CROSS Safety Report
Fire extinguishers in common areas
A reporter raises a point about the provision of fire extinguishers in the common parts of flats. They go on to say that extinguishers should be provided in some cases, to cover identified risks, but that they are not specified due to cost savings pressures and assessor unawareness.
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A reporter raises a point about the provision of fire extinguishers in the common areas of flats.
This concern emerged because risk assessors and companies alike are regularly recommending the removal of fire extinguishers from common areas. The assessors’ explanation for this is that if an untrained tenant was to use the extinguisher, they would put themselves at risk. The reporter’s assumption on the motivation of this practice is that it is purely driven by the reduction of installation and service costs.
The recommendation is in line with current guidance available, namely “Fire safety in purpose built flats”, where in part 21 it is stated that:
“21.3 It is rare for there to be a need for fire-fighting equipment to be used by people present in the common parts of blocks of flats. It is, nevertheless, usually provided in plant rooms and other such rooms, for use by the staff and contractors.
21.4 The provision of fire extinguishers and other forms of fire-fighting equipment in common parts for use by residents is problematic. It is not expected that residents should need to tackle a fire in their flats to make their escape. Indeed, to obtain a fire extinguisher located in the common parts for this purpose would involve the person leaving their flat in the first place.
21.5 This does not preclude residents from providing their own fire extinguishers and fire blankets. Indeed, it may be appropriate for landlords, and others responsible for the common parts, to encourage this as part of the process of engaging with, and educating residents on, fire safety”.
However, the reporter is of the opinion that in cases of mixed-use buildings (if for example there is a commercial part), or if there are people who are working in the building (such as reception staff, security personnel, cleaners, or concierges), then these areas “fall under the definition of their work place and thus are covered under the Health and Safety at Work Act”. In conjunction with the Regulatory Reform (Fire Safety) Order 2005 – which applies to the common parts of buildings and makes provision in article 13 for non-automatic fire-fighting equipment to be available when appropriate – the reporter proceeds in the interpretation that extinguishers should be present in these areas.
Differing quality of training
They also think that there are different levels in the quality of training provided between all the available courses for fire risk assessors. They consider that when a course is fragmented and run through many third-party companies then it becomes harder to ensure consistency in the quality of the courses delivered. This may have as an outcome that some assessors may not have the necessary background to judge when it is appropriate to place or remove fire extinguishers from the common parts of buildings.
The reporter has interacted with professionals who have been certified as assessors by some courses and are operating in the industry. Despite this, they are not feeling completely comfortable doing some assessments. Despite that uneasiness, they continue completing these assessments so that they remain in business and do not lose their income.
The reporter’s suggestion is for the introduction of a third-party registration of risk assessment companies, who can then only participate and complete a risk assessor’s course on the condition of a proven track record for a set period of time.
Expert Panel Comments
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This is not a new issue, and this discussion has been recurring in the fire safety domain for some time. The need for portable fire fighting equipment (PFFE) in any premises is covered by the Regulatory Reform (Fire Safety) Order 2005 (FSO) and is, as always, subject to a suitable and sufficient fire risk assessment (FRA) by a competent person.
If PFFE is incorrectly omitted, or unnecessarily present, it is considered it is due to a misunderstanding of the need to provide PFFE in the risk assessment or the overselling of PFFE by suppliers. As with every industry that provides technical solutions, the potential for commercial pressures should be acknowledged in this discussion, and the eventual choice be made on technical merits or demerits, and, the finding of the FRA.
The Construction Industry Council’s Setting the Bar Report compiles the findings of Working Group 4 on fire risk assessors, and outlines their next steps on the competence of fire risk assessors. Work on this topic is ongoing, and the Fire Sector Federation has published an Approved Code of Practice for fire risk assessors.
It is also of note that clause 156 of the Building Safety Act 2022 (Amendment of the Regulatory Reform (Fire Safety) Order 2005), under article 156(4) will amend the FSO to ensure that “The responsible person must not appoint a person to assist them with making or reviewing an assessment under article 9 unless that person is competent.”
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