In this Briefing Note we consider the maintenance of fire safety arrangements during the current pandemic, as it is of critical importance to make sure that workplace fire safety risks continue to be adequately controlled.
Irrespective of the risks arising from COVID 19, any applicable fire safety legislation remains in force, and the duties arising remain unchanged. However, fire safety legislation is not prescriptive, so providing appropriate supplementary or alternative fire safety arrangements are implemented, and that the overall objectives of the legislative requirements are met, then the Responsible Person will generally have discharged their duties.

Core Requirements

When considering the changes in the premises that have been introduced in response to COVID 19, in all cases, the initial starting point must be a review of the existing fire risk assessment, fire safety arrangements and fire procedures to determine whether they remain valid.
Relevant changes to the premises can include, but are not necessarily limited to, the following:
• Reduced occupancy numbers.
• The absence of key personnel, such as fire wardens and assembly marshals.
• Reduced ability to record the presence of, and account for, staff, contractors and visitors in the event of an evacuation.
• The implementation of one-way or queueing systems.
• The erection of screens and barriers.
• Waste collection arrangements.
• The size and location of assembly points.
• The ability to establish the evacuation status of parts of the building that are under the control of others.
• The storage of significant quantities of alcohol-based hand cleanser.

Having reviewed the changes that have been implemented within the premises, it will then be necessary to review the fire safety arrangements and amend them so that they remain suitable and sufficient, and most of all, workable under the prevailing circumstances.

Answers

The following answers to some common questions will hopefully set out how the issues raised might be addressed.

  • Fire Wardens – is there an adequate number throughout the day and do their duties and responsibilities require revising? Key personnel which include Fire Wardens and Assembly Marshals may be absent. You should ensure you have sufficient adequately trained personnel to carry out these roles based on current occupancy levels.
  • Fire Risk Assessments – What needs to be done to ensure changes to occupancy numbers and working practices have been properly assessed. Fire Risk Assessments should be reviewed to ensure they remain valid with reference to the changes to the premises as outlined in Core Requirements above. Check that current Personal Emergency Evacuation Plans (PEEPs) are not affected and that named ‘buddies’ will be present at all times (as they may be working from home). If emergency voice communications form part of the PEEPs you will need to ensure they remain fully operational (suitable PPE should be made available at designated refuge points) or amend your PEEPs as required.
  • One-way systems, safety screens and queuing systems – Do any of these arrangements impact on escape routes and travel distances? Do screens obstruct detectors or sprinkler heads? Are sufficient and suitable fire extinguishers provided? Can fire alarm call points be accessed on one-way systems? In an emergency, can occupants easily leave the one-way system to access the nearest escape route or does the one-way system lead occupants away from the nearest exit? You will need to ensure that any measures introduced resulting from the pandemic do not adversely affect means of escape, travel distances, signage, extinguisher and fire alarm call point accessibility, detector, or sprinkler heads.
  • Should there be consultation with insurers and possibly Fire & Rescue Authorities? Where appropriate you should consult with your insurance company if conditions internally (or externally) have materially changed from when the original policy was issued. The Fire Authority will also need to be consulted if there are material or structural alterations or if any passive or active fire safety measures have been changed / withdrawn – (in these instances it is strongly recommended that you carry out a further Fire Risk Assessment that will incorporate any such changes).
  • Can fire doors be wedged open to improve air circulation? No – as fire doors form a vital part of the building’s passive fire protection. It may be acceptable to fit certain doors with magnetic door holding devices linked directly to the fire alarm (BS 7273-4). You will need to involve your approved fire alarm contractor to carry out this type of work as a critical (Cat A) interface between the fire alarm system and the hold open device is necessary in certain circumstances. Buildings with a single staircase or sleeping risk should not use acoustically activated hold-open devices under any circumstances.
  • Do current assembly points facilitate social distancing? Are current assembly points sited close to passing members of the public? Are several assembly points required to ensure social distancing? Can virtual assembly points be established using technology? Can communications at assembly points be improved using technology to remain effective but also to help with social distancing? The objective in any evacuation is to clear the building and be able to advise the Fire and Rescue Service (FRS) of the building’s evacuation status. A secondary business continuity objective is to be able to advise evacuated persons of the situation and what actions are required of them. Subject to someone being appointed to collate status reports from individual Fire Wardens, to liaise with FRS and there are means of communicating with those who have been evacuated, there is no specific requirement for designated assembly points thereby maintaining social distancing.
  • Do I need to continue with testing and maintenance programs for the fire alarm/emergency lighting etc? Yes – you should continue with maintenance and testing programs for all fire safety systems and equipment.
  • Are we legally obliged to carry out fire drills and observe social distancing? There is no legal requirement to carry out a fire evacuation drill in the generally accepted way. There is however, a legal requirement to train staff in fire precautions and actions that they would need to take in order to safeguard themselves and relevant persons on the premises in the event of a fire. The standard model invariably used is no longer always appropriate and it is most likely to require modifying to take account of changes in working practices and reduced building occupancy because of the pandemic.  In some instances, it will be appropriate to limit participants in an evacuation drill to better control social distancing and supplement the drill with additional familiarisation training. This could be achieved by amending the existing evacuation drills and adopting a more modular approach involving evacuation of individual floors or departments at any one time. Alternatively, the drill could involve only Fire Wardens, new starters and personnel who would be expected to take the lead in an evacuation. This would ensure that in the event of a genuine alarm, they would be able to help with the evacuation of colleagues. Social distancing must be observed during evacuation fire drills.
  • Do I need to stop to put on my face covering / mask or other PPE? For a fire evacuation drill then yes, but for an unplanned fire evacuation then you should not delay your evacuation to collect these items.

We hope that the above guidance will answer some of the fire safety questions which you may have with regards to the current pandemic.
At William Martin Compliance we have a nationwide team of experts who offer a comprehensive range of fire safety compliance services to property management professionals. Please do not hesitate to contact us with any specific questions you may have.

For all enquiries please contact us: enquiries@wmcompliance.co.uk or call our team on 0203 819 8829

Click this link to download the Fire Safety Procedures During Pandemic – Briefing Note.