Practical Fire Safety Guidance consultation response

The Branch Council of the Scottish Branch has made the following contribution to the consultation on the new proposed Practical Fire Safety Guidance for Existing Non-Residential Premises:

Practical Fire Safety Guidance for Existing Non-Residential Premises Consultation (3-2-17)

If you don’t want to open the whole response, I have quoted our main comment below:

The objectives of revising the guidance include:

• Updating outdated terminology to reflect the single Scottish Fire and Rescue Service (SFRS) rather than relating to Fire Authorities in Scotland.

• A requirement to clarify the guidance to satisfy users, some of whom would like more detail and some less.

The Scottish Branch of the Institution of Fire Engineers have considered the proposed consolidation of 5 sector specific fire safety guides into one, in the form of the presented “Practical Fire Safety Guidance for Existing Non-Residential Premises”. We are of the opinion that the objective of updating text with reference to the SFRS is entirely desirable and will increase the clarity of the document(s). We also agree with the aim of making the guidance easier to use for the individual duty holder. This individual duty holder is the ultimate target for the information provided and therefore the style, content and format of the document(s) should be focused on their requirements. We do not understand how consolidating the 5 guides into one can be expected to achieve this. Many duty holders will be responsible for single purpose buildings, and this category of duty holder are the ones who might require most help in understanding the concepts of fire safety in their building. To consolidate the 5 guides into 1 will inevitably require this duty holder to disregard significant portions of the text which do not apply to them. This has the potential to make the comprehension of the document more difficult.

Duplication of material between guides is cited as a disadvantage of the current system however we do not see that this is the case. The documents are unlikely to be produced in paper format in any great numbers and as a piece of reference material will be held in electronic form. This means that there is little saving to be made from reducing the page count from 5 documents to 1. Maintaining 5 documents rather than 1 may be easier for the Scottish Government to produce and maintain, but in our opinion this will not benefit the individual duty holder.

Any duty holder who is responsible for complex buildings when more than one use needs to be taken into account would perhaps benefit from the consolidation. We would however argue that as the complexity of buildings increases, the assumed skill and understanding of the duty holder should increase. It is reasonable to expect this duty holder better able to cope with advice from multiple guides and not require the help which a consolidated guide might provide.

In summary we believe that the updating of the existing guides with regard to terminology is important and should go ahead. We do however think that the consolidation of 5 guides to a single document risks confusing average duty holder and could be counterproductive to the aims and objectives of the project.