Should the humble EICR be improved?


Should the humble EICR be improved to include a tick box for a valid/in date FRA (Fire Risk Assessment) for blocks of flats for the communal area? This would be in line with The Regulatory Reform (Fire Safety) Order 2005,

Some things to note might be
THE NATIONAL Fire Chiefs Council (NFCC) has published a position statement urging the Government to introduce more robust regulations




As always please be polite and respectful in this purely academic debate.


Come on everybody let’s help inspire the future.


  • Surely fire barriers and sealing on an EICR is a limitation. We have no idea what is hidden.

    Gary

  • Referring to situations where a known fire barrier situated above a ceiling for example appears to have been compromised with no subsequent resealing. So prior to this, it is essential to ascertain the division of the buildings fire compartments, if such divisions exist. The inspection will be documented as a representative example on the certificate.

  • Maybe the humble EICR and the humble FRA should have a tick box that refers to the other being present and in date/valid.

    So starting from nothing, how could you sign off the first? (For the definition of recursion, see recursion...)

       - Andy.

  • Worse than that, in an older  building without access to plans an history, how do you know if what is there is supposed to be there, or is now redundant since a re-configuration - perhaps a change of use ?

    Or what is simply missing that ought to have been  there ?The position of the fire zone boundaries may well have moved since original construction. For example I work somewhere that now has far more fire doors than it needs, and has hose reel points where the hose has now been removed, once sprinklers were added. If one of the 'not needed' firedoors was changed for an ordinary one, that would not be an issue, but without the full history it would be hard to tell.

    At some point between actually becoming the fire risk assesor, and total denial of any responsibility for anything non-electrical, lies a limit of knowledge.

    Mike

  • One of the key aspects we inspect is the provision of fire barriers, sealing arrangements, and protection against thermal effects, as outlined in section 527. If during the inspection, this area is marked as ‘Limitation’ (LIM), it is essential to provide a clear explanation for this.

    For instance, if a comprehensive fire risk assessment is necessary to determine the adequacy of fire barriers and sealing arrangements, this should be noted in the report.The outcome of this assessment can then inform any required remedial actions to address the identified limitations

  • what is your approach to tackling this tick box on an EICR ?

  • Lots of vaid points there Mike.  I wonder what the Grenfell Inquiry will bring up when it is published in September 2024

  • (For the definition of recursion, see recursion)

    Thanks Andy - I think my point is that despite the natural professional superiority (!), the building design process may not always start and end with an electrician, and his or hers may not be the dominant set of decisions.

    M

  •  

    I had to take early retirement from work as a facilities manager for health reasons but still think about work matters every day and am still very much interested in various subjects, electrical installations being one of them.   So, here is my two penneth on this question.

    I personally do not think that the EICR should include a tick box on the existence of a FRA.  As others have said, its outside of scope and conducting an EICR properly is challenging enough.

    On the other hand, in my experience Fire Risk Assessments do have a check box for things like the presence of and adequate maintenance of fire doors, fire alarms, fire shutters, emergency lighting, EICR’s etc.  They do not cover legionellosis or lifting appliances as they are not relevant to fire safety.  Most fires are started by electrical issues so it’s only right that the fire risk assessment should check whether the installation is / was safe and is hence being managed.  The problem I’ve personally experienced is that FRA’s were often massively incorrect due to a lack of competence of their authors, inadequate team working in asking before writing, simply failing to look properly, or even repeating the same factual errors of previous FRA’s for which correcting feedback had been given.   Competence in fire safety is, or certainly was, an issue similar to what is commonly discussed here and on other electrical forums in terms of competence of people completing EICR’s.

     

    While I wasn’t entirely sure of the IET’s intent for Regulation 527, in my own former specification for carrying out an EICR I used to include the following wording:

    Where zones of fire protection have been provided or are clearly evident, the inspection should include a check on the integrity of any fire stopping that may have been installed in accordance with Regulation 527.2 - Sealing of wiring system penetrations.

    In practice, I cannot recall it ever being carried out by an electrical contractor during an EICR.  On the other hand, I certainly encountered instances where fire stopping around services penetrations was lacking in both old and new commercial installations where it should have been present e.g. boiler room walls or between floors in a multi storey building.

     

    The Government produce a series of guidance books on Fire Risk Assessments at Fire safety in the workplace: Fire risk assessments - GOV.UK (www.gov.uk) and for instance the one for offices and shops can be seen at 9449_Offices_and_Shops_v2.pdf (publishing.service.gov.uk) where the text in

     

    In some very small offices and shops, record keeping may be no more than a few sheets of paper (possibly forming part of a health and safety folder), containing details of significant findings, any action taken and a copy of the emergency plan. The record could take the form of a simple list which may be supported by a simple plan of the premises (see Figure 12). In more complex premises, it is best to keep a dedicated record including details of significant findings, any action taken, a copy of the emergency plan, maintenance of fire-protection equipment and training. There is no one ‘correct’ format specified for this. Further guidance is given in Part 2, Section 7.1.

    You must be able to satisfy the enforcing authority, if called upon to do so, that you have carried out a suitable and sufficient fire risk assessment. Keeping records will help you do this and will also form the basis of your subsequent reviews. If you keep records, you do not need to record all the details, only those that are significant and the action you have taken. It can be helpful to include a simple line drawing to illustrate your fire precautions (Figure 12). This can also help you check your precautions as part of your ongoing review.

    The referenced drawing at figure 12 is an example line drawing plan showing general fire safety precautions including those walls of 30 minute fire resistance. 

    In my opinion, a good FRA would therefore include a plan of the zones of fire resistance and that plan could be used by the electrical competent person to meet Regulation 527. 

    I am not up to date on the current situation with fire safety since leaving work but I was aware of plenty of recommendations on minimum standards of competency of risk assessors in order to improve that industry.

  • You must be able to satisfy the enforcing authority, if called upon to do so, that you have carried out a suitable and sufficient fire risk assessment. Keeping records will help you do this..

    Is there an assumption that the records will survive any possible fire on the premises then?

       - Andy.