The Fire (Scotland) Act (2005) requires that employers ensure, as far as is reasonably practical, the safety of all employees against the harm caused by fire in the workplace. Fire remains a major cause of damage, physical harm, and fatalities in the workplace. Public buildings and places where groups of people meet are especially at risk.
The main requirement of the Fire (Scotland) Act is for duty holders (in this case, the charity trustees of the congregation) to undertake a fire safety risk assessment (FSRA) and consider a number of prescribed fire safety measures to protect employees and anyone else using the building. The Fire (Scotland) Act is supported by the Fire Safety (Scotland) Regulations 2006 (FSSR), which provide further information and guidance on prescribed fire safety measures and fire safety management.
In general, the law sets out to achieve fire safety in the event of fire and describes seven general requirements:
- Carrying out a FSRA of the premises (one should be undertaken for each premises)
- Identifying fire safety measures necessary as a result of FSRAs
- Implementing these fire safety measures using risk reduction principles
- Putting in place fire safety arrangements for the ongoing control and review of fire safety measures
- Complying with the specific requirements of the FSSR and other associated regulations
- Keeping the FSRA and outcomes under review
- Record keeping
Please note: The fire safety advice provided in this section of the toolkit is general advice and covers the legal requirements of the FRA and FSSR. However, all congregational buildings are different and it would be impossible to provide guidance to fit all circumstances. A degree of judgement is required and it is strongly advised to seek specialist advice when unsure of how to proceed with fire safety arrangements or when it might be difficult or impractical to apply the requirements described within the toolkit to particular properties. This is especially important when buildings of historical importance are concerned. The Church of Scotland General Trustees and the Church of Scotland Insurance Service (COSIS) will be able to offer additional advice and support and you are strongly advised to contact them in the first instance.
The charity trustees and other members of the congregation are best placed to carry out a FSRA, as they know their buildings best. The procedure for carrying out a FSRA is described in the following section and a small group of volunteers should be tasked with undertaking this. However, it is the responsibility of all charity trustees to ensure that the outcomes from the FSRA are implemented. If the charity trustees do not feel that they are comfortable, confident, or competent to carry out a FSRA, please contact the Church of Scotland General Trustees or the COSIS for further advice and guidance.
4.2 Fire Safety Risk Assessment (FSRA)
The FSRA is an essential element in the overall health and safety policy of any premises. The FSRA should be specific to the fire safety arrangements in the premises to which it applies. A general risk assessment, as described in section 2 of this toolkit, is not appropriate when considering fire hazards and risk.
Congregational properties are generally considered to be low risk in terms of fire safety. However, this depends on building location, structure, fabric, activities undertaken, and those who might be at risk.
The FSRA is an organised and methodical look at buildings and the activities taking place within buildings so that the likelihood of fire can be established and the harm that it could cause to the people in and around buildings can be assessed. If fire safety measures are already in place, such as fire alarms or fire extinguishers, these are reviewed during the FSRA to establish if they are still appropriate or if more action is required.
4.3 Five steps of a FSRA
To carry out a suitable and sufficient FSRA, it is important to consider each of the following five points as described within the Scottish Government’s fire safety guidance booklet (ISBN 0-7559-4965-X), available free from www.gov.scot.
Please refer to Part 3.7 of this toolkit for advice on who should carry out the FSRA for properties. There is no prescribed template in the legislation for a FSRA. However, a template has been included in the template section of the toolkit.
Step 1 – Identify people at risk
Describe who works in or uses your properties (inside and outside), including visitors and contractors, and how often they use the buildings. It is also necessary to consider and document in a FSRA the age range of users (including the very young, children, and the elderly), the maximum number of people who can safely use buildings at any one time, and those with disabilities.
Step 2 – Identify fire hazards
For a fire to start, there has to be a source of ignition, fuel, and oxygen. If one of these components is missing, a fire cannot start. It is important to stop these three components from coming together to prevent a fire from starting.
Potential ignition sources are those where sources of heat could become hot enough to ignite material found in the premises, including:
- Discarded smoking material
- Naked flames such as candles, gas open-flamed equipment
- Electrical, gas, or oil-filled heaters
- Hot processes such as repair work
- Cooking equipment
- Lighting equipment such as lamps
- Deliberate fire raising
- Faulty electrical installation and equipment
Potential sources of fuel include fixtures, fittings, contents, and the physical structure of properties. For example:
- Textiles, soft furnishings, and clothing
- Flammable liquids and solvents
- Flammable chemicals
- Seasonal decorations
The main source of oxygen within properties is from open windows and doors. However, any structural defects might also be a significant source of oxygen. Some chemicals are oxidising and may provide additional sources of oxygen if used or stored incorrectly.
Step 3 – Evaluate the risk and decide if existing fire safety measures are adequate
The chances of a fire starting will be low if there are few ignition sources. However, properties should be critically examined to identify any potential accidents, acts, or omissions which might allow a fire to start (please see sections 2 and 5 of the toolkit). It is important to consider the likelihood of deliberate fire raising as part of this evaluation.
Having considered the chances of a fire starting and the people likely to be at risk should a fire occur, the extent of the actual risk to those people must be considered. For example, the possibility of:
- Fire starting on a lower floor, affecting the escape route for people on upper floors, especially when there is only one escape route
- Fire developing near the only final exit
- Fire and smoke spreading because of open windows and doors
- Fire and smoke spreading through large open areas, such as a sanctuary
- Fire and smoke affecting the behaviour of people in the property
Section 55 of the Fire (Scotland) Act 2005 requires that the following principles be considered when implementing fire safety measures:
- Avoiding risks
- Evaluating risks which cannot be avoided
- Combating risks at source
- Adapting to technical progress
- Replacing the dangerous with the non-dangerous or less dangerous
- Developing a coherent overall fire prevention policy which covers technology, organisation of work, and the influence of factors relating to the working environment
- Giving collective fire safety protective measures priority over individual measures
- Giving appropriate instructions to employees
Following identification of fire hazards in step 2, the risks should be avoided by removing or reducing sources of ignition, fuel and oxygen. If hazards cannot be removed, measures should be taken to reduce the risks. Fire safety measures should be put in place to reduce the likelihood of fire and the spread of fire, to provide means of escape, to fight fire, to detect fire and give warning, to arrange for action in the event of fire, and for training.
Step 4 – Record FSRA information
Once the FSRA has been carried out, the findings must be recorded, including any action taken or to be taken in future. The record must be kept on the property and all employees and other relevant people such as volunteers must be made aware of its contents. The fire service may also wish to see a copy of the record if they visit a property.
Although the Fire (Scotland) Act requires that a record is kept if five or more employees are employed, the Church of Scotland requires that all congregations keep a record of their FSRA and any further action taken to control the risks of fire.
Step 5 – Review of FSRA
FSRAs should be reviewed regularly. If the findings of the assessment are considered to be no longer valid, a significant change has taken place affecting a property, or organisation of the work undertaken has affected the fire risk or the fire safety measures, the assessment should be reviewed. Situations which might prompt a review include:
- A change in the number of people present or the characteristics of the occupants, including the presence of people with some form of disability
- Changes to work procedures, including the introduction of new equipment
- Alterations to the building, including the internal layout
- Significant changes to furniture and fixings
- Significant changes to displays or quantities of stock
- An introduction or increase in the storage of hazardous substances
- Becoming aware of shortcomings in fire safety measures or potential improvements.
4.4 Managing fire safety
It is important for the Financial Board to demonstrate a congregation-wide commitment to fire safety within church properties and to promote a positive culture towards the risks of fire. The Financial Board must ensure that the outcomes from the FSRA are used to develop a suitable:
- Fire safety policy for properties
- Emergency fire action plan which must be kept on the property in question at all times
- Fire safety information and training plan
- Maintenance programme of the fire safety measures in place
- Robust recording of information and record keeping
4.5 Fire safety policy
The Financial Board must ensure that there is a clearly defined fire safety policy for the protection of everyone who uses church properties, including staff, volunteers, and visitors. The fire safety policy is similar to the health and safety policy and should include arrangements for planning, organising, controlling, monitoring, and reviewing the fire safety measures taken.
4.6 Emergency fire action plan
The Financial Board must ensure that there is a written emergency fire action plan in place that sets out the action that must be taken by staff and volunteers in the event of a fire, and to ensure the safe evacuation of properties.
It is important that consideration is given to how staff, volunteers and visitors with disabilities will be helped from properties and also how to evacuate safely any children or young people. For example, during worship, duty elders could be asked to take responsibility for the safe evacuation of a property in case of emergency.
4.7 Fire safety information and training
All staff (including stewards, volunteers, performers, visiting contractors, and temporary and agency staff) and other relevant persons should be given information, training, and instruction on the fire safety measures to be taken or observed on the premises, including the action to be taken in case of fire.
The specific fire safety training needs of any young persons employed should be considered.
Training of each member of staff should take place as soon as possible after they are appointed and regularly at predetermined intervals after that, to ensure that they remain familiar with procedures. Information should be given to staff and other relevant persons whenever there is a change in the risk from fire, where changes have been made to the emergency fire action plan or other fire safety measures, or where working practices or people’s responsibilities have changed.
4.8 Fire drills
Fire drills should be carried out to check that all employees, volunteers and anyone else regularly using a property understand and can implement the emergency fire action plan. Fire drills will also provide assurance to the Financial Board of the effectiveness of the emergency fire action plan and identify any weakness in the evacuation policies and procedures. A full fire safety drill, including emergency evacuation, must be carried out at least once a year. Additional fire safety drills should be considered in large properties or properties with a complex layout.
4.9 Maintenance of fire safety measures
In all premises, including those not usually staffed or those used on a relatively infrequent basis, emergency routes and exits, firefighting equipment, fire alarms, emergency lighting, fire and rescue service facilities, and other fire safety measures should be kept in efficient working order and be covered by a suitable system of maintenance. Regular checks, periodic servicing and maintenance should take place and any defects put right as quickly as possible.
Each day that a property is used, a general walk through should take place to ensure that escape routes are clear from obstructions and that any fire detection system is working. All emergency escape doors must be operational and any emergency lighting working.
If a fire alarm system is in place, this should be tested at least on a weekly basis. If alternative methods of alerting property users of the presence of fire are used, these should also be tested weekly.
All other fire safety measures, including fire extinguishers, should be checked on a monthly basis to ensure that they are in the correct location and operational.
4.10 Recording information and keeping records
The Financial Board must keep adequate information and records to demonstrate compliance with fire safety legislation. This includes information on:
- Significant findings from the FSRA
- Fire safety measures implemented and any further action to be taken
- Persons especially at risk
- A copy of the emergency fire action plan
- Details of training, education and information provided
- Maintenance records of specific fire equipment such as the fire alarm system and fire extinguishers
4.11 General considerations of good fire safety management
The following points should be considered by all Financial Boards when looking at fire safety within buildings:
- Adequate, suitable and safe storage provisions and good housekeeping rules should be in place for all the materials used within congregational properties
- Any chemicals, dangerous substances, materials, and equipment must be stored appropriately
- All equipment used within congregational properties must be used as per manufacturers’ instructions
- All electrical installations and equipment must be safe to use and regularly inspected and tested
- A suitable no smoking policy should be in place and enforced
- Suitable arrangements and precautions must be in place to ensure the safe management of building, alteration and remedial work
4.12 Provision of fire alarms and fire extinguishers
Much confusion surrounds whether congregational properties require a full smoke detection and fire alarm system. Fire safety legislation states that there must be a means of alerting property users in the event of a fire. In small properties, a small, hand-operated sounder or a verbal instruction might be sufficient. In larger, more complex properties, a manual or automatic integrated fire system may be required. No specific guidance exists to determine which system is to be used in which situation and it is important that the FSRA evaluates all potential fire safety risks to assist the Financial Board in deciding which is best.
Fire safety legislation states that firefighting equipment must be provided where necessary. Again, the FSRA will assist the Financial Board in their decision making as to whether to provide firefighting equipment. However, it is important to note that any firefighting equipment provided and in place within congregational properties is likely to be used by the fire service when there is a small fire and therefore can be beneficial in protecting the building from extensive damage from fire.
Further advice and information regarding the provision of automatic fire detection and firefighting equipment within congregational properties can be obtained from either the Church of Scotland General Trustees or the COSIS.