handles?” My short answer would be ‘Yes’, but again I would recommend referencing the situation in the fire risk assessment report along with a statement as to why you’ve deemed this to be acceptable.  

For example, fire doors are wedged in the open position in high footfall areas due to the risk of the spread of COVID-19. Suitable control measures include staff being trained to close the doors in the event of an alarm activation.

“Do we need to undertake staff training and fire drills for furloughed staff?” Surprisingly, I’ve been asked this question many times over the last few months. Article 21 of the Regulatory Reform (Fire Safety) Order 2005 states that fire safety training MUST (b) be repeated periodically where appropriate and (e) take place during working hours.

While undertaking training on furlough is allowed, and indeed is a sensible course of action to take, some fire safety training requires hands-on or face-to-face sessions. In my view, it would be sensible to complete this immediately prior to returning to the workplace.

What about fire drills? 

As for fire drills, during furlough these would have no benefit, but when reopening a workplace after a three-month (or more) shut down it would be advisable to undertake a drill as soon as is reasonably practicable.  

Any drills conducted should be undertaken while making every effort to ensure social distancing measures are observed. In public buildings, it wouldn’t be advisable to undertake a drill during peak hours. Desktop ‘staff only’ exercises may be the best short-term option.

In summary, then, the fire risk assessor should be able to exercise discretion and judgement. This should not be a new skill for experienced assessors. The current situation offers a unique set of conditions to work under, but we still need to provide sound advice that’s reasonably practicable. 

The Secret Risk Assessor is well-known risk assessor in the fire sector. They have asked for their name to be withheld so they can speak freely about common failings they see in buildings across the UK.