Management failures have contributed to – and are more than likely the root cause of – a number of fires, some of which have resulted in deaths and serious injuries. However, businesses can minimise the risk of such failures happening by producing a fire safety policy that clearly demonstrates how an organisation is implementing appropriate fire safety arrangements, in line with the Regulatory Reform (Fire Safety) Order 2005 in England and Wales.
Maintaining a suitable written policy is a key step in the effective management of fire safety precautions. For larger organisations with several premises, it should demonstrate clearly and concisely the arrangements that an organisation is adopting strategically and tactically, with the flexibility to be varied for site-specific operational needs through the premises emergency plan. A suitable and sufficient fire risk assessment should include the examination of the strategic, tactical and operational effectiveness of an organisation’s arrangements, and directly inform the policy, so that appropriate preventive and protective measures can be recorded.
The Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999 together require employers to prepare a written policy for health and safety, and in particular the arrangements in place. This typically takes the form of a health and safety manual.
The Fire Safety Order requires the responsible person for the premises to have the same effective written arrangements in place for fire.
Often, fire safety is a feature of the general health and safety policy/manual usually buried within the arrangements section, and not referred to specifically within the written statement of intent. However, it is increasingly being recognised that, to assist the responsible person in promoting a positive safety culture, and provide appropriately knowledgeable staff and well managed organisations and premises, fire safety needs to be separated out of general health and safety, and given its own policy. In doing so, a written set of arrangements will clearly identify the fire safety strategy to all internal and external stakeholders.
Fire safety manual
When construction or building work takes place, fire safety design information – whether it has been provided as a client’s duty under the Construction (Design and Managment) Regulations, or by a person carrying out building work as required by Building Regulations – and the form it takes, should detail the design and ongoing management needs.
A fire safety manual which contains a fire safety policy will provide an easily accessible reference source for staff to keep up-to-date with an organisation’s fire safety planning, organ-isation, control, monitoring and reviewing arrangements.
It is a robust means of ensuring that the fire precautions (plans, systems, equipment and management) are in place and working effectively as a fire safety strategy.
The policy should include a statement of intent, a section outlining the organisation of fire safety, including roles and responsibilities, and, finally, the arrangements – identifying how the responsible person will meet their fire safety duties.
However, this must not be the only focus of the policy; those producing it should have an awareness of other matters that a good fire safety policy can cover, such as business continuity, and environmental and financial impacts.
In particular, the specific organisation and arrangements surrounding fire risk assessments should be easily identifiable through the policy. Action plans to identify adequate preventive and protective measures, with suitable deadlines for implementation and who is responsible for quality assuring the remedial works, should be included.
Statement of intent
The statement of intent must be fairly brief and written in clear and simple language, so it can be easily understood and broken into smaller statements or bullet points. It should set out a clear commitment to the organisation’s aims – including, for example, maintaining an environment safe from fire, the life safety of staff and all relevant persons, and business continuity.
It should also seek to contain measurable and modifiable objectives in relation to the general fire precautions – reducing the risk of fire, means of escape, fire detection and warning, training, emergency plans, etc – and briefly how they intend to achieve them. The fire safety policy statement must be posted in a prominent location and be brought to the attention of all staff and relevant persons, as appropriate.
Organisational issues
The organisation section of the policy should define the names (where appropriate), positions and duties of those within the organisation who have any managerial or supervisory responsibility for fire safety.
Careful thought will need to be given to how the duties of individuals at all levels of management and supervision are linked, to ensure that elements work congruently. Adequate reporting is an essential element for all organisations, but even more so for larger ones. Financial commitment to fire safety should be clear, and delegated financial authority should also be identified.
The description of the duties that each individual is given should not contain responsibility overlaps, and each individual needs to be clear about their responsibilities and where the limits lie. It is recommended that contingency planning is an element of the organisational structure – for example, identifying the replacement for a member of staff who is unavailable on a given day, week or month, etc.
It is also very useful to provide an organisational chart within this section, and to identify a suitably competent fire safety advisor, so that specialist advice is readily available to those with responsibility.
Arrangements
Well thought through arrangements that are subsequently embedded in a policy should demonstrate to any person that the planning, organisation, control, monitoring and review of the preventive and protective measures are appropriate. The policy document is fundamental to a successful fire safety management system, which should address the following questions:
Planning:
- what is our systematic approach to fire risk assessment, including a programme for when it will be completed and reviewed?
- what priorities and objectives are being set for eliminating hazards and reducting risk?
- what deadlines are being adopted for the design and implementation of preventive and protective measures?
- what methods of risk control are being used to minimise risk?
- what are the performance standards for the implementation of the fire risk assessment and the preventive and protective measures?
Organisation:
- how are employees and representatives included in carrying out the fire risk assessment?
- what communication and consultation is in place to promote a positive and visible approach to fire safety?
- how is fire safety information effectively communicated to relevant persons?
- what information, instruction and training is provided to secure competence, and how is this evaluated, particularly for those who carry out risk assessments?
- what fire safety assistance is in place?
Control:
- what is being done to ensure that everyone with responsib-ilities clearly understands how to discharge them?
- what time and resources are being given to those with responsibilities?
- how is the performance of those with responsibilities being assessed, and what improvement actions are being taken?
- what supervision is in place for those with responsibilities?
Monitoring:
- what is being done to implement the fire safety policy?
- how effectively are risks being controlled?
- how is the fire safety culture being assessed?
- what routine inspections are in place to ensure effective preventive and protective measures?
- how are incidents investigated to ensure that lessons are learnt and remedial actions can be taken?
Review:
- what priorities for remedial action are established as a result of the monitoring activities?
- how often is the whole fire safety management system reviewed to ensure it remains effective?
Specific arrangements
The arrangements section of the fire safety policy should provide specific details of the measures used to carry out the objectives of the policy statement, including site-specific practices.
To assist the responsible person to produce a suitable amount of readily available information, instruction, training and reference material for specific duties, the arrangements section could be written to be congruent with the articles of the Fire Safety Order that make up the fire safety duties, and some others. It is recommended that business continuity measures are identified.
As a fire risk assessment is in essence an evaluation of the responsible person’s compliance with their fire safety duties, the significant findings will feed directly into the detail that is provided within all sections of a fire safety policy, but particularly the arrangements section. This could include the measures in relation to:
- general fire precautions
- fire risk assessment
- principles of prevention
- dangerous substances
- firefighting equipment
- contacts with emergency services
- fire warning and detection
- maintaining escape routes and exits
- procedures for serious and imminent danger
- additional emergency measures for dangerous substances
- routine maintenance
- safety assistance
- provision of information to employees
- provision of information to employers and the self employed
- training
- cooperation and coordination in shared premises
- employee responsibility
- provision of measures to protect firefighters
Assessment lynchpin
It is important to understand that the findings of a fire risk assessment will provide vital information for producing or updating both the fire safety policy and the emergency plan.
It is recommended that the Government’s sector-specific guides – available at www.firesafetyguides.co.uk – be referred to.
A hazard may not be physical, such as an inadequate detection system or inadequate fire-resistant construction. It could be management based – for example, staff who have not received adequate training on the emergency plan, or arrangements that are not recorded in the existing policy.
It might even involve another organisation that shares the building which is not cooperating as required by the premises owner and lease agreement.
It should be remembered that the fire safety policy needs only to be appropriate, having regard to the size of the organisation (number of employees, premises, etc) and the nature of the activities
Emergency planning
AN ORGANISATION should also have arrangements in place for emergency planning. For an organisation with premises on more than one site, emergency planning will be a generic intention, but inevitably the fire safety policy cannot cover all of the variances that will occur at each premises. These variances could be dealt with by procedures being added to an appro-priate emergency plan produced by a competent person at each premises.
Once produced as a document, the emergency plan should form an integral part of the staff training package, and will make a useful reference document for staff refresher training and during
fire drills.
Areas that could be included in an emergency plan include:
- how people will be warned if there is a fire
- what staff should do if they discover a fire
- how the evacuation of the premises should be carried out
- where people should assemble after they have left the premises, and procedures for checking evacuation
- identification of key escape routes, how people can gain access to them and escape to a place of total safety
- arrangements for fighting the fire
- the duties and identities of staff who have specific responsibilities in a fire
- arrangements for safe evacuation of people identified as being especially at risk, such as those with disabilities, lone workers and young persons
- any machines, appliances, processes or power supplies that need to be stopped or isolated if there is a fire
- specific arrangements, if necessary, for high-risk areas
- contingency plans for when life safety systems, such as evacuation lifts, fire detection and warning systems, sprinklers or smoke control systems, are out of order
- how the fire service will be called and who is responsible for this
- procedures for meeting the fire and rescue service upon its arrival and notifying crews of any special risks, such as the location of highly flammable materials
- what training employees need and the arrangements for ensuring this is given
- phased evacuation plans (where some areas are evacuated while others are alerted but not evacuated until later)
- plans to deal with people once they have left the premises
In order to provide readily available information to the emergency services, it is recommended that an information box is maintained, containing up-to-date information about occupants, which can be removed by nominated staff. It is also good practice to prepare post-incident plans for dealing with situations that may occur. Contingency plans to determine specific actions and/or the mobilisation of specialist resources should be prepared to cover specific contingencies, such as unaccompanied children, people wishing to rejoin friends, transport from the building, or inclement weather.
Katie Cornhill is a fire safety officer with Hampshire Fire and Rescue Service.