The need to review Fire Risk Assessments
Many businesses, whether they have remained open, or not, are experiencing changes in risk. In all cases, businesses should be aware of these changes in risk and review their Fire Risk Assessments (FRA) accordingly, to ensure they are suitable and sufficient. Responsible Persons (RPs) should always be reminded to seek advice from a competent fire risk assessor where doubt exists. It may also be advisable for the RP to consult with their insurers when considering risk assessment and mitigation. However, please note determining compliance with the Regulatory Reform (Fire Safety) Order 2005 (RR(FS)O 2005), remains the role of the FIre and Rescue Service, not your insurer.
Although many businesses are closed during the lockdown period, it is important that the following is considered:
* Risk of arson
Securing premises is important to reduce the risk of arson. This includes removing any external sources of fuel or ignition which could cause fire spread. Ensuring gates and fences are closed and locked as well as having working CCTV, security systems and external lighting may help to prevent the anti-social behaviour which can lead to arson.
* Shared Means of Escape
Securing a premises should not affect the means of escape from other premises which are still open, residential buildings or where wayleave agreements are in place.
* Maintaining Fire Safety Measures
The internal fire protection measures such as fire doors should be closed and in good order as these provide vital protection in the event of fire.
The maintenance and testing of the fire detection and alarm system should be continued where it is possible and safe to do so. This should be prioritised based on the risks identified by the RP and their Contractors For example: (i) a fire in a shop that hasn't been closed may affect residents in the flat above the shop; (ii) a fire detection and alarm system which serves multiple premises, some of which may still be operating.
Scaling the Risk
Businesses which remain open are likely to experience a surge in demand. The following should be considered:
* It is essential that FRAs are undertaken or reviewed where there are significant changes in ways of working or processes. This may include:
More materials, storage requirements, or higher quantities of finished product being on site than would normally be the case.
Parts of the premises being closed; the FRA should determine the level of risk resulting from the changes and any mitigation measures e.g. more frequent deliveries/collections or the use of other sites to provide storage.
* Where staff numbers have been increased, businesses must ensure that they continue to provide appropriate staff training. This is sometimes overlooked where employees of the same company come to work at a different site. RPs should be able to show that all personnel are aware of what to do in case of fire. They should also test their emergency procedures, particularly after large staff increases.
* Reductions in staff due to sickness and self-isolation is to be expected. While the numbers of those who are absent will be bolstered by those returning to work, in the short-term businesses should ensure that their FRA reflects the added risk of such reductions. Issues may include having insufficient staff available to carry out processes safely, increasing the risk of fire. Similarly, a reduction in staff may result in employees not being able to successfully carry out evacuations and emergency procedures such as in-house fire response or fire warden duties.
Businesses may employ people who are classed as vulnerable, or those who are vulnerable may be in their care. The effects of the virus on working practices and available staff may negatively affect the ability of vulnerable persons to escape in the event of fire. Employers should continue to undertake and review their Personal Emergency Evacuation Plans (PEEPs) for their staff. This is particularly crucial in the care industry where residents may rely on staff to instigate evacuation measures. In any case, procedures should be reviewed so that they accurately reflect the staff available. Such reviews must carefully weigh the risks from fire and the ability of such businesses to operate safely.
Alterations to Buildings
Some premises may also have been repurposed to undertake other work. An example would be a warehouse which previously had a very small risk and few staff, now undertaking essential work to provide manufacture of medical items or the packing of food parcels. This may have happened within a short timeframe and it is unlikely that fire safety will have been a primary consideration. Such actions may increase the risk due to the type of work being carried out, the number of staff present and any material works that may be necessary to allow the building to facilitate its task. Other alterations – such as wedging fire doors open to reduce the need to touch door handles or sealing fire doors in order to prevent air movement between sections of a building – could affect fire safety measures to provide protection from fire and access to means of escape. Similarly, premises may have undertaken other measures such as partitioning or simply locking of doors that may compromise a building’s existing fire strategy. In all cases, a review of the FRA should be undertaken to determine the effect on risk and the mitigation measures that may need to be taken. In addition, the current pandemic does not remove any requirements under the Building Regulations to ensure that alterations meet the functional requirements.
This information is of a temporary nature in response to the current COVID-19 situation and relates to current Government advice and restrictions related to COVID-19. I will aim to update this information on a regular basis.
Please refer to the Government’s guidance on COVID-19: https://www.gov.uk/coronavirus