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Testing and Maintenance - Resi

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Re: Testing and Maintenance - Resi

Post by hammer1 »

The song goes...{I'm gonna walk down to electric avenue and I'm gonna say ' have you got PAT testing records for all that mate'}
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Re: Testing and Maintenance - Resi

Post by baywaves »

I am sorry hammer1, but I am even more confused. You said "I have in this case got acceptance from LFB in regards to doing monthly MCP checks...." I presume that you mean London Fire Brigade.

You now appear to be confirming what I have said all along and that was that 'you don't'.

Because the 'acceptance' which you quote as your justification to do monthly MCP tests appears to be from a 20I4 email sent between a fire officer and a fire advisor located in North Wales. Please tell me that I am missing something here.

So I would ask the same question to you again 'do you have written approval from LFB to you, specifically stating that they are happy for you to do monthly MCP?

If the answer to that question is no, then you really need to rethink your stance on this.

Grenfell has opened up a whole new can of worms, or should I say it has 'exposed' a can of worms for the fire safety industry. I can imagine that right now the enquiry team have asked for and are scrutinising the fire alarm test schedules for this building and heaven help the fire assessor who has deviated from the recommended guidance.
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Re: Testing and Maintenance - Resi

Post by hammer1 »

baywaves wrote: Wed Sep 27, 2017 10:54 am I am sorry hammer1, but I am even more confused. You said "I have in this case got acceptance from LFB in regards to doing monthly MCP checks...." I presume that you mean London Fire Brigade.

You now appear to be confirming what I have said all along and that was that 'you don't'.

Because the 'acceptance' which you quote as your justification to do monthly MCP tests appears to be from a 20I4 email sent between a fire officer and a fire advisor located in North Wales. Please tell me that I am missing something here.

So I would ask the same question to you again 'do you have written approval from LFB to you, specifically stating that they are happy for you to do monthly MCP?

If the answer to that question is no, then you really need to rethink your stance on this.

Grenfell has opened up a whole new can of worms, or should I say it has 'exposed' a can of worms for the fire safety industry. I can imagine that right now the enquiry team have asked for and are scrutinising the fire alarm test schedules for this building and heaven help the fire assessor who has deviated from the recommended guidance.
Cannot really upload emails on here due to confidentiality, I do have recorded a response in regards to my situation.

I provided a link for additional info that you say all fire officers would not, as you can see a similar response was provided from Wales. There were other posts in that thread that thought would add to this discussion.

We are entering primary authority partnership with LFB from October which should clarify our processes.

I am sure Grenfell did not have a AFD system in place and no MCPs so not sure what relevance that is here. The main testing and maintenance issue will be the smoke systems installed at that building.
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Re: Testing and Maintenance - Resi

Post by baywaves »

hammer1 wrote: Wed Sep 27, 2017 11:35 am
We are entering primary authority partnership with LFB from October which should clarify our processes.
Well that is good news and it would also be good if you could come back to us and let us know what the partnership agrees about MCP tests.

Nonetheless, you appear convinced that monthly break glass testing is the way you are going. So good luck with that.

Look, I am not trying to be a smartass here but it’s all fine and dandy saying that ‘you can use a risk based approach to justify this’ blah blah blah.

You can use a risk assessment to justify the things that you want to do, and you can also use it to justify the things you don’t want to do. But at the end of the day, you have to do what is right.

When the [Edited by Jack Kane - please don't disguise sweary words, thanks] hits the fan and you are standing in a coroners court because a group of people have died in a fire because the fire alarms failed between the last tests and the coroner says ‘why weren’t you testing these alarms weekly’ then your risk based approach will mean absolutely nothing, nor will any email written by a fire officer in London or North Wales.

Because the next thing the coroner will say is ‘well if you had been testing them weekly as per guidance, then you would have picked up the fault and these people may have been alive today’. (and I bet I know how you are going to reply to this)

Take a look at the ‘guidance’ documents produced by the Home Office at the link below. They are specifically designed to support and offer guidance on the risk assessment approach (there is one for nearly all type of occupancy) and they all say weekly tests. Not one of them says ‘yeah feel free to come up with your own testing regime based on your risk assessment’. But if that is what you read into them, then you need more advice than I can offer.

https://www.gov.uk/government/collectio ... r-business

Below is a document which is more than likely the one which relates to the occupancy you are dealing with in your original post, and it also says weekly tests:-

http://www.cieh.org/library/Knowledge/H ... nce_08.pdf

Look I know and I believe that I understand where you (sorry! where we) are all coming from. I know this is a ridiculous test requirement and it’s incredibly onerous and time consuming, but you have to be very careful these days about what you do and about what you advise others to do. That is way I said previously that there is not a fire officer in the country who will put their name on a letter saying that they are giving you permission to deviate from the standard. The only exception would be if that was 'brigade' policy.
Last edited by Jack Kane on Fri Sep 29, 2017 12:35 pm, edited 1 time in total.
Reason: Edited by Jack Kane - please don't disguise sweary words, thanks
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Re: Testing and Maintenance - Resi

Post by hammer1 »

baywaves wrote: Wed Sep 27, 2017 12:38 pm
hammer1 wrote: Wed Sep 27, 2017 11:35 am
We are entering primary authority partnership with LFB from October which should clarify our processes.
Well that is good news and it would also be good if you could come back to us and let us know what the partnership agrees about MCP tests.

Nonetheless, you appear convinced that monthly break glass testing is the way you are going. So good luck with that.

Look, I am not trying to be a smartass here but it’s all fine and dandy saying that ‘you can use a risk based approach to justify this’ blah blah blah.

You can use a risk assessment to justify the things that you want to do, and you can also use it to justify the things you don’t want to do. But at the end of the day, you have to do what is right.

When the sh1t hits the fan and you are standing in a coroners court because a group of people have died in a fire because the fire alarms failed between the last tests and the coroner says ‘why weren’t you testing these alarms weekly’ then your risk based approach will mean absolutely nothing, nor will any email written by a fire officer in London or North Wales.

Because the next thing the coroner will say is ‘well if you had been testing them weekly as per guidance, then you would have picked up the fault and these people may have been alive today’. (and I bet I know how you are going to reply to this)

Take a look at the ‘guidance’ documents produced by the Home Office at the link below. They are specifically designed to support and offer guidance on the risk assessment approach (there is one for nearly all type of occupancy) and they all say weekly tests. Not one of them says ‘yeah feel free to come up with your own testing regime based on your risk assessment’. But if that is what you read into them, then you need more advice than I can offer.

https://www.gov.uk/government/collectio ... r-business

Below is a document which is more than likely the one which relates to the occupancy you are dealing with in your original post, and it also says weekly tests:-

http://www.cieh.org/library/Knowledge/H ... nce_08.pdf

Look I know and I believe that I understand where you (sorry! where we) are all coming from. I know this is a ridiculous test requirement and it’s incredibly onerous and time consuming, but you have to be very careful these days about what you do and about what you advise others to do. That is way I said previously that there is not a fire officer in the country who will put their name on a letter saying that they are giving you permission to deviate from the standard. The only exception would be if that was 'brigade' policy.
We agree to disagree we have slightly different approaches. ./thumbsup..

I wasn't insisting a blanket change to monthly testing on MCPs, only when an issue is raised. It would need to be carefully assessed and detailed in FRA it is not just picking test frequencies from thin air. We are here to challenge things we feel are not reasonably practical, I wouldn't be doing my job if I just code hugged at every level. I agree it has got to be something major and requires scrutiny if you are suggesting a variation and should always seek advice from your fire authority.

Nearly 90% of residents weekly tests they silence the sounders (in my experience) which is the main but not solely the reason for the test anyway so they are not BS compliant anyway.

Plus these sites are unmanned so no daily checks as per BS requirements so again you could say non compliant if system fails in between the weekly tests.

There is a section in most if not all BS standards which mention variation and deviation from the BS and what you need to do in those scenarios.

Fire officers will never put their name in anything these days however their support on some cases can enhance your argument. That link I put up where the officer replied from Wales was a very good and sensible reply.
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Re: Testing and Maintenance - Resi

Post by Messy »

How dare you Hammer

I 'signed off a number of variations from BS and ADB when I was an inspecting officer.

Guidance is guidance and the BS's are best practice. As you say, risk based control measures are the answer to everything and NOT sticking to the guidance.

Consider camoflage green extinguishers? A shop where everything is that colour. Would you accept them or say no as is not best practice?

What if it's a poncey boutique who have risk assessed the issue, have a letter from the extinguisher company that the extinguisher is safe to use, have staff only rule to first aid firefighting and staff training that reduces the identification issues?

I could not find a reason to say no as their FFE strategy was otherwise sound

So Bewaves, was I wrong?
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Re: Testing and Maintenance - Resi

Post by baywaves »

Messy wrote: Wed Sep 27, 2017 4:11 pm So Bewaves, was I wrong?
Had they not have been able to find them in a fire, then yes, you would.
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Re: Testing and Maintenance - Resi

Post by Messy »

Baywaves - (sorry about he typo in the last message) - are you saying that the HM FS guidance & BS's should be applied verbatim and no variations and/or flexibility applied?

Surely that is NOT how risk based assessments are supposed to work?

I am intrigued
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Re: Testing and Maintenance - Resi

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Messy wrote: Thu Sep 28, 2017 5:17 pm Baywaves - are you saying that the HM FS guidance & BS's should be applied verbatim and no variations and/or flexibility applied?
No I am not saying that at all. In fact If you go back and read my first post you will clearly see that what I said was:-

Whilst I agree that sticking to British Standards can be an onerous task, I would suggest that any deviation from those standards needs to be justified and would require 'written' agreement with your enforcing authorities. As simple and as straightforward as that.

Then I get a reponse saying that ‘I have in this case got acceptance from LFB in regards to doing monthly MCP checks’. I questioned this because I genuinely didn’t believe that that was the case. I think it was the use of the term ‘acceptance’ more than anything else that spooked me and let me to believe that it wasn’t written permission that he had.

Then to justify that comment further, I get shown a piece of text from 2014 that was supposed to be from a fire officer in North Wales, no brigade letterhead, no signature, in fact nothing that would even suggest that it was actually written by a fire officer (and not by one of my kids)

And why would anyone think that that 2014 extract was their ‘get out clause’ to deviate from acceptance guidance. So it was quite clear to me that there was no written permission.

But what I do find worrying is that, when anyone asks a question on this forum, the default answer is ‘put it into your risk assessment and you will be okay’.

As I have already said, you can use a risk assessment to justify anything that you want to do, and you can also use a risk assessment to justify anything you don’t want to do. But at the end of the day, you have to do what is right and that is to stick with best practice guidance.

If you are going to deviate, then you need to get all those with an interest in the property to sign up to it. Not just because you think it a good idea to do so. You have to be very very careful these days. And that is really the only point I am trying to make.
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Re: Testing and Maintenance - Resi

Post by Messy »

[/quote]

But what I do find worrying is that, when anyone asks a question on this forum, the default answer is ‘put it into your risk assessment and you will be okay’.

As I have already said, you can use a risk assessment to justify anything that you want to do, and you can also use a risk assessment to justify anything you don’t want to do. But at the end of the day, you have to do what is right and that is to stick with best practice guidance.

If you are going to deviate, then you need to get all those with an interest in the property to sign up to it. Not just because you think it a good idea to do so. You have to be very very careful these days. And that is really the only point I am trying to make.
[/quote]



I agree with almost all of what you have written above. Of course it is best for everyone if best practice can be applied. However, when best practice doesn't fit - or may make things more dangerous - then of course variations must be considered. I agree that care needs to be exercised whenever moving away from standard control measures and management systems. But when you are dealing with premises regularly that are not 'standard' - and in my case, premises where no formal guidance is available, common sense must be the default.

Consultation with stakeholders, enforcers is sensible - as is peer reviews. Something I do extensively if considering a significant variation.

I totally agree that when people ask any forum 'How long is a piece of string?' and others answer, "that's all down to your risk assessment" - it is not particularly helpful.

BUT, I really do not see that happening on this site very often and must challenge your statement : "when anyone asks a question on this forum, the default answer is ‘put it into your risk assessment" . The inference is that this sort of post is a regular occurrence. The moderators very tightly control posts and rightly so .

Have a look at some of the fire safety topics discussed on the IOSH discussion forum for an example of H&S professionals dabbling in fire safety and regularly getting it wrong.There's a sort of professional ego thing going on with some on that site and some feel they must comment to maintain their status within the site. I have seen advice from a professional organisation's website that is so shocking (& dangerous), I now no longer contribute to that forum.

Thank you for clarifying you position re flexibility when using guidance, as for a minute I thought I had found a 'code hugger' - my pet hate :)
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Re: Testing and Maintenance - Resi

Post by hammer1 »

baywaves wrote: Thu Sep 28, 2017 6:02 pm
Messy wrote: Thu Sep 28, 2017 5:17 pm Baywaves - are you saying that the HM FS guidance & BS's should be applied verbatim and no variations and/or flexibility applied?
No I am not saying that at all. In fact If you go back and read my first post you will clearly see that what I said was:-

Whilst I agree that sticking to British Standards can be an onerous task, I would suggest that any deviation from those standards needs to be justified and would require 'written' agreement with your enforcing authorities. As simple and as straightforward as that.

Then I get a reponse saying that ‘I have in this case got acceptance from LFB in regards to doing monthly MCP checks’. I questioned this because I genuinely didn’t believe that that was the case. I think it was the use of the term ‘acceptance’ more than anything else that spooked me and let me to believe that it wasn’t written permission that he had.

Then to justify that comment further, I get shown a piece of text from 2014 that was supposed to be from a fire officer in North Wales, no brigade letterhead, no signature, in fact nothing that would even suggest that it was actually written by a fire officer (and not by one of my kids)

And why would anyone think that that 2014 extract was their ‘get out clause’ to deviate from acceptance guidance. So it was quite clear to me that there was no written permission.

But what I do find worrying is that, when anyone asks a question on this forum, the default answer is ‘put it into your risk assessment and you will be okay’.

As I have already said, you can use a risk assessment to justify anything that you want to do, and you can also use a risk assessment to justify anything you don’t want to do. But at the end of the day, you have to do what is right and that is to stick with best practice guidance.

If you are going to deviate, then you need to get all those with an interest in the property to sign up to it. Not just because you think it a good idea to do so. You have to be very very careful these days. And that is really the only point I am trying to make.
Sorry you felt I was lying but that's your opinion. To be honest I cannot see why anyone would say porkie pies on this forum is it be a total waste of time a bit sad and unprofessional.

I added the 2014 extract to add to the debate as it covered same topic I wasn't saying I used this thread as my argument to the fire authority reason from moving away from BS. Again if you feel some of the messages were porkie pies and written by kids that's your opinion. I don't think many would last long in their jobs if they started uploading work documents on a public forum....

My main point was you stated not one fire officer in U.K. Would move away from BS or that is what I thought you meant and I was saying from my experience this is not the case.

Your other comments are basically what I was trying to say so we actually do agree :).

Totally agree stick to guidance but in the real world this can be hard to achieve so we need to work together to find a suitable solution.
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Re: Testing and Maintenance - Resi

Post by baywaves »

hammer1 wrote: Fri Sep 29, 2017 4:02 pm
Your other comments are basically what I was trying to say so we actually do agree :).

Totally agree stick to guidance but in the real world this can be hard to achieve so we need to work together to find a suitable solution.
All's good my friend, I think we are more or less on the same page.
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