The maintenance of ageing fire precautions

As part of an overall maintenance strategy, organisations should identify ageing fire precautions and have in place a regime to maintain such items.

Many buildings will have fire precautions that can be described as physical assets that need to be properly maintained to ensure that they are fit for purpose and continue to function as efficiently and effectively as possible. This will ensure legal duties in relation to protecting relevant persons from the risk of fire are met.

All fire precautions will be subject to ageing, which if not managed appropriately can lead to equipment failure, which in turn can lead to future regulatory non-compliance, increased fire risks to life and greater business continuity issues in the event of a fire.

As part of an overall maintenance strategy, organisations should identify ageing fire precautions that may require a maintenance regime that goes beyond “best practice”, and put into place the regime to maintain such items.

Legal duties

Article 17 of the Regulatory Reform (Fire Safety) Order 2005 states that “where necessary in order to safeguard the safety of relevant persons the responsible person must ensure that the premises and any facilities, equipment and devices provided in respect of the premises under this Order … are subject to a suitable system of maintenance and are maintained in an efficient state, in efficient working order and in good repair”.

It should be noted that similar requirements are contained in the respective legislation for Scotland and Northern Ireland.

In this context, “where necessary” can be taken as meaning that the duty holder must do what is reasonable to protect relevant persons in terms of the maintenance needs of the facilities, equipment and devices provided under the Regulatory Reform (Fire Safety) Order 2005.

In turn, these can be described as the general fire precautions that will include measures:

• to reduce the risk of the spread of fire on the premises
• in relation to the means of escape from the premises
• for securing the safe use of the means of escape
• for fighting fires on the premises
• to the means for detecting and giving warning of fire.

The key part of Article 17 is the requirement for these elements to be maintained in an efficient state, efficient working order and good repair. Guidance for enforcing authorities notes that this is a three-part test that can be best described as follows.

• The equipment/device/facility works to its required design and specification (eg the fire warning system is functioning).
• The equipment/device/facility is in good repair, free from physical damage or disrepair (eg call points not hanging off walls).
• The equipment/device/facility is subject to regular testing, inspection and examination to remain in an efficient state.

Maintenance of general fire precautions is an essential part of the overall fire risk management framework and can form part of any formal enforcement procedures.

Government publication, Guidance Note No 1: Enforcement, states that risk assessments should include references to maintenance. It continues by stating that enforcing authorities are “expected to use their professional judgement in evaluating the maintenance of any equipment and devices provided in accordance with the risk assessment to protect all relevant persons in and around the premises from the dangers of fire”.

Ageing asset issues

To meet the above requirements, those responsible for fire safety will normally adopt a regime of planned preventative maintenance based upon best practice (such as detailed in relevant British Standards) in conjunction with a reactive repairs regime in the event of defects occurring/being identified between maintenance schedules.

However, during its lifecycle all fire precautions can degrade due to age-related mechanisms and it may be the case that maintenance frequency and regimes could be required that are beyond those recommended in the British Standards. It is therefore essential that as part of the overall maintenance regime, such ageing is identified, considered and appropriate measures are taken to manage the risks.

When referring to ageing fire precautions, it is important to note that this does not necessarily relate to the chronological ageing process, rather ageing is “the effect whereby a component suffers some form of material deterioration and damage with an increasing likelihood of failure over the lifetime of the asset”.

As an example, a property can have fire door assemblies of the same age and specification throughout the premises, yet one assembly could be subject to greater ageing due to its location, frequency of use and potential for damage to occur through use.

The management of ageing fire precautions therefore begins with an awareness that ageing is not about how old the equipment is, but what is known about its condition, and the factors that influence the onset, evolution and mitigation of its degradation. This suggests that for those with responsibility for maintaining ageing fire assets, there is a need to:

• organise ageing management in terms of identifying the assets, what they do and their criticality to the business
• make an assessment of current condition through appropriate condition surveys, inspections and associated risk assessments including how condition may change over the asset lifecycle
• implement an “ageing management programme” including the use of preventative or condition-based maintenance regimes
• ensure there is feedback and analysis of the process to ensure it remains fit for purpose, including the use of performance indicators.

As well as the physical ageing process, other factors will need to be given consideration. This can include obsolescence and a lack of spare parts or the disappearance of the original equipment manufacturer, or non-conformance with current safety requirements, codes, standards and procedures.

Competency, availability and organisation of the employees/contractors responsible for asset management are also essential to ensuring that this understanding of current and predicted asset condition is used when making asset management decisions.

Management programme

BS 9997: Fire Risk Management Systems notes that organisations should “plan, document, implement and manage the processes for maintenance and testing of fire safety systems to ensure that they operate correctly in the event of fire”.

As part of this, an organisation may require an “ageing maintenance programme”. This should detail the actions necessary to ensure any ageing fire precautions are maintained in an efficient and cost-effective way. The main elements of such a plan will be as follows.

• Scope of the ageing management programme (AMP) (selection of systems, structures, components and understanding of ageing).
• Preventative actions (operating procedures/controls to minimise ageing).
• Detection of ageing (inspection, testing, plant monitoring).
• Monitoring of trends (data analysis, predictive analysis, etc).
• Acceptance criteria (performance standards, incredibility/probability of failure).
• Mitigation actions (maintenance, repairs, replacement, etc).
• Corrective actions (revised operating procedures, de-rating, refurbishment).
• Feedback of operating experience (failure database).
• Quality management (record keeping).

It should be noted that within an ageing maintenance programme there may be differing schedules from those in relation to statutory compliance requirements being met through normal best practice. Where this is the case, the ageing maintenance programme needs to interface with such compliance requirements.

It should be noted that management of ageing fire precautions will require regular monitoring, review and revalidation following any unwanted incidents, major repairs, refurbishment or replacement of key items.

Summary

Managing ageing fire precautions effectively may require a shift in the way fire asset condition is regarded, assessed and maintained. This requires a proactive approach with a thorough understanding of the fire asset ageing mechanisms and condition, and the ways in which assets interact (including cause and effect).

The characteristics of an “ageing asset” can be defined as when:

• damage due to degradation has accumulated and may have become widespread and be accelerating
• design or performance margins may have eroded to a point where future acceptable performance cannot be assumed
• a different more quantitative approach to proactive and reactive maintenance may be necessary for determining the extent and rate of damage to demonstrate fitness for service
• proactive ageing management and asset care is required through revalidation, major repairs, refurbishment and replacement of key items at various times.

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