As the time approaches in 2013 for general practices to register with the Care Quality Commission, and comply with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010, it is essential that they review their premises safety systems in good time to ensure compliance. This includes the vitally important area of fire safety. Martin Hodgson outlines the key requirements for fire safety in primary care and what primary care managers should do to ensure that they comply with the CQC standards when the time comes to register.
By law all workplaces must have procedures in place both to prevent the outbreak of fire and to warn and evacuate occupants of buildings in case fire does occur.
Employers have responsibility for ensuring the health, safety and welfare of their employees and others who may have access to the workplace. These general duties include safety in relation to fire hazards, both from the work processes and activities, as well as general fire safety in the workplace. In England and Wales they are augmented by specific duties for fire safety under the Regulatory Reform (Fire Safety) Order (RRO) 2005. In Scotland the Fire (Scotland) Act 2005, as amended, applies.
Complying with the law
Under current fire regulations employers have a statutory duty to:
carry out a fire risk assessment of the workplace
identify the significant findings of the risk assessment and the details of anyone who might be especially at risk in case of fire
provide and maintain such fire precautions as are necessary to safeguard those who use the workplace
provide information, instruction and training to employees about the fire precautions in the workplace.
The regulations also require organisations to name a “responsible person” who will oversee fire arrangements and ensure that the fire risk assessments focus on the safety of all people using the premises, especially the disabled or infirm.
Fire risk assessments
The fire risk assessment forms the basis of an organisation's fire safety precautions and is a key requirement of the law. It should be conducted by the “responsible person” or by another competent person and can be carried out either as part of a general risk assessment or as a separate exercise. The aims of the fire risk assessment should be to:
identify any fire hazards
eliminate the hazards or to reduce the risk to as low a level as reasonably practicable
decide what physical fire precautions and management arrangements are necessary to ensure the safety of people in the building if a fire does start.
The fire risk assessment should take the whole of the premises into account, including outdoor locations, sheds and storage areas, and any rooms or areas that are rarely used. If the premises are small, as many practices are, it may be possible to assess it as a whole. In larger premises, it is usually easier to divide it into rooms or a series of assessment areas.
The findings of the risk assessment should be communicated to staff and recorded. Once complete a fire plan can be developed that takes account the findings from the risk assessment.
Fire safety arrangements
The exact contents of an organisation's fire plan will be dictated by its fire risk assessment but all primary care organisations should try to minimise risks by taking the following steps.
All practices should have a fire policy in place that is implemented in practice, agreed with staff representatives, shown to new staff on induction and regularly updated and reviewed.
A fire plan should be developed which includes well-thought-through evacuation procedures. These must be designed with great care and with the particular needs and capabilities of the people using the premises in mind. Infirm patients, or those with mobility difficulties, must be helped to evacuate by making staff responsible for them and by setting out a designated protocol for evacuation that takes into account staff numbers. The capabilities of staff at low staffing periods must be considered in the plan.
Members of staff should be nominated to be fire wardens. Their role is to support the day to day implementation of the fire policy, to ensure all staff participate regularly in fire safety training and fire drills, to co-ordinate and direct staff in the event of a serious fire, and to liaise with the fire brigade upon their arrival.
Fire escape routes and exits should be clearly marked and Braille signs should be used to help visually impaired service users. Special attention should be paid to lighting around stairs and fire exits. Both should be kept clear of clutter and checked regularly.
Special attention should be paid to fire doors, which are a major protection in a premises against the spread of smoke and which are sometimes found propped open by fire crews. It is essential that fire doors are kept closed and staff are trained to make regular checks that this is the case in premises that do not have automated fire door closure systems.
Fire drills should be carried out frequently and practices should provide adequate levels of fire training for staff. All organisations should have a fire prevention strategy which seeks to raise the awareness of staff, patients, visitors and contractors to the dangers of fire.
Fire detection systems, extinguishers and alarms should be checked regularly as recommended by manufacturers and should be serviced frequently by qualified contractors.
Other measures, such as checking that no-smoking policies are strictly enforced and electrical safety, are also essential, as is the development of a partnership relationship with local fire brigades whose advice should be sought in any areas of concern.
It is recommended that a fire safety officer be asked to inspect and report on the premises and make recommendations about types of alarms, extinguishers, fire doors and smoke/heat detectors. Alarm systems should ideally be automated and integrated with electrical fire detection systems, sprinkler systems and heat and smoke detector systems.
Emergency fire procedures should be clear and follow national good practice. Staff should be trained to, in the event of fire:
sound the alarm immediately
call the fire brigade immediately
ensure that all patients, staff and visitors evacuate affected areas of buildings via the nearest exits immediately and assemble in prearranged muster points.
During evacuation one member of staff should be responsible for checking the nominal role and ensuring that everybody is accounted for. The names of any missing persons must be reported immediately to the officer in charge of the first fire appliance to arrive. Staff may attempt to fight a minor fire with available fire-fighting equipment but only once the evacuation is under way and provided they can do so without personal risk. Evacuation is the primary concern.
All staff should be trained in the location of fire alarms and relevant equipment, the exit routes from buildings and the fire routine and plan.
Practice managers should ensure that the organisation has a fire evacuation plan. The plan itself should be simple and clear. Escape routes in a building should be designed so that those inside can get away quickly and not be placed in any danger from fire. The routes should be depicted on fire notices displayed around the building.
Helping elderly or infirm patients to evacuate a building is probably the most difficult part of any fire evacuation procedure relating to a healthcare premises. Practice managers should therefore ensure that all primary care premises have a pre-worked plan that has been practised during fire drills and communicated to all staff.
Action to be taken after a fire or incident
Existing risk assessments, policies, procedures and training should be reviewed immediately after a real fire or after a “near-miss” — especially where a small fire has been caught early and extinguished. The cause of any incident, no matter how small or seemingly trivial, should be identified, investigated and reported. Lessons should be learnt and fed back into the risk assessment.
Practice managers have a statutory duty to provide or arrange adequate levels of fire training for staff working in the practice. Training should be based on the particular features of the workplace and employees roles. However, all training should:
cover emergency evacuation procedures and plans
explain the duties and responsibilities of employees, including individual roles and responsibilities within the general plan
take account of the findings of risk assessments
cover the procedures and equipment to be used in the event of fire, eg the location of fire extinguishers and fire exits
be easily understandable by employees.
All staff should be trained in evacuation arrangements and be shown the means of escape as soon as possible after attending the premises for the first time, preferably as part of their induction training. A key goal of fire safety training is to ensure that all staff understand the importance of sounding the alarm if they suspect that a fire may have started. Some staff, especially junior members, may need reassurance that they will not “get into trouble” in the case of a false alarm.
Face-to-face training can be provided by arranging in-house sessions from a competent training provider. In some cases it may also be sourced from a local NHS Trust or primary care body. Accurate records of attendance should be kept.
E-learning is growing in popularity and some very good fire e-learning packages exist. A good source is the Skills for Health Core Learning Unit site, which is accessible to staff with an NHS e-mail.
Fire safety and the CQC
As from April 2013 all primary care providers that carry out regulated activities under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010 will have to be registered with the CQC in order to practise. Guidance about Compliance: Essential Standards of Quality and Safety, published in March 2010, contains the outcomes the CQC expects service users to experience if a provider is compliant with the regulations.
Within this guidance providers must comply with the requirements of Regulation 15 and Outcome 10: Safety and Suitability of Premises. This specifies that providers must ensure that people who work in or visit the premises are in safe, accessible surroundings that promote their wellbeing and protect them against risks associated with unsafe or unsuitable premises. This includes risks from fire.
This requirement is supported by a number of prompts which describe what effective services should do in order to deliver the required outcomes and comply with the regulations. Service providers must:
meet the requirements of the Health and Safety at Work Act 1974 and associated regulations, including the Regulatory Reform (Fire Safety) Order 2005 and other relevant legislation (Prompt 10A)
ensure that service users, visitors and staff know what to do in the event of an emergency (Prompt 10E)
ensure that there are fully planned and practised fire evacuation procedures in place (Prompt 10G).
Outcome 20 also relates to the need for service providers to report the failure of a fire safety system to the CQC, while Outcome 21 requires them to keep fire records for a minimum of three years.