As part of their general responsibility for the maintenance of church buildings, church halls, and the like, Incumbents and PCCs have always needed to make appropriate arrangements for dealing with the outbreak of a fire. Most architects point out, as part of their Quinquennial Inspection reports, the suitability or otherwise of lightning conductors and fire extinguishers.
Similarly, church and church hall insurers frequently stipulate the provision of fire extinguishers. PCCs have always found themselves, as in so many matters, weighing the cost of substantial provision in this area against any legal requirements and stipulations of insurers.
Correct maintenance of electrical systems is one of the best ways to prevent the outbreak of a fire in a church building while unattended.
The Regulatory Reform (Fire Safety) Order 2005, requires churches to undertake an assessment of all fire risks.
WHAT NEEDS TO BE DONE?
Ecclesiastical have kindly allowed us to reproduce their document on Fire Precautions:
The RRO applies to all businesses, places of worship and the voluntary sector. It does not apply to private dwellings in single occupation. A Responsible Person is required to conduct a comprehensive risk assessment in order to:
- Identify any possible dangers and risks including sources of ignition
- Identify people who may be at risk, especially those working alone or in isolated areas, children or parents with babies, the elderly or infirm and people with disabilities
- Evaluate the level of risk, and remove or reduce any fire hazards where possible.
- Protect people by providing fire precautions such as fire extinguishers, emergency escape routes and exits
- Record any major findings and the action taken, prepare an emergency plan, inform and instruct relevant people such as stewards and provide any necessary training
- Review the fire risk assessment regularly and make changes where necessary
Where five or more persons are employed a formal record of any significant findings and remedial measures which have or may need to be taken must be made. We would advise that irrespective of the number of employees, or even if you have none, that you make a record of your risk assessment and record the measures you have put in place.
The Responsible Person can be one of the following:
- Employers with control of the workplace.
- Person with overall management control of a building
- Occupier of the premises.
- Owner of premises if an empty building
- Landlord where the building is in multi-occupancy
The Responsible Person must appoint one or more Competent Persons to assist in undertaking the preventative and protective measures. A person is regarded as competent where they have sufficient training and experience or knowledge and other qualities to enable them to properly assist in undertaking the preventative and protective measures.
Government guidance documents
The Government has issued a range of detailed guidance notes. These include Small and Medium Sized Places of Assembly (up to 300 persons) which includes churches and church halls and Large Places of Assembly (over 300 persons) which includes large churches and cathedrals. An entry level guide ‘A short guide to making your premises safe from fire’ and a fire risk assessment form are also available. This and all of the other guides can be downloaded from www.firesafetyguides.communities.gov.uk
Fire risks in the workplace must be assessed either as a separate exercise or as part of a general review of health and safety. Any fire hazards within the premises will need to be identified including possible ignition sources (eg electrical wiring or processes using the application of heat). The use and storage of combustible materials, together with the presence of flammable liquids and gases needs to be noted.
Another hazard to document is the susceptibility of the premises to arson attack. Although it is now illegal to smoke in most premises the control of smoking and the disposal of smoking materials also need to be noted.
Reasonable fire fighting equipment must be provided. As part of the initial risk assessment, a record must be made of all fire-fighting equipment. This includes portable fire extinguishing appliances, hose reels, dry and wet risers, sprinkler systems, smoke venting systems and any other apparatus or equipment provided to deal with a fire.
The location of fire hydrants and the accessibility of the premises for fire brigade appliances should also be noted.
Checks that need to be made:
Whether or not a fire can be detected and people warned within a reasonable time. Details of any existing fire detection system and other methods for raising the alarm need to be recorded.
Anyone who may be in the building should be able to get out safely in the event of a fire. This means looking at fire exit routes, signage and emergency lighting, and recording the existing arrangements.
Everybody who is in the building needs to know what to do in the event of a fire. This means examining existing arrangements for evacuation, written fire procedures, staff handbooks and manuals, and induction and refresher training courses for staff.
Fire safety equipment should be properly maintained. This includes looking at existing service and maintenance contracts and procedures for routine inspections.
A check also needs to be made of the effect a fire in your premises would have on neighbouring premises so that they can take the appropriate action.
If five or more persons are employed the significant findings of the fire risk assessment must be recorded.
We would strongly recommend, however, that all fire risk assessments are recorded irrespective of the number of employees. A written record is invaluable evidence that a fire risk assessment has been carried out.
Are any changes required?
Having noted the existing situation, the next stage of the assessment is to decide whether any changes to the existing arrangements are required including the introduction of additional safety measures.
The following will need to be considered:
- The first stage is to examine the various hazards that have been identified and what control measures can be introduced to either eliminate or minimise the risks as far as reasonably practicable. The best possible control measure is to eliminate the fire hazard altogether. This may be achieved, for example, by the removal of rubbish and combustible materials that are no longer required or the prohibition of smoking from the entire site.
- The substitution of hazardous materials with less hazardous counterparts can reduce the fire risk. For example, replace solvent-based paints, thinners and cleaners with water-based counterparts or ones with higher flash points.
- If hazards cannot be eliminated or substituted, the risk can be reduced by the introduction of engineering controls such as the use of metal cabinets for storing flammables. Ideally, large quantities of flammables should be stored in a purpose built detached building away from the main premises.
- A decision will need to be made whether there is a need to upgrade existing fire detection and warning methods. If the premises are such that a fire could go undetected for some considerable time or people could be working in a part of a building and be unaware of the need to evacuate, an automatic fire detection and warning system is probably required.
- Improvements may also be required to escape routes. This may require the provision of additional fire exit doors. As a minimum, steps will need to be taken to ensure that all exit routes are kept clear of obstructions and that fire exit doors can be opened easily from the inside without the use of keys, cards or digital locks. Additional fire exit signs and emergency lighting may also be required.
- Is additional fire fighting equipment required? As a general guide, one water fire extinguisher with a rating of 13A is required for each 200m2 of floor area. In addition, other extinguishers such as carbon dioxide for electrical hazards will be required.
- The final part of the assessment will be to form an emergency plan. It will need to include the actions to be taken by staff in the event of a fire, evacuation procedures and the arrangements for calling the fire brigade. The necessary training will need to be undertaken to ensure that all staff know what to do.
A periodic review of the fire risk assessment is necessary to ensure that the procedures are amended to take account of new processes, change in the number and location of employees and alterations to the buildings.
The regulations are enforced by the Fire Authority who may inspect the premises to check that the regulations are being carried out.
Following an inspection of the premises, the Fire Authority may issue an enforcement notice requiring safety work to be carried out. If they consider that there is a serious risk to people from fire, a prohibition notice could be issued restricting the use of the premises until remedial action is taken.
In practice there is very little change from the situation prior to the implementation of the new Order. The need to carry out a fire risk assessment has not changed although this now applies to all premises and open air events and there is no longer the need for there to be at least one employee for it to be a legal requirement. The assessment now also requires the Responsible Person to think about the effect of a fire on their neighbours.
Although the guidance notes are very detailed they are designed to be used by lay people. The introduction to the guidance says that it is not prescriptive and that there is no obligation to adopt any particular solution in the guide if fire safety can be met in some other way. However, if you are unable to apply the guidance then you should seek expert advice.
For example, churches do not necessarily have to have fire alarm systems, fire exit signs, emergency lighting or outward opening doors if the risk assessment shows that these are not necessary. However, arrangements must be in place to ensure that a fire can be detected and that persons can evacuate the buildings safely. For example, stewards should have torches and be positioned to open exit doors.
The Order is enforced by the Fire Authorities who can enter premises at any reasonable time without force and issue Improvement and Prohibition notices.