COMPLIANCE & RISK ASSESSMENT
current arrangements. Additionally, to ensure that an effective fire risk management system can operate it is essential that the asset is well understood in terms of its condition and the maintenance requirements. To achieve this, the asset needs to be thoroughly documented in terms of condition requirements and how it needs to be maintained. If there is any doubt on the accuracy or content of this information then surveys of the building fabric (external walls and compartment wall construction), fire stopping, fire doors, fire/smoke dampers, fire alarm systems, smoke control systems, etc. should be undertaken by competent fire surveyors to detail all of the passive and active fire installations within individual buildings in order to create asset registers for specific relevant fire installations and provisions. Insufficient documentation, incomplete records and inadequately documented fire safety management processes and arrangements present a substantial threat to the fire risk management system.
A VIEW FROM THE OTHER SIDE In our experience of providing a broad range of specialist fire safety consultancy services on complex estates and PFI Centre of Best Practice projects, we often find fire strategy documentation that does not reflect the final design stage, with omissions and errors in documentation which often do not reflect the as-built arrangements.
Fire strategy drawings are seldom kept up to date and often do not mirror existing room layout arrangements and present-day room usage. Post practical completion alterations to the building are commonly not reflected accurately within fire strategy documentation with derogations originating from pre and post practical completion lacking supporting validatory documentation such as fire engineering assessments and proof of stakeholder sign off. The original design intent is often ambiguous, performance specifications, test evidence, and elevation drawings are often unavailable. Operation and maintenance (O&M) information tends to be incomplete or even contradictory, with certificates of conformity absent, fire safety management information missing and maintenance records (including statutory compliance records) being woefully lacking. In reality, the fire safety documentation and records are in a poor state of play and many clients need a helping hand in re-setting their fire risk management systems and information base.
HOW DO I DEVELOP AN EFFECTIVE FIRE RISK MANAGEMENT SYSTEM FOR A COMPLEX
BUILDING OR ESTATE? The critical steps are as follows:
● Understand the asset, including fire safety documentation relating to design, construction, management, and general know-how. Documents need to be present, complete, accurate and reflect the as-built facility/estate.
● Determine any contractual asset condition requirements related to leases, etc.
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● Undertake timely, comprehensive and informative fire safety surveys, fire safety documentation audits and fire safety management audits.
● Remediate any non-compliances in building fabric identified as necessary and document in SMART action plans.
● Address all gaps that have been identified in documentation, by updating and correcting all records, databases and files.
● Undertake a risk profiling exercise of buildings and estates based upon the outcome of the surveys and audits.
● Maintain a risk register to inform strategic action plans and budgetary requirements.
● Compile a single database set of relevant and accurate documentation for each building or asset.
● Work collaboratively with stakeholders and competent third parties to develop policies, procedures and arrangements that underpin the fire risk management system to incorporate all statutory compliance regimes that are required. But remember – the key is not to over complicate the system and ensure you keep things simple.
WHAT DOES STATUTORY COMPLIANCE
LOOK LIKE? The aim is to ensure buildings and estates have complete and appropriate documentation accompanied by a record of maintained statutory compliance aspects in the condition required. A comprehensive record of robust statutory compliance regimes that are regularly monitored and audited, will assist to de-risk the potential for non-compliance and provide confidence in the fire risk management system for all stakeholders.
In terms of fire safety compliance, indiscriminately applying statutory fire safety guidance intended for the design and construction phase to a built and operational facility, should be avoided. This approach does not represent value for money, often leading to unnecessary disruption to service delivery due to construction or refurbishment activities with no benefit in risk reduction terms. The fire risk management system should be striving to achieve an appropriate level of fire safety based upon a suitable and sufficient assessment of risk and applying fire safety guidance proportionately. Risk profiling of buildings and estates is an effective and strategic approach to managing the complexity of property portfolio’s and should be an integral part of the fire risk management system.
Adopting a ‘plan, do, check, act’ approach to the fire risk management system with an emphasis on proactive monitoring and auditing, will have a positive impact on development, delivery and maintenance of the fire risk management system. Asking for help and assistance from competent and experienced third parties also makes good business sense.
The fire safety and risk management system will only be as good as the information it is based upon – get this right and the next stop is working towards best practice.
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