Fire safety requirements: A management system approach

In the wake of the Grenfell Tower tragedy, the UK Government published an independent report into building regulations and fire safety, produced by Dame Judith Hackitt. Robert Morley, a Lead Assessor at MMRA of fire risk management systems to BS 9997:2019, explains the management system approach to fire safety requirements. 

The Grenfell inquiry and subsequent report highlighted a series of failings within general management and control of building fire safety and presented a suite of recommendations in an attempt to address these concerns. There were a couple of key recommendations from the Hackitt report that are of particular relevance to organisations that wish to develop their approach to fire risk into a formal management system.  

The FRMS interconnects and integrates with elements of other management systems such as competency, document control, recording and monitoring so many of the base requirements will be familiar to most organisations, not least the requirement to demonstrate learning and continual improvement.

The first called on organisations to have an information system in place and a requirement to maintain relevant documentation on the buildings they manage. The second said duty holders should have a safety case file, identifying key hazards and risks and describing how they control those risks through a safety management system.  

These two recommendations provided BSI with the foundation for the development of BS 9997:2019, which built on the previous fire risk management system standard PAS 7. That is where the fire risk management system (FRMS) comes into play; BS 9997:2019 provides a framework by which organisations can demonstrate compliance with those recommendations, among many other requirements, through their accreditation to the standard.  

BS 9997:2019 covers a wide range of premises and they don’t necessarily have to be inhabited. All buildings carry an element of risk, occupied or not. Warehouses, office blocks, institutions and residential blocks can, therefore, all potentially be covered by BS 9997:2019.  

No room for error 

It is a detailed standard, with more than 70 normative requirements many of these requiring documented evidence to demonstrate that a particular element of the standard is being addressed.  

There are of course existing regulatory requirements in place to address basic aspects of fire risk in buildings such as the need to carry out regular fire risk assessments. BS 9997 does incorporate these requirements, but within the context of a holistic fire risk management system (FRMS). The FRMS interconnects and integrates with elements of other management systems such as competency, document control, recording and monitoring so many of the base requirements will be familiar to most organisations, not least the requirement to demonstrate learning and continual improvement. For example, if an organisation regularly has incidents of false alarms or missing firefighting equipment, the FRMS should demonstrate these incidents are being captured and acknowledged, and that appropriate actions are put in place to reduce their reoccurrence.  

Achieving accreditation to BS 9997:2019 

MMRA is currently the only organisation offering accreditation to BS 9997:2019. The accreditation system used by MMRA is approved by UKAS, thereby BS 9997 accreditation by MMRA provides clear traceability up to the national accreditation body.  

As an accreditation body, MMRA must remain independent and impartial when providing its accreditation services. As such, we generally become involved once there is a functioning FRMS in place in the client organisation, covering whatever it decides is its scope of properties. 

MMRA will carry out an initial accreditation to BS 9997:2019 using a two-stage process.  Stage 1 involves the client organisation providing written evidence against each of the 70-plus normative requirements of the standard. Invariably, this will involve the submission of a variety of documents and many will already be in place covering other systems such as ISO 9001, for example. BS 9997:2019 is concerned with these management elements too, so there may be a whole raft of documents for the client to submit.  

The Stage 1 process is a desktop exercise – a remote assessment to check the organisation has all the key documentation in place. MMRA will assess the documentation and provide feedback as to whether we consider what has been supplied is sufficient to address the requirements.  

Putting the FRMS together is, a significant undertaking as the organisation must have systems in place that demonstrate that not only is each clause being addressed but that it is also being correctly implemented and understood by the relevant members of the organisation.  

Stage 2 of the assessment is a more traditional audit whereby MMRA will schedule interviews with key personnel, such as the Fire Risk Manager, local building managers and senior executives, to ensure the requirements of the standard are being implemented in line with procedure. It is not just a case of having the documents on a shelf somewhere – people have to be using them. As a result, we ask for evidence of how staff manage their day-to-day fire risk requirements such as fire drills and checking the condition and operation of fire doors and firefighting equipment.  

The Stage 2 assessment takes two to three days, as it also involves reviewing documentation, providing feedback and closing out any remaining issues.  

Looking forward 

Providing there is successful close-out of all the remaining issues from the initial assessment MMRA will issue a certificate of compliance against the requirements of BS 9997:2019 and the organisation becomes accredited to the standard. The work does not however stop here, in order to maintain their certification, the organisation is subject to annual surveillance audits and a more detailed three-yearly re-certification audit. This ensures the organisation is taking positive steps in addressing findings and recommendations from previous audits as well as taking positive and continual action in improving their FRMS.