Where fire is concerned honesty is the best policy, strategy and procedure.1 That was the message in an article I authored last year which focused on the importance of fire policy. What amounts to fire policy, fire risk management strategy and procedure is not thoroughly understood and many people responsible for fire safety within organisations or individual buildings, struggle to get it right.
Following the release of BS 9999: 20172 which contains a revised section 4, entitled “Designing for the management of fire risk” and reference to the term fire risk management strategy, I thought it might be worthwhile sharing some thoughts on how to craft fire risk management strategy.
In this article I’ll answer the following questions:
• What is a fire risk management strategy?
• Why it is useful to have one?
• Who might be tasked with developing one?
• When might one be required?
• How should it be structured?
As the title would suggest a fire risk management strategy is focused towards the management of fire risk. There are some subtle differences between a fire strategy and a fire risk management strategy. A fire strategy report describes the fire safety issues and how they are addressed. It acts as a guide for the design team, by identifying standards or setting performance criteria, e.g. for the capacity of a smoke extract system, and/or the fire resistance of elements of structure.
It is the basis of the submission to the approving authorities i.e. Building Control Body and Fire Authority. A concept fire strategy report will evolve through the design process being refined and expanded as the project progresses with a view to becoming an as built fire strategy for use throughout the buildings life cycle.
The term ‘Fire Risk Management Strategy’ was defined in PAS 7: 20133 as “A document which defines an organisations fire risk management system and method of implementing the overarching policy”. A fire risk management strategy can be developed for an organisation responsible for a single building or an organisation with responsibility for a multi-site portfolio.
When designing fire risk management into buildings there is great benefit in providing building occupiers and/or their person designated with fire safety responsibilities i.e. fire, health and safety managers with the opportunity to become involved with the design and construction process – thus ensuring improved operational performance and better working environments.
There are also on-going business benefits; maintenance and operational cost of a building during its lifecycle far outweigh the original capital cost of construction, and these could potentially be explored and relayed by the fire engineer.
• Involvement at an early stage of building, managers and end users or their fire safety / health and safety managers allowing for early challenges of the practical implications of design concepts in terms of how they may impact upon on-going day to day practicalities, maintenance and operational costs pertaining to the fire strategy.
• Ensuring that full training, commissioning and handover is provided at an early stage, which reduces the cost of a protracted handover and means the building will reach optimal performance sooner.
• Allowing for post occupancy evaluation, which monitors the project outcomes post completion against performance and cost criteria, and ensures lessons are learned for future projects.
A fire risk management strategy may be developed by someone designing new buildings or it may be developed as part of organisations fire risk management system documentation. At the design stage, a fire strategy report will usually contain some commentary on management, for example; where it has been necessary to make assumptions regarding the management of the building in the development of the fire strategy these should be stated in the fire strategy report.
The fire strategy report may incorporate more comprehensive commentary on fire risk management, for example; if variations from the national guidance are proposed and justified with the use of fire engineering analysis or simply as the fire strategy report evolves through the design process into an as built fire strategy and more information on the use and management of the building comes to light.
A fire risk management strategy for a single building may remain incorporated within the fire strategy report or become a separate document. If a fire risk management strategy is drafted for an organisation operating a portfolio of buildings it is preferable for it to be a separate document.
A fire risk management strategy can also be developed post occupation. The standard Scope of Works for the Fire Engineer produced by the Fire Industry Association – Fire Engineering Council4 , sets out the following services at RIBA Stage 7 – Use and aftercare (previously RIBA stage L)5.
These services are to produce, or assist in the production, of organisational fire risk management policy, strategy and procedure. Moreover, organisations seeking to achieve a high level of assurance and management system level 1, as defined in BS 9999: 2017 can demonstrate this by conformity to PAS 7. In order to demonstrate attainment of a level 1 management system some organisations may decide to have their management system certificated.
There may be a number of professionals with interest in the development of a fire risk management strategy.
The interested parties could range from fire safety professionals i.e. designers, fire engineers and fire safety managers, or owners, tenants, occupants, facility managers, health and safety managers and security staff.There may be a number of professionals with an interest in reviewing a fire risk management strategy and these could include: regulators and enforcers, including building control bodies, fire authorities, health and safety inspectors, environmental health officers, and environmental agencies.
There may also be third party certification bodies with an interest in certificating a fire risk management system may wish to assess any claim of conformity against PAS 7.
A claim of conformity can be made on the basis of:
1. a first‑party conformity assessment performed by the organization itself (self‑assessment);
2. a second‑party conformity assessment performed by, for example; a trade association; or
3. a third‑party conformity assessment performed by an organization, such as a certification body, that is independent of both the organization responsible for the fire risk management system and, for example; a trade association.
Guidelines for auditing management systems are given in BS EN ISO 190116 . Requirements for bodies providing audit and certification of management systems are given in BS EN ISO/IEC 17021-17.
PAS 7 imposes a requirement that the organisation shall define and document its fire risk management strategy in order to implement and maintain procedures that identify the aspects of its activities, products and services relevant to the scope.
By considering the context of the organisation it is possible for the organisation to evaluate the risks to the organization by determining and recording those aspects that can have a significant impact on life safety, property protection, business continuity and the environment, as dictated by the organisation’s policy. The fire risk management strategy shall address the following seven factors of strategic fire risk management:
1. fire risk assessment
2. resources and authority
3. fire safety training
4. control of work on site
5. maintenance and testing
7. emergency planning
Michael Porter once said “Strategy is about making choices, trade-offs; it’s about deliberately choosing to be different”8 . In many ways this is true of a fire risk management strategy.
A strategic fire risk management approach can be defined as an integrated or holistic approach to understanding and managing the risks posed by the threat of fire which enables an organisation to optimise its underlying processes and achieve more efficient results. In our experience, no two organisations have the same strategy even if they are in the same sector.
The benefits from establishing effective fire risk management strategy are clearly demonstrable, being able to align the nuances of fire risk management, into the broader auspices of safety/quality management. This is particularly useful for organisations standardising approaches within other disciplines such as: Health and Safety, environmental protection, business continuity, security and quality systems.
BB7 are offering a free gap analysis against the requirements of PAS 7: 2013 – Fire Risk Management System Specification. We are particularly interested in hearing from organisations with complex fire risk management challenges.
BSc Hon’s MSc MBA CEng FCIBSE FRICS FIFireE PPCABE
1 Bradford, Ben (2016) BB7 Where fire is concerned, honesty is the best policy.
2 British Standards Institution. (2017). BS 9999: 2017 – Code of Practice for fire safety in the design, management and use of buildings. London: British Standards Institution.
3 PAS 7: 2013 Fire risk management system. Specification.
6 BS EN ISO 19011:2011 – Guidelines for auditing management systems
7 BS EN ISO/IEC 17021:2011 – Conformity assessment. Requirements for bodies providing audit and certification of management systems
8 What is Strategy? 1996. Harvard Business Review November 1996. Michael Porter