Memorandum by Tyco Fire and Integrated
Solution (FRS 66)
We have reviewed draft issued for comment dated
2006-08 and wish to present our considered views as fire engineers
who have been directly involved in UK as one of the major fire
safety engineering companies for the past 100 years.
We make four overarching observations as follows:
1. The document shows a number of inconsistencies
with both the approach and the philosophy being adopted in Approved
Document "B".
2. The document demonstrates, in our view,
a move by the Government to abdicate is responsibilities for the
welfare of its citizens.
3. It fails to address the large losses
annually suffered by Great Britain plc through fire.
4. The fire at the Buncefield Oil Depot
serves to highlight the conceptual failings in the approach to
fire safety now being proposed.
Our specific comments are as follows:
INTRODUCTION
Clause 2.
The only target set for the PSA is the reduction
of deaths in the home by 20% and deliberate fire by 10%.
With direct fire losses suffered by GB plc annually
now running at over £1.5 billion per annum with double that
amount in consequential losses, the government appears primarily
concerned with addressing press media headlines.
Clause 4:
The clause seeks to give responsibility for
fire safety in local communities without any authority to ensure
effective implementation.
The proposed approach runs counter to that proposed
in AD "B" where there are moves to repeal local acts
which address issues such as unsprinklered compartment sizes.
CHAPTER 1—FIRE
PREVENTION AND
RISK MANAGEMENT
Clause 1.10:
The role of the Fire and Rescue service is seemingly
focused only on domestic area and all considerations of the major
fire hazards and threat to life, presented by industry and commerce
are ignored.
Clause 1.11:
The document rightly identified the old and
financially vulnerable as being the major "at risk"
groups but fails to address the reality that these groups do not,
without assistance or intervention, have the means to provide
effective fire protection. Without addressing the issue of cost
the exercise becomes one of warm words' only.
Clause 1.17:
We welcome the acknowledgement of the benefit
and need to install automatic firs suppression system for high
risk groups.
Clause 1.22:
The arson losses to society are particularly
acute in schools and should be acknowledged. In tasking the Fire
and Rescue Service with arson reduction strategies, there is a
notable absence of measures being taken by Government with regard
to its role and responsibilities to safeguard the schooling of
children and the welfare or its citizens.
Clause 1.27:
Having acknowledged the economic benefits of
arson mitigation, Government support is required to measures such
as automatic fire suppression which provide "a firs-fighter
in every room" and reduce the dependence of the Speed and
level of response of the Fire and Rescue services.
Clause 1.31:
We welcome the recognition of sprinkler Systems,
and other automatic fire suppression systems, but believe the
document does not explain that using such systems significantly
reduces loss of life, and livelihood through fire.
Clause 1.33:
Whilst we understand the desire to make property
owners take responsibility for fire safety the removal of formal
and competent enforcement represents an abdication of the Government's
responsibilities form. safety and wellbeing of GB plc. In theory
a failure by one individual or company may be their own downfall,
but, as in the case of the Buncefleld Oil Depot, the consequences
to their neighbours lives and livelihoods can be severely impacted
through no fault of their own. Holding ones hand up in horror
and then washing them of the problem is not responsible government.
The Buncefield site was already under a (CIMAH) risk assessment
scheme more rigorous that that now proposed under the RRO. The
RRO is being used, in our view, as justification for a downgrading
of fire safety enforcement
CHAPTER 2—WORKING
TOGETHER THE
REGIONAL APPROACH
Clause 2.1:
The proposal to develop local frameworks runs
counter to AD "B"—which seeks to remove local
frameworks in favour of an overarching national approach.
CHAPTER 7—FINANCE
Clause 7.7:
The actions of the Fire and Rescue service must
remain within capped limits regardless of the need or hazard to
the public and to the nation. Again Buncefield serves to illustrate
that fires do not cause destruction within imposed financial constraints.
CHAPTER 9—RESEARCH
Clause 9.5:
Whilst welcoming the acknowledgement that improved
collaboration on research is desirable, no constructive support
appears to be on offer for a task that the Fire and Rescue service
alone may not be equipped to execute. Work on innovative approaches
to fire safety will extend far beyond the remit and resources
of the Fire and Rescue Service and requires a more centrally supported
initiative.
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