Prison
Service
Order
Health and Safety
FIRE SAFETY
ORDER
NUMBER
3803
Date of Initial Issue
Issue No.
09/07/2007
277
PSI Amendments should be read in conjunction with this PSO
Date of Further
Amendments
01/07/09
28/03/08
Addendum – PSI 13/2009: Introduction of Cell Snatch
Rescue Equipment
Annex B added (Preparing evidence and information
for Standard Audit Unit 18 - Fire Safety)
PSO 3803
Page 1
EXECUTIVE SUMMARY
STATEMENT OF PURPOSE
The purpose of this PSO is to ensure that Area Managers, Heads of Groups and Governing
Governors have in place a system for effectively managing the risks from fire to which staff and
others who may be affected by their undertakings are exposed, including a comprehensive Fire
Safety Policy which complies with the requirements of the Regulatory Reform (Fire Safety) Order
2005 and any subsequent legislation or guidance.
DESIRED OUTCOME
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Effective management of the fire risks in the prisons and other Prison Service Buildings;
A reduction in the number of fires across the Service;
Improved health and safety of staff and others because of more effective management of
fire risks;
A reduction in damage to cells and other property.
MANDATORY ACTIONS
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Prepare a local fire safety policy which includes a policy statement, and sets out the
organisation and arrangements for implementing the policy, and bring this to the attention
of all their staff;
Appoint a member of the SMT as the health, safety and fire safety sponsor;
Ensure access to competent fire safety advice and the appointment of staff designated for
specific fire safety duties;
Carry out fire risk assessments and ensure that measures are implemented to eliminate or
control all the significant risks;
Implement arrangements to ensure the safety of staff, prisoners and others in the event of
a fire or other emergency;
Where SDBA is deployed ensure that staff are trained in its use and are subject to regular
health checks;
Provide sufficient fire detection and warning systems, fire fighting equipment, escape
routes and emergency lighting and ensure that adequate fire safety signs are posted;
Have systems in place for checking and maintenance of fire detection and warning
systems and fire fighting equipment;
Implement arrangements to ensure the safety of disabled staff, prisoners and others in the
event of a fire;
Ensure that staff, prisoners and others are given information and training on the identified
fire risks, control measures and evacuation procedures;
Ensure that arrangements are in place for consultation with staff on fire safety issues;
Implement a system for reporting and investigating all fires.
Where a premises is shared ensure co-operation and co-ordination with the other
employer;
Where substances that may cause a fire or explosion are stored or used ensure that
precautions are in place to reduce any risks from such substances so far as is reasonably
practical;
Ensure that a memorandum of understanding between the premises and the local fire
brigade is agreed;
Have in place arrangements to regularly audit, monitor and review fire safety performance.
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PSO 3803
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RESOURCE IMPLICATIONS
Area Managers, Heads of Groups and Governing Governors should already have systems in place
for effectively managing the fire safety risks in their areas of control. The implementation of this
PSO should not result in additional cost for fire fighting equipment. Where additional fire fighting
equipment is required this should not result in significant additional costs.
Many prisons will have already appointed a fire safety advisor who may have received some fire
safety training. However, it is recognised that, to ensure competence under the new Regulations,
there is a need for fire safety advisors to be trained to a higher standard than is currently the case.
A fire safety advisors’ course which will ensure that advisors are trained to the required standard is
currently being developed. The cost of the course has yet to be determined. Interim arrangements
for the training of fire safety advisors is given at para 2.2. .
PEFORMANCE STANDARDS
This PSO underpins the Fire Safety Standard. It will become auditable by SAU six months
following the implementation date.
IMPLEMENTATION DATE:
6 August 2007
Phil Wheatley
Director General
Area/Operational Manager
Further advice or information on this PSO can be sought from:
Steve Brinkworth, telephone number: 020 7217 5196
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PSO 3803
Page 3
PSO FIRE SAFETY
CONTENTS
1.
1.1
1.2
1.3
1.4
1.5
Fire Safety Policy
Legislation
Responsibilities
Fire Safety Policy
Headquarters and Other Office Accommodation
Co-operation and Co-ordination
2
2.1
2.2
2.3
2.4
Organisation
The Health and Safety Model
Access to Competent Advice
Time for Competent Persons to Carry out the Role
Consultation with employees
3.
Planning and Implementing
3.1
Introduction
3.2
Risk Assessment
3.3
Review of Fire Risk Assessments
Contingency Planning
3.4.1
General
3.4.2
Cell Fires
3.4.3
Staff and Others with Disabilities
3.4.4
Memorandum of Understanding
Fire Fighting Equipment
Fire Detection and Warning Systems
Checking and Maintenance of Equipment
Emergency Routes and Exits
Fire Signs and Notices
Fire Investigation and Reporting
Provision of Information to Staff
Provision of Information to Prisoners
Training
Monitoring Performance
Audits
Dangerous substances
Guidance
Annex A
Procedures to take in the event of a fire
Annex B Preparing evidence and information for Standard Audit Unit 18 - Fire Safety
Addendum – PSI 13/2009: Introduction of Cell Snatch Rescue Equipment (CSRE)
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PSO 3803
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PSO FIRE SAFETY
CHAPTER 1: FIRE SAFETY POLICY
1.1
Legislation
1.1.1
The Regulatory Reform (Fire Safety) Order (RRO) 2005, which came into force in October
2006, places a duty on the ‘responsible person’ to implement general fire safety
precautions that will ensure, as far as is reasonably practicable, the safety of employees
and others who may be affected by his/her undertakings and to take reasonable
precautions to ensure that the premises are safe. The RRO also requires the responsible
person to:
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Carry out an assessment of the risks from fire;
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Prepare a policy on fire safety which sets out the arrangements for the effective
planning, organisation, control, monitoring and review of the preventative and
protective measures that are implemented to manage the identified fire risks;
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Appoint a competent person;

Provide information and training for employees.
1.1.2
The RRO refers to the individual with responsibility for ensuring that the requirements of the
Regulations are met as the ‘responsible person’. For the purpose of this PSO the
responsible person for individual prisons will be the Governing Governor. Area Managers
and Head of Group will have responsibility for ensuring that the requirements of the RRO
are met in their areas of control.
1.1.3
This PSO sets out the core policy requirements to ensure compliance with the RRO.
1.2
Responsibilities
1.2.1 The Prison Service Management Board, as the employing authority is responsible, so far as
is reasonably practicable, for:

the health, safety and welfare of its staff;

conducting the business of the Service so as not to endanger the health and safety
of others who may be affected by its undertakings;
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ensuring that systems are in place to effectively manage fire safety and health and
safety;
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ensuring that the Service’s fire safety and health and safety performance is
reviewed annually.
1.2.2
At a strategic level the Director General is responsible for ensuring the fire safety and
health and safety of all staff and others who may be affected by the Service’s undertakings.
This responsibility is delegated through the management line to Heads of Groups, Area
Managers, Governing Governors, managers and those in charge of other Prison Service
buildings.
1.2.3 This PSO sets out the actions Area Managers, Heads of Groups and Governing
Governors must take to ensure that systems are in place to effectively manage the
risk from fire to which staff, prisoners and others are exposed and to ensure
compliance with current legislation.
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1.3
Page 5
Fire Safety Policy
1.3.1
The RRO 2005 requires the responsible person to effectively plan, organise, control,
monitor and review the preventative and protective measures that are implemented to
manage the identified risks from fire.
1.3.2
The Director General’s and the Board’s commitment to ensuring the safety from fire of staff
and others who may be affected by their undertakings, together with the organisational
structure for fire safety and health and safety, is set out in the Prison Service Health and
Safety Policy Statement and Organisational Chart. A copy of the Prison Service Health and
Safety Policy Statement and Organisational Chart can be found in PSO 3801, Health and
Safety.
1.3.3
The Director General is responsible for developing the Prison Service Fire Safety Policy
and this is done through the issue of this PSO and guidance documents. However, the
complex nature of the organisation, coupled with the widespread location of establishments
and other workplaces, make it impossible for one single policy document to be uniformly
applicable. Local Policies, based on the advice given in centrally issued policies and
guidance notes and taking into account existing circumstances and risks must be
developed and implemented locally.
1.3.4
Area Managers, Heads of Groups, Governing Governors and those in charge of other
premises must have in place a local statement detailing the Fire Safety Policy of that
establishment or Prison Service building. This Policy Statement must:

include a general fire safety policy statement, which sets out the ownership and
clear commitment of senior management to the policy;
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detail how fire safety is to be planned, implemented, measured and audited,
including the allocation of individual responsibilities;

state the arrangements for monitoring performance;
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state the arrangements for carrying out the policy i.e. the systems and procedures.
1.3.5
Area Managers Heads of Groups and Governing Governors must ensure that the Fire
Safety Policy is brought to the attention of all staff. All local policy statements must be
reviewed when any significant changes take place, but at least annually. Any changes
must be brought to the attention of all staff.
Line managers at all levels are responsible for ensuring that fire prevention
measures particular to their area of control are implemented.
1.4
Headquarters and other Office Accommodation
1.4.1 In Cleland House fire risk assessment are carried out annually by consultants on behalf of
Amey, the facilities provider for Cleland and Abell House.
1.4.2 The Headquarters Health and Safety Committee will decide who will be responsible for coordinating fire safety arrangements in Cleland and Abel House and take responsibility for
ensuring that any remedial action as a result of fire risk assessments are completed.
1.4.3 In other office accommodation Area Managers or Heads of Group must ensure that fire risk
assessments are carried out by a competent person and nominate a member of staff to coordinate fire safety arrangements.
1.4.4 Where office premises are shared with another employer the responsibility for ensuring that
fire risk assessments are carried out will rest with the ‘responsible person’ who will usually
be the owner of the building. The Head of Group will be responsible for ensuring that they
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Page 6
co-operate with the responsible person and co-ordinate their activities to ensure the safety
of staff and others from the risks of fire.
1.5
Co-operation and Co-ordination
1.5.1
Where premises are shared with another employer (this includes people who are self
employed) each employer is required to co-ordinate their activities for managing the risks
from fire. Co-ordination and co-operation will include both employers:

identifying the nature of any risks from fire and how they might affect others in or
around the premises;
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taking all reasonable steps to inform each other of the risks to other employees’
health and safety arising out of their own employees work.
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co-operate with each other so as to comply with relevant legislation;
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co-ordinating the various measures that have been taken to reduce the risks from
fire including contingency planning;
1.5.2
Where premises are shared with other employers, for example, where health care or
education providers work on site, Governing Governors and Heads of Group must cooperate and co-ordinate with the employer to ensure that the fire precautions and protective
measures are effective throughout the building.
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CHAPTER 2: ORGANISATION
2.1
Health and Safety Model
2.1.1
Under PSO 3801, Health and Safety Policy Statement, Governing Governors are already
required to appoint a member of the Senior Management Team as the health and safety
sponsor, to assist the Governor in the co-ordination of all health and safety activities within
the establishment and to ensure effective implementation of the local health and safety
policy. The Health and Safety Sponsor should be trained to IOSH Managing Safely
standard and will normally have line management responsibility for the health and safety
advisor. This is the model used for health and safety across all establishments.
2.1.2
Because of the close relationship between fire safety and health and safety fire safety will
be integrated into the existing Prison Service health and safety model at establishment
level. This will be done by adding fire safety to the Health and Safety Sponsor’s role. Line
management of the fire safety advisor is a local decision. However, assigning this role to
the health and safety advisor will further integrate health and safety and fire safety and
should result in a more cohesive approach to managing some of the major risks to which
prisons are exposed.
2.1.3
If they have not already done so Governing Governors must appoint a member of the
Senior Management Team as the health and safety and fire sponsor, to assist the Governor
in the co-ordination of all health and safety and fire activities within the establishment and to
ensure effective implementation of the local health, safety and fire policies.
2.1.4 Health and Safety and Fire Sponsors must be at least functional head level and will be a
member of the Senior Management Team. Health Safety and Fire Sponsors must be
trained and qualified to IOSH Managing Safely level.
2.1.5
It is recognised that in order to carry out the role effectively sponsors will require basic fire
safety training and a one day course that meets these needs is now being developed.
Governing Governors will be advised when the course is available and will be expected to
ensure that all fire safety sponsors are trained to this standard.
2.2
Access to Competent Advice
2.2.1
Fire Safety Officer
2.2.1.1 Governing Governors must ensure they have access to competent advice on fire safety
matters through the appointment of a suitably qualified fire safety advisor.
2.2.1.2 The current training standard for fire safety advisors is the successful completion of the West
Midlands Fire Officers’ Training Course. It is recognised that because of the requirements of
the RRO additional training, particularly on conducting risk assessments is needed. A new
training course to address this shortfall in fire safety advisors training is now being developed.
Governing Governors will be advised when then course in available and will be required to
ensure that fire safety advisors are trained to this standard.
2.2.1.3 Until the new training course is available Governing Governors must ensure that fire safety
advisors are trained to the West Midlands Fire Officers’ Training Course Standard.
2.2.1.2 Where a fire safety advisor who has not attained West Midlands Fire Officers’ Training Course
Standard is appointed they must be trained to this standard within six months of their
appointment
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2.2.2
Page 8
Contingency Planning
2.2.2.1 Area Managers, Heads of Groups and Governing Governors must ensure that a sufficient
number of staff to help implement contingency plans are appointed and suitably trained.
2.3
Time for Competent Persons to Carry out the Role
2.3.1
Governing Governors must carry out an assessment of the needs of their particular
establishment to determine the time needed by the competent person to carry out the role of
fire safety officer. Where the role being fulfilled by a competent person is deemed to be a
part-time post, arrangements must be made to ensure that there is sufficient time allocated
to the role.
2.5
Consultation with Employees
2.4.1
Area Managers, Heads of Groups and Governing Governors must have arrangements in
place for consultation on fire safety issues with staff through their appointed safety
representatives and non trade union members of staff.
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CHAPTER 3: PLANNING AND IMPLEMENTING
3.1
Introduction
3.1.1
Planning is essential for the effective implementation of fire safety policies. It is concerned
with the prevention of fires, through the identification, elimination and control of hazards
and risks. Planning and implementing will include the following:

assessment of all the significant fire risks to which staff and others are exposed
whilst in the particular establishment;

operational plans to implement measures to eliminate or control the identified risks.
3.2
Risk Assessment
3.2.1
Area Managers, Governing Governors and Heads of Groups must ensure that a suitable
and sufficient assessment of the risks from fire to which staff and others may be exposed is
carried out.
3.2.2
Fire risk assessments must be carried out by a competent person.
3.2.3. The risk assessment must include people who are especially at risk, young people, parents
with babies, the elderly or infirm, prisoners and people with disabilities.
3.2.4
The assessment must include risks from any dangerous substances which could cause a
fire or explosion.
3.2.5
The risk assessment must include the risks from identified arsonists.
3.2.6
The risk assessment must identify the general fire precautions that need to be implemented
to comply with the requirements of the legislation.
3.2.7
Risks assessments may sometimes indicate that the elimination or control of the risk
requires a built solution. Where this is the case, NOMS as the Service’s landlord, will be
responsible for carrying out the building work. However, Governing Governors must ensure
that, until the required building work is completed, arrangements to reduce the risk to an
acceptable level are implemented.
3.2.8
The significant findings of the assessment must be recorded. This must include any
persons who have been identified as being especially at risk.
3.2.9
Guidance or carrying out a fire risk assessment is given in Fire Safety Guidance Note which
will be published in the near future.
3.3
Review of Fire Risk Assessments
3.3.1
Risk assessments must be reviewed: when there is reason to believe that they are no
longer valid;

following an outbreak of fire;

following the failure of precautions e.g. fire detection systems and alarm systems;

following substantial changes to furniture or fittings;

following alterations to the building, including internal layout;
if

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the prison is re-rolled;
at least annually.
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3.4
Contingency Planning
3.4.1
General
3.4.1.1 Governing Governors must develop, record and implement evacuation procedures to be
followed in the event of fire or other emergency including the nomination of a sufficient
number of competent persons to implement the arrangements.
3.4.1.2 All such procedures must take account of periods of reduced staffing levels such as at night
or at weekends.
3.4.1.3 In Cleland and Abel House the Business Continuity Unit is responsible for implementing
evacuation procedures.
3.4.1.4 In other office accommodation Area Managers and Heads of Groups must develop, record
and implement evacuation procedures to be followed in the event of fire or other
emergency including the nomination of a sufficient number of competent persons to
implement the arrangements in their area of control.
3.4.1.5 To ensure that contingency plans are fit for purpose and to ensure that staff are fully aware
of the procedures that they must follow in the case of a fire or other emergency regular fire
drills should be carried out. The effectiveness of the procedures for evacuation should be
evaluated and any shortcomings rectified.
3.4.1.6 Area Managers, Heads of Groups and Governing Governors must ensure that fire drills are
carried out and reviewed at least annually and any measures necessary to ensure that the
evacuation plans are effective are implemented.
3.4.2
Cell Fires
3.4.2.1 Governing Governors must ensure that all operational staff are aware of the local safe
systems of work to be used in the event of a cell fire.
3.4.2.2 Local safe systems of work must include an instruction to carry out a dynamic risk
assessment before entering a cell where a fire is in progress and the information from this
assessment used to make decisions on appropriate action.
3.4.2.3 Guidance on the use of SDBA including training and medical examination is given in IG
34/1996, Fire Safety: the Use of Short Duration Breathing Apparatus (SDBA) in Prisons.
3.4.2.4 A smoke hood which will replace SDBA has been developed. A tender for the production of
the hood has now been let and it is envisaged that the hood will be ready for use across the
Service by late 2008.
3.4.3
Staff and Others with Disabilities
3.4.3.1Area Managers, Heads of Groups and Governing Governors must ensure that systems are
in place for alerting staff and prisoners who may not hear alarms warning of imminent
danger.
3.4.3.2 Area Managers, Heads of Groups and Governing Governors must ensure that procedures
are in place for the safe evacuation of staff and prisoners who may, because of a disability,
be unable to exit to a place of safety unaided.
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3.4.4
Page 11
Memorandum of Understanding
3.4.4.1 Governing Governors must have in place a Memorandum of Understanding with the local
fire brigade which sets out the way in which the fire brigade and the prison will co-ordinate
their actions to ensure the health and safety of fire brigade staff, Prison Service staff,
prisoners and others in the event of a fire.
3.5
Fire Fighting Equipment
3.5.1
The type of fire fighting equipment required to effectively manage the fire risks will be
identified by the risk assessment.
3.5.2
Area Managers, Heads of Groups and Governing Governors must ensure that any fire
fighting equipment identified as part of the risk assessment is provided in their area of
control.
3.5.3
Staff who may be required to use fire fighting equipment must be trained in its safe use.
3.6
Fire Detection and Warning Systems
3.6.1 The RRO requires the responsible person to implement appropriate fire detection and alarm
systems. Implementing such systems will usually require extensive building work that
NOMS, as the Prison Service Landlord, is responsible for carrying out and may take time to
arrange.
3.6.2
NOMS are implementing fire detection and warning systems in all new builds and all major
refurbishments.
3.6.3 NOMS have also agreed with the Crown Premises Inspection Group (CPIG), via a
Memorandum of Understanding, that they will identify ten prisons each year which are at
risk because of lack of warning and detection systems. Within available resources NOMS
will implement warning and detection systems in the identified prisons.
3.6.4 Where fire detection and warning systems are already installed Heads of Group and
Governing Governors must ensure that they are adequately maintained.
3.6.5
Where detection and warning systems are not already in place or the risk assessment
indicates that the detection and warning systems are not adequate the Governing Governor
must inform the Area Manager who must bring this to the attention of Operational Property
Unit and NOMS.
3.6.6
While waiting for the long term solution to be implemented appropriate control measures to
adequately manage the risk in the short term must be implemented and maintained
3.7
Checking and Maintenance of Equipment
3.7.1
All fire detection systems, warning systems and fire fighting equipment must be subject to
regular checks and maintenance to ensure that they are available for use at all times. .
3.7.2 Area Managers, Heads of Groups and Governing Governors must ensure that all checks
and maintenance on fire detection systems, warning systems and fire fighting equipment
are carried out and that any remedial action identified is completed in a timely manner.
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3.8
Emergency Routes and Exits
3.8.1
To ensure that, in the event of danger, staff and others can evacuate the premises as
quickly and safely as possible Area Managers, Heads of Groups Governing Governors
must ensure that routes to emergency exits are as short as possible and are kept clear and
that sufficient emergency lighting is provided..
3.9
Fire Signs and Notices
3.9.1
Fire signs and notices, as required by Health and Safety (Signs and Notices) Regulations
1996 must be posted to ensure that staff and others can identify escapes routes,
emergency procedures and find fire fighting equipment. The number and type of fire safety
signs required should be identified by the risk assessment.
3.9.2
Area managers, Heads of Groups and Governing Governors must ensure that adequate
fire safety signs are posted throughout the area of control.
3.10
Fire Investigation and Reporting
3.10.1 All fires, however small, must be reported and investigated (see annex A) and any remedial
action required as a result of the investigation should be implemented to agreed
timescales.
3.10.2 Any injury to staff or prisoners as the result of a fire must be reported internally and to
HASS as required by PSI 11/2002, Accident Reporting.
3.11
Provision of Information to Staff
3.11.1 Staff must be provided with comprehensible and relevant information on:
 The significant findings from the fire risk assessment;
 The preventative and protective measures in place to reduce the risk;
 Procedures to be followed in the case of a fire;
 The identity of persons nominated with responsibility for fire safety;
 Where the workplace is shared, the risks from fire from the other employer’s
undertakings.
3.11.2 Where children under the age of 18 are employed (e.g. on work placements) the parent or
guardian of the child must be provided with information on the fire risks to which the child
will be exposed and the control measures in place to reduce the risk.
3.11.3 Where a dangerous substance, which may cause fire or explosion is used, staff and others
such as contractors, who may be affected by the risk must be provided with comprehensive
information on the substance, the nature of the risk and the measures taken to reduce the
risk.
3.11.4 Area Managers, Heads of Groups and Governing Governors must ensure that all staff are
provided with comprehensible and relevant information on the fire risks to which they are
exposed and the preventative and protective measures which are in place.
3.11.5 Area Managers, Heads of Groups and Governing Governors must ensure that, where
employees from an outside organisation are working in a prison or area of control, the
employer of those employees is also provided with comprehensible and relevant
information on the fire risks to which they may be exposed and the preventative and
protective measures which are in place.
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3.12
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Provision of Information to Prisoners
3.12.1 Governing Governors must ensure that prisoners are provided with information on the local
arrangements for dealing with fire. This will normally be done during induction training.
3.13
Training
3.13.1 Staff must be provided with adequate fire safety training;
 At the time when they are first employed i.e. induction training;
 On being transferred to an unfamiliar area or workplace.
 On the introduction of new work equipment, technology or a change to existing
equipment;
 The introduction of new systems of work or a change to the systems of work already in
use.
3.13.2 Training must:

Include adequate information on the risks, control measures and evacuation
procedures;

Be repeated periodically, where appropriate;

Be adapted to take account of any new or changed risk;

Be appropriate to the risk identified by the risk assessment;

Take place during working hours.
3.13.3 All new recruits will receive fire safety training during the POELTs course.
3.13.4 A training pack, which includes a CD, for training all staff in fire safety is being developed
and all staff must be trained to this standard.
3.13.5 Area Managers, Heads of Groups and Governing Governors must ensure that all staff
receive fire safety training at induction, on transfer (where this involves a significant change
or is to an unfamiliar workplace) or when changes that alter the hazard or risk are made.
3.13.6 Area Managers, Heads of Groups and Governing Governors must ensure that all staff
receive fire safety training regularly, but at least every three years.
3.14
Monitoring Performance
3.14.1 Area Managers, Heads of Group and Governing Governors must have procedures in place
to monitor the fire safety performance of the establishment, or other area of control.
3.14.2 The local Health and Safety Committee is responsible for ensuring the quality and frequency
of local safety inspections and for identifying remedial action which may need to be carried out
following an inspection.
3.14.3 The fire safety officer must be an ex-officio member of the Health and Safety Committee
and fire safety should be a standing item on the agenda.
3.15 Audits
3.15.1 A formal audit of the systems in place to manage fire safety is carried out every four years
at each establishment.
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3.15.2 Governing Governors must ensure that any recommendations made as a result of fire
safety audits are completed in a timely manner.
3.16
Dangerous Substances
3.16.1 The Dangerous Substances and Explosive Atmosphere Regulations (DSEAR) 2002 set out
the measures that employers must implement to ensure the health and safety of employees
and others where substances that may cause a fire or explosion are used. The RRO 2005
requires employers to carry out an assessment of the risks from dangerous substances as
described by DSEAR and put measures in place to eliminate or control risks.
3.16.2 Where a dangerous substance, which may cause a fire or explosion, is present Governing
Governors must ensure that the risks to staff or others who may be affected by the risks are
eliminated or reduced as far as is reasonably practicable.
3.16.3 As far as is reasonably practicable a dangerous substance or use of a dangerous
substance must be replaced with a substance which either eliminates or reduces the risks.
3.16.4 Where it is not reasonably practicable to eliminate the risks Governing Governors must
ensure that measures are implemented and maintained to:
 Control the risk
 Mitigate the detrimental effects of a fire.
 Ensure that arrangements are in place for the safe handling, storage and transport of
dangerous substances and waste containing dangerous substances.
3.17
Guidance
3.17.1 In the future, Fire Safety guidance documents will be issued to underpin this PSO. These
will be issued instead of PSOs or PSIs and will set out advice on the actions that Area
Managers, Heads of Groups and Governing Governors need to follow in order to ensure
compliance with the requirements of this policy and relevant legislation.
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Annex A
Procedures to take in the event of a fire.
All fires must be reported:



immediately to the local fire brigade using the 999 system
as soon as possible thereafter on the Incident Reporting System
in the case of a serious fire to the National Operations Unit.
All fires must be investigated:




where arson is suspected fires must be reported to the Police,
all fires must be investigated by establishment staff with a fully detailed report
prepared and recorded,
a record of all fires must be kept
after a reportable fire a new Fire Safety Risk Assessment must be undertaken to
identify any additional control measures which might be required.
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GUIDANCE NOTE
Annex B
Link to Performance Standard 18 – Fire Safety
Preparing evidence and information for Standard Audit Unit 18 - Fire Safety
Introduction:
Audits of Fire Safety are conducted by the Fire Safety Advisors attached to the Operations
Property Unit based in Cleland House London. Currently the Fire Safety audit examines 29
baselines against strict criteria, which are designed to test whether each establishment is
complying with both its statutory duty and Prison Service Fire Policies. The auditors are obliged to
report their findings fairly and honestly and the purpose of each audit is to identify both areas of
compliance and areas where improvements are necessary, it is not intended as a criticism of the
Fire Safety Advisor and no matter what the outcome should not be viewed as such.
In order to assist Fire Safety Advisors and their managers to prepare for and pass a Fire Safety
Audit details of what the Auditor will be looking for are shown below against each of the 29
baselines:
Auditable Baselines:
18.1
A comprehensive local fire safety policy document:
18.1.1 Has been prepared and signed by the Governor - The auditor will expect to see a hard
copy document with an introduction from the Governor, which has been signed and
dated. It is anticipated that a master copy will be maintained on the local intranet.
18.1.2 Includes a statement of intent, organisation and local arrangements - The auditor will
review the wording of the local fire policy and will expect to see a statement from the
governor that expresses a full commitment to achieving a positive fire safety culture
throughout the establishment and compliance with the Regulatory Reform Fire
Safety Order 2005 (RRO) and the requirements of relevant Prison Service
Orders/Instructions. In addition the policy should show how fire safety will be
managed throughout the establishment and by whom. The expectation is that each
aspect of fire management will be allocated to specific managers and not just to the
fire safety advisor.
18.1.3 Deals in adequate detail with all relevant statutory requirements - The auditor will expect
to see that procedures and arrangements are in place to deal with Articles 8 to 22 of
the Regulatory Reform (Fire Safety) Order 2005 as qualified in Prison Service Order
3803 (Fire Safety), Prison Service Fire Manual and Standards Audit Unit Baseline 18.
18.1.4 Is brought to the attention of all employees - The auditor will expect to see a Governors
Order or similar, notifying all staff of the existence of the Local Fire Safety Policy
encouraging them all to read it and identifying how and where it can be accessed. It
is anticipated that the policy will be accessible in a number of formats, including
hard copy on departmental notice boards and on the local intranet. The use of the
local intranet alone would only be acceptable where the establishment can
demonstrate that all staff have routine access to a computer linked to the net.
18.1.5 Is reviewed at least annually and any changes are brought to the attention of staff - The
auditor will wish to inspect records of an annual review having been undertaken and
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will also wish to see that individual assessments have been reviewed following any
fire, change of use or structural alteration. It is anticipated that details of the review
including the date undertaken and the signature of the reviewer, including any
significant findings, will be recorded.
18.2
A fire sponsor, who is a member of the Senior Management Team (SMT) is trained in
strategic fire safety and to Institution of Occupational Safety and Health (IOSH) Managing
Safely standard has been appointed - The auditor will wish to interview the Sponsor
and inspect his/her qualifications/certificates and discuss how the sponsor is
managing fire safety within the establishment. Training in Strategic Fire Safety refers
to the course of that name identified by Operations Property Unit.
18.3
A Fire Safety Advisor(s) and deputy, trained to agreed Prison Service Standards or working
towards those qualifications have been appointed in accordance with the RRO Article 18 The auditor will wish to see evidence of all fire-training courses that the fire safety
advisor and deputy have attended and any certificates achieved. Initially until the
new Fire Safety Advisor's Course becomes available, attendance at the old fire
officer's course run by West Midlands and Surrey Fire Brigades will be considered
acceptable. However once the new course is available all Fire Safety Advisors will be
expected to have passed the course within two years.
18.4
Prior to construction/alteration or change of use of premises, the establishment fire
safety advisor/health and safety advisor, is consulted. Thereafter an application is
made to the local authority building control or an approved inspector and comments
received from Crown Premises Inspection Group (CPIG) are incorporated when the
work is undertaken and a record of all such applications is kept - This baseline is
designed to ensure that locally generated alterations, additions, refurbishments or changes
of use of the buildings in the Prison do not inadvertently breach the requirements of the
Building Regulations, prejudice the means of escape or interfere with the existing fire
compartments designed to stop fire spread. Additionally it is intended to ensure that any
new or re-designed structures incorporate all the necessary fire protection measures and
include as necessary automatic fire detection systems, fire alarms, emergency lighting, fire
signage etc. The Auditor will wish to see: details and plans of any changes of use, new
builds, alterations, refurbishments etc. written records of consultation with the
establishment fire safety advisor and minutes of 420 and other local meetings. In addition
copies of applications made to building control will be reviewed as will any
recommendations received from CPIG and evidence will be required to show that any
comments received have been complied with. In addition the auditor will probably wish to
inspect the building(s) where the work has been carried out
18.5
Suitable and sufficient Fire Risk Assessments for all buildings are carried
out by a competent person and recorded - The auditor will wish to
Inspect all risk assessments to ascertain that they are suitable and sufficient
and that they have been dated, recorded and signed by the assessor.
Carry out an inspection of some of the premises to which the assessments
ensure that the reality matches what is recorded on the assessment.
Check that a copy of the assessment is available in the building to which it
refers and is readily available to staff
refer, to
The test of suitability and sufficiency will be
(1) That the assessment contains details of all hazards/risks and that these are,
recorded in the list of significant findings. These could include for example:
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Details of any inadequate means of escape such as excessive travel distances,
unprotected escape staircases, blocked escape routes etc.
Details of any fire safety measures or equipment, which have either not been provided or
are not properly maintained or managed, e.g. damaged fire doors, emergency lighting etc.
Details of any high/medium fire risk areas e.g. Cell Fires, Kitchens, Workshops, Flammable
Storage, which are inadequately fire protected or where there are no automatic fire
detection or suppression systems.
Details of any failures to carry out: Fire training, Fire Evacuation drills Fire equipment
maintenance etc.
Details of any electrical systems, which are not adequately protected by fuses, trip
switches or which are not being regularly tested by a competent person etc
The list above is not exhaustive and is supplied only as an example of the sort of issues that
should be recorded in the list of significant findings
(2) That the assessment contains details of the Control measures, which are in place to
mitigate the risks/hazards, this could include:
That a building has been equipped with automatic fire detection and suppression systems
which is tested to the relevant British/European standard
That Portable Electrical Appliance Testing is carried out on all electrical equipment
annually
That staff are trained in the use of SDBA, which is available 24 hours per day
Fire drills and staff fire training are carried out on induction and refreshed annually
As with (1) above this list is not exhaustive and only gives examples of some common control
measures
(3) That an Action Plan has been prepared and is being processed:
The action plan should identify and prioritise all the work that is necessary to properly
control any risks/hazards identified in the assessment process
The Action Plan should identify each improvement that is necessary, the person
responsible for carrying out that particular piece of work and the date by which the work
must be completed.
The Action Plan should be acknowledged and signed by the Governor or his representative
to ensure that it has the correct level of authority and will be processed to completion
The outcomes of the Risk Assessment and the Action Plan should be monitored by the
Health and Safety Committee and controlled by the Senior Management Team
18.6
Fire risk assessments are reviewed when any changes are made, but at
least annually so as to be current at all times - The Auditor will wish to see
Written evidence to prove that the required reviews have been carried out and that each
assessment itself and the central records have been signed and dated to that effect.
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Where there has been a material change to a building or its use/occupancy has changed
the Auditor will wish to see evidence that this has been reflected in the risk assessment.
Additionally where a fire has occurred in the building that the assessment has been
reviewed immediately thereafter and any improvements to the control measures, which
have been identified are in place.
18.7.1 The assessments detail the significant findings and the identified control measures The Auditor will wish to see
That the assessment shows a detailed list of all the significant findings identified during the
assessment process and a list of the control measures and other arrangements, which
have been put in place to mitigate the risks and hazards
18.7.2 The assessments identify those persons who maybe at particular risk, such as
prisoners, pregnant workers, young persons, disabled persons and lone workers The auditor will wish to see
That where prisoners are kept in locked cellular accommodation, they are identified as
being at particular risk, similarly that persons from any of the other categories shown
above are listed as appropriate, accompanied by necessary documents such as
Personal Emergency Evacuation Plans (PEEPs).
18.8 The assessment identifies any risks arising from the storage or use of
dangerous substances, which may cause fires or explosions: This baseline is designed to assess compliance with article 12 and part 4 of Schedule 1 of
the RRO. The auditor will wish to see in respect of any dangerous substance maintained in
an establishment, that every effort has been made to replace the substance in use with one
that is less hazardous
and that where this has not been
possible, suitable and sufficient control measures have been put in place to control the risk
and mitigate the effects of fire. It will be expected that written documentation will be
available to demonstrate that this process has been followed
18.9 Fire risk assessments are made available to all staff and the methodology
used to achieve this is recorded - The Auditor will wish to see
That a Governor's Order or similar has been issued notifying all staff of the existence and
location of the assessments and encouraging staff to read them. Ideally a front sheet or
similar arrangement will have been provided on the front of each assessment, which has
been signed by all members of staff who work in the area to which the assessment refers,
thereby acknowledging that they have read and are familiar with its content
In addition the auditor is likely to ask members of staff at random where the risk
assessments are located and what they say
18.10 Inspections of all areas of the establishment are carried out weekly by a
Competent fire advisor, to check that all fire escape routes are clear and fire doors and
other protective measures are not prejudiced. Records of all inspections are kept.
The intention behind this baseline is to ensure compliance with article 4 of the RRO.
The expectation is that the fire advisor will walk right round the establishment once
per week to visually check that corridors and staircases leading to fire exits are not,
blocked, partially obstructed or being used for storage and that all fire doors are in
working order and have not been wedged held or locked in the open position,
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similarly that all fire-fighting equipment is in place and is not being used to wedge
open doors or for purposes other than that for, which it is intended.
A simple recording procedure is expected to be used, which shows the date of the
inspection, who carried it out and details of any failings found. Where failings have
been identified the record should indicate what action was taken to rectify the
problem.
18.11 Actions are taken to address any deficiencies identified by the Crown
Premises Inspection Group (CPIG) and copies of action plans prepared and actions taken
are kept. - The Auditor will wish to see;
Copies of all CPIG reports issued within the last five years
Details of the action plans, which were produced by the prison to deal with any deficiencies
identified by CPIG
Evidence that the deficiencies identified have been rectified in accordance with the action
plan
Copies of any business case, which has been prepared and forwarded to Area
Manager level for dealing with deficiencies, which are outside of the budgetary
control of the establishment e.g. provision of fire detection and suppression
systems.
18.12.1 Contingency plans contain detailed instructions on procedures to be
followed in case of fire - The auditor will wish to see that the plans are up to date and
relate to the regime currently operating at the prison and will check that the
procedures listed are realistic and workable
18.12.2 Are readily available to all staff who have a defined role in the plans
The auditor will wish to see that Copies of the plans are located at places where each of
the defined persons will have access to them as required e.g. In the
Control/Communications Room, Night Orderly Officer's office, The Gate Lodge etc
18.12.3 Take account of times of reduced staffing - The auditor will wish to see
that arrangements for the night patrol have been included as a separate procedure and
that there are sufficient staff to activate and manage the procedures. Issues such as the
role of the Orderly Officer and the management of doubles keys etc. will be looked at
critically to ensure that they are feasible and take account of the unexpected e.g. the
orderly officer collapsing during an incident a similar approach will be used for other
defined roles.
18.13.1 Contingency plans include arrangements for the evacuation of all persons with
known disabilities/special needs - The Auditor will wish to see; Evidence that the needs
of persons with individual/special needs have been included in the plans in the form of
Personal Emergency Evacuation Plans and they demonstrate that details of the location of
both staff and prisoners with disabilities/special needs are recorded and that agreed
arrangements are in place for their evacuation in the event of an emergency
18.13.2 Contingency plans include the nomination and training of sufficient staff
to effect an evacuation - The auditor will wish to see that the various roles detailed in the
plans have been allocated to named staff or posts and that those persons who are
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expected to carry out those roles have been trained to carry out their duties. Inspection of
training records and evacuation drill reports will be undertaken and staff will be interviewed
and asked to describe their role in an evacuation and how they will carry out their duties.
18.14.1 Fire Evacuation drills are carried out annually from all buildings in the
Establishment - The auditor will wish to see:
Records of Evacuation drills from all buildings over a number of years.
Evidence that some evacuation drills involve the local fire brigade and test the
overall process of dealing with a fire evacuation
Evidence that where use of a particular building such as segregation
units/healthcare make a full evacuation difficult, that both desktop exercises or partial
evacuations have been used to test that procedures and plans are suitable and sufficient.
Evidence that some evacuations are undertaken during the night patrol to assess the
adequacy of the process
18.14.2 A report of the outcome of each drill is prepared and recorded and the results are
considered by the Health & Safety (H&S) Committee - The Auditor will wish to
see
Post evacuation reports stating the outcomes of each drill and identifying any problems,
which occurred or lessons learned, which need to be catered for and incorporated into the
evacuation process and copies of the H&S Committee minutes to test that reports have
been considered and where appropriate action has been recommended and taken.
18.15
Fire Evacuation drills include an effective system for accounting for all
persons - The Auditor will wish to see the systems, which are in place:
Evidence that assembly points have been identified for each building and that they are
signed in accordance with the Health & Safety, safety signs and signals regulations 1996
That fire action notices located near fire alarm call points and on notice boards clearly
indicate the assembly point to which evacuees must go
Evidence in cellular accommodation that an effective roll call system is in place, which does
not rely on a fixed board in the Wing Office or other location, which can not be taken to the
assembly point
Evidence that the roll board is kept up to date at all stages of the regime
Arrangements for accounting for staff members and visitors, when they are working within
the cellular accommodation areas, are in place. Where tally systems or visitors books are
used the auditor will wish to see that the process is effectively managed at all times
Where a system using Fire Marshals is in place the auditor will wish to check that there are
sufficient marshals to cover all floors/areas of the building and that the number of Marshals
takes account of annual leave and other absences
The auditor will also wish to see evidence that the Fire Marshals have received appropriate
initial and subsequent refresher training
18.16
Site plans showing the location and capacity of water supplies, the
location, number and type of fire fighting, fire safety and fire detection
equipment including fire signage, are prepared and maintained - The Auditor will wish
to see Plans for the whole site showing the location of Fire Hydrants and Emergency water
Supplies with details as to their capacity and in the case of hydrants the pressure and flow
of water
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Plans for each building (Locking Drawings are good for this) showing the location of Hosereels, Fire Extinguishers, Sprinkler Systems, Wet and Dry Rising Mains and any control
switches for smoke extraction or ventilation systems.
In addition details of the location of fire alarm indicator panels, call points, Automatic Fire
Detection (AFD) and emergency lighting, emergency cut off switches for gas and electric
supplies should be included.
Lastly it will be considered good practice for the plans to show the location and extent of fire
resisting construction and fire compartments within all buildings.
18.17 The location of water supplies is clearly signed and the supplies are easily
accessible by the fire service - The auditor will carry out a site inspection in
order to check that each fire hydrant has a standard black on yellow indicator plate
located such that the position of the hydrant to which it refers is clearly evident. That
each hydrant pit lid has been painted in conspicuous yellow paint so that it is readily
visible and identifiable
Emergency Water Supply tanks are similarly signed such that the location of the access is
clearly evident and visible
That no obstructions have been placed either on or near to the water supplies, which would
interfere with their immediate use by the fire brigade
18.18 All fire-fighting, fire safety equipment and fire signage is in place - The
Auditor will tour the site to ascertain that all necessary equipment is in place. An inspection
of the records will be undertaken to identify what equipment has been provided and to
check that the records match the actual provision
In addition the auditor will assess the provision and adequacy of fire doors and fire signage
for example fire action notices at each call point, 'fire door keep shut' notices on fire doors
and fire exit signage etc. will be considered
18.19.1 All fire fighting and fire safety equipment is tested and maintained in
accordance with the relevant British/European (BS/EN) Standard, Manufacturer's
instructions and statutory requirements and the results are recorded - The auditor will
inspect:
All test records in respect of: Fire alarm and detection systems, Emergency Lighting, Fire
Hydrants, Fire Extinguishers, Fire Hose-reels, fixed installations such as Sprinklers, Smoke
extract and Ventilation systems, fire door repair and maintenance etc. to check that they
are all being routinely checked and tested in accordance with Section 9 of the Prison
Service Fire Manual and relevant British Standards and that accurate records are being
maintained. N.B. The auditor will expect to see the test records kept separate from other
Planned Preventative Maintenance (PPM's).
In addition the auditor will check a number of items at random such as extinguishers, hosereels and fire doors during his site inspection to check that the test record on individual
pieces of equipment matches that shown on the central records.
18.19.2 Any necessary remedial actions identified during testing and maintenance
procedures are carried out within specified timescales -
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The auditor will wish to see evidence that where a fault has been identified during a routine
test that it is reported using the small repair system and a further job sheet is generated to
carry out necessary remedial action, within a reasonable period of time. Given that most of
the tests are directly related to life safety issues it is anticipated that repairs will be
undertaken within 7 days.
18.20.1 All staff receive fire safety training initially on appointment, or on transfer from
another establishment and attendance is recorded - This baseline is designed to test
compliance with the requirements of Article 21 of the RRO. The auditor will wish to see the
following:
Copies of the fire-training syllabus, which is being used (The syllabus should match the
training requirements set out in Section 4 of the Prison Service Fire Manual)
Evidence that all staff members receive induction training, that a programme of fire training
has been prepared and is being followed and that records of fire training delivered on
induction are maintained.
18.20.2 The training is repeated at least once in each three year period and
attendance is recorded - The auditor will wish to make sure that the programme for
delivering refresher training is realistic and achievable, and that records are readily
available to evidence that a three yearly cycle of refresher training is being delivered
In addition to the above the auditors will interview members of staff at random and ask
them when they last attended Fire Training and also ask them to describe what actions they
would take in the event of certain fire situations to test that their knowledge is current and
correct
18.21 Fire Training includes information on the risks, control measures, evacuation
procedures and gives instruction on the use of fire-fighting equipment, where
appropriate - The Auditor will wish to review the lesson plan being used for the delivery of
fire safety training and where applicable any Power-Point presentation, which is used in
order to ascertain that the risks, control measures and significant findings identified in the
risk assessments are incorporated into the training.
In addition the Auditor will wish to see any specific training that is delivered with regard to a
safe system of work for managing cell fires and in addition will wish to check that practical
training in the use of fire-fighting equipment is being delivered to unified grades and other
staff who might be called upon to deal with a fire in their area of work. Finally the lesson
plan will be expected to deal in detail with the fire contingency planning and evacuation
arrangements, which are in use by the establishment.
18.22
Fire training takes account of persons with individual/special needs and
describes the procedures that may/will be adopted to assist them in the event of fire
- This baseline requires a number of different types of evidence and the auditor will be
looking for;
Evidence that the fire-training syllabus includes specific reference to the needs of staff,
prisoners and visitors who are disabled or have special needs and the types of assistance
they may require
Evidence of any equipment specifically provided for use by or in connection with those with
disabilities or special needs and that those members of staff who are expected to use the
equipment have been trained (Equipment such as Evac-Chairs would come into this aspect
of the audit)
In addition the auditor will ask whether the establishment have any persons who are
disabled or have special needs and will wish to see that Personal Emergency Evacuation
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Plans have been prepared for both prisoners and staff, which are known and understood by
staff with a duty to assist them in the event of fire
Where possible persons with special needs will be randomly interviewed by the auditor to
establish that they are aware of arrangements, which have been put in place, should they
need assistance in the event of a fire
18.23 All staff that control or manage prisoners are made aware of the location of those
prisoners, with a known history of arson and records are kept - The auditor will wish
to see:
Lists or equivalent IT documentation both current and historical, which identifies prisoners
with a known history of arson
Evidence that the list includes prisoners with previous convictions for arson, not just those
serving a current sentence for that offence
Details of, which members of staff are notified about prisoners with a history of arson
The auditor is likely to ask the Security Department to identify through LIDS/PNC any
known arsonists and then cross-reference the findings with the list being issued.
The auditor will also interview individual staff members at random to check whether they
are aware of any arsonists on their wing or in their normal place of work
18.24
All prisoners receive fire training on induction or transfer from another
prison and records are kept - The auditor will wish to see the following:
A syllabus or equivalent setting out what information is given to prisoners.
Copies of individual prisoner’s induction training record to see that fire training has been
included and dates when the training was delivered are recorded
Evidence that the needs of ethnic minorities are catered for and that delivery of the fire
training in languages other than English is available
Evidence that the training is reinforced by notices both in cells and on notice boards
available to prisoners, which set out action prisoners must take in case of fire
In addition to the above the auditor will interview prisoners at random and ask them
whether they have received fire training and what action the prisoner should take in case
of fire.
18.25.1 All fires are reported immediately to the local fire service using the 999
3
System - The auditor will wish to see:
4
That the contingency plans or fire orders give clear instructions to a specified person for
calling the fire brigade in the event of fire both day and night
That any local arrangements with the fire brigade which allow for establishment staff to
investigate the fire before calling 999, includes a proper risk assessment and safe system
of work, such that at no time will an individual member of staff enter a building or area
from which an alarm of fire has been received on his/her own. This is particularly
important during the night patrol when staffing levels are low.
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That a fire log or similar record of all fires is maintained by control/communications and
that the Fire Officer is informed of all such fires at the earliest opportunity
18.25.2
All fires are reported on the Incident reporting system (IRS) - The requirements of
this baseline are reasonably self-explanatory, however the auditor will ask for the IRS
system to be interrogated in order to review all fire incidents and to cross reference them
with the record maintained by the fire safety advisor. In doing so a check will be made
that the Fire Service have been called on each occasion
18.25.3
In the case of serious fires they are reported to the National Operations
Unit by the duty governor - This baseline is designed to ensure that fires of real
consequence are notified to the appropriate departments. The definition of a serious fire
is not absolute, however the following are examples; (1) a fire which takes one or more
cells out of use for a period exceeding 48 hours, or (2) which disrupts the normal regime
for 24 hours or longer or (3) which extends beyond the room of origin and substantially
effects other areas - would all be considered serious in the context of this baseline. The
auditor will be reviewing fire reports and IRS reports to ascertain whether this procedure
has been followed in appropriate circumstances.
18.26.1 All fires are investigated, where arson is suspected fires are reported to
Police The auditor will wish to see :
That a system for reporting fires, which have been started deliberately, to the Police is in
place and is actively used - The auditor will review fire reports and the IRS to identify
whether this has occurred and will check that a crime reference number has been
received and recorded on the fire report.
18.26.2 All fires are investigated by establishment staff and a report detailing
all relevant information is prepared and recorded - The Auditor will wish to see that
a fire investigation report has been prepared in respect of all fires, which have occurred in
the establishment
That any recommendations to avoid recurrence detailed in the fire investigation report
have been actioned by the establishment and have been considered by the H& S
Committee
That significant trends are identified to ensure that preventative action can be
implemented
18.26.3 A record of all fires is maintained - The auditor will wish to see a simple
record showing the time, date, location and nature of each fire, which occurs in the
establishment. A long term historical record covering as many years as possible is
essential.
18.26.4 A review of the risk assessment is undertaken to identify any additional
control measures, which might be necessary - The auditor will wish to see evidence on
the Risk Assessment that this process has been followed and depending upon the nature
of the fire that additional control measures have been introduced or requested, where
necessary
18.27.1 Safe systems of work, which ensure the safety of both staff and prisoners
in the event of a cell fire are developed, recorded and implemented - This
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baseline is intended to test compliance with Articles 4 and 15 of the RRO and the auditor
will wish to see that a specific risk assessment has been carried out and fully identifies the
risks and hazards posed by a cell fire, both to the prisoner and to staff, both of whom are
relevant persons within the meaning of the RRO. Arising from the assessment it is
expected that a Safe System of Work, which mitigates and controls all the identified risks
will be developed, recorded and then implemented. Clearly the safe system of work will
need to mitigate the possible effects on staff and prisoners of smoke and other products of
combustion arising from the fire and separate assessments under the Control of
Substances Hazardous to Health (COSHH) Regulations and the Personal Protective
Equipment (PPE) Regulations are likely to be required. The original or reviewed
assessment, which showed that Respiratory Protection Equipment (RPE) was or was not
necessary, will be reviewed by the Auditor
The written safe system of work (SSOW) must clearly show how a cell fire will be dealt with
and how any likelihood of staff being exposed to heat and smoke is removed, but at the
same time still allows for the effective rescue of the prisoner from the cell.
Systems, which only cater for extracting the prisoner from the cell when he/she is compliant
and will walk out when invited, will not be considered as adequate. The SSOW must cater
for non-compliant and unconscious prisoners
Where the SSOW relies upon the attendance of the Fire Brigade to rescue a prisoner from
a cell fire, the establishment must demonstrate that the brigade, equipped with Breathing
Apparatus, can get to the cell door within 5 minutes from the time when the fire was first
discovered not from when the original 999 call is sent.
Any assessment where the Brigade are being relied upon to carry out the rescue of a
prisoner from a cell fire, must make provision for the non availability of the brigade because
of their attendance at another incident or other reason such as routine fire work in the area
they cover.
18.27.2 Unified grades are given information, instruction and training about how
to use the safe
system of work (SSOW) - The Auditor will wish to see that both theoretical and
practical training linked directly to the SSOW described in 18.27.1 is contained in the
Fire Training Lesson Plan delivered by the Fire Safety Advisor and that the training
records show that all unified grades have attended the training. It is anticipated that
the training will cover aspects such as cell inundation procedures, cell entry
procedures, cell search and rescue procedures and fire-fighting techniques.
18.28.1 Where an assessment for the need for Respiratory Protective Equipment (RPE)
shows that it is required, suitable equipment is introduced and Staff are trained in its
use and the training is recorded - This baseline reflects the possible findings from the
assessment carried out under 18.27.1 that RPE is required. Where this is the case until
smoke hoods become available, compliance with IG34/96 and the Prison Fire Manual
section 10, will be expected and the Auditor will wish to see:
where SDBA/RPE is in use:




18.28.2
A member of staff has been trained as an SDBA/RPE trainer
Staff trained as SDBA/RPE wearers have been subject to a medical examination or
fitness standard test and the result has been recorded
The outcome of initial staff training is recorded
Staff continuation training is completed and the outcome recorded
Staff who are required to use RPE have regular medical examinations - The Auditor
will wish to see a certificate or other confirmation from a doctor confirming that each of the
Issue No. 277
Additional Annex - issue date 28/03/08
PSO 3803
Page 12
RPE wearers had satisfactory functioning of their; Respiratory - Cardiovascular and
Musculoskeletal Systems prior to undertaking initial training in the use of RPE
Records of further medical examinations must be kept in respect of those RPE wearers who
have reached the age of 40 and thereafter at 5 yearly intervals until age 50 and then bi-annually
until age 55.
18.28.3 All RPE equipment is adequately maintained in accordance with
statutory requirements and Prison Service Instructions - The Auditor will
wish to see:
Detailed records of all maintenance and testing procedures to ascertain whether they are
sufficiently detailed and accurate to meet the requirements of the Personal Protective
Equipment Regulations, The Pressurised Vessels Regulations and as appropriate the
Management of Health and Safety at Work Regulations. In addition to checking the records
the auditor may physically inspect a number of RPE sets to check that all use and
maintenance of the equipment has been recorded in the log book
18.29.1
Local fire services are invited to visit at least once in every 12 months and
records of those visits are kept - The auditor will wish to see
Records of all fire brigade visits to the establishment over a lengthy period
Evidence that where more than one local fire station sends a fire engine on the first
attendance, that all such stations are invited to visit.
Evidence that where the stations that attend the establishment are crewed by whole-time
fire fighters that each of the four watches attends on an annual basis
Evidence that more senior fire officers who might take charge of a more serious incident
are invited to attend periodically to familiarise themselves with the agreed procedures
particularly in respect of Silver Command arrangements
18.29.2
A memorandum of understanding (MOU) setting out agreed procedures in the event
of fire is prepared, signed and exchanged with the local fire service The Auditor will wish to see that a written agreement (MOU) signed by the Prison Governor
and the Senior Fire Service Officer for the area has been produced, setting out in clear
detail the agreed roles, actions and procedures that will be followed by staff from both
organisations in the event of a fire/evacuation. It is impossible to go into specific detail in a
guidance note of this type, but a model MOU has been produced by HMP Highdown, which
can be used by other establishments as a guide in preparing their own MOU.
Issue No. 277
Additional Annex - issue date 28/03/08
PSO 3803
Page 1
Number
Prison Service Instruction
13/2009
AMENDMENT TO PSO 3803 - Fire Safety Policy Statement (CSRE)
PSO 3803 – Fire Safety-Introduction of Cell Snatch Rescue Equipment
(CSRE) and Annex A
Implementation Date
1 October 2009
30 September 2010
CONTAINS MANDATORY INSTRUCTIONS
For Action
DOMS, Governing governors.
Monitored by
SAU & self audit
For Information
On authority of
All Prison Service Staff
NOMS Agency Management Board
Contact Point
Further advice about this PSI is available from Les James on 020 7217 1803
Other Processes Affected
None
NOTES
The expiry date only refers to this PSI. Amended contents of PSO 3803 will remain in force until
revised or removed.
Issued 01/07/09
PSI 13/2009
Page 1
Amendment to PSO 3803 – Fire Safety Policy Statement
5
1)
Purpose
The purpose of this instruction is to set out the arrangements for the introduction and
ongoing use of Cell Snatch Rescue Equipment (CSRE) across the Prison Estate.
Mandatory actions
2)
The arrangements introduced by this Instruction must be attached to PSO 3803 Fire
Safety Policy Statement as an addendum.
3)
All establishments which have closed cellular or cubicle accommodation (for not more
than 4 persons) fitted with inundation points must have sufficient sets of this
equipment issued and available and must ensure that sufficient staff are trained in its
use to enable any cell fire to be effectively dealt with by staff wearing CSRE at any
time, both day and night.
4)
CSRE must be issued and available at all establishments which meet the criteria
shown in 3 above and all wearers must receive both initial and refresher training at
the frequencies described in this Instruction.
5)
Authority not to use CSRE at any establishment may only be given by the DOM, Area
Manager or Director of High Security Prisons as appropriate.
Purpose of the Equipment
6)
CSRE will replace the existing Short Duration Breathing Apparatus, but will be used for the
same purpose by prison staff, as part of the immediate action needed to save life during a
cell fire. It will provide staff with up to 15 minutes respiratory protection from smoke and
toxic fumes. It is intended for this limited purpose only and must not be used for general fire
fighting duties or for escorting fire service staff.
Use of the Equipment
7)
For safety reasons the use of CSRE is limited to incidents in cells or small cubicles
designed for not more than 4 persons, which are fitted with inundation points. Use of CSRE
in larger areas would be dangerous in that staff might become disorientated. and the
equipment is only intended for rescues that would take less than 10 minutes.
8)
Where establishments have closed corridor design access to cells not fitted with
mechanical smoke extraction systems, the corridors may become smoke-logged.
Movement along such corridors wearing CSRE may substantially reduce the effective
working time for the equipment.
9)
Other than in exceptional circumstances where a prisoner is in imminent danger the
equipment should only be used by two trained staff overseen by the Orderly Officer (or
equivalent).
10)
Where only one trained wearer is available and a prisoner is in immediate danger, the
Orderly Officer (or equivalent) may, only if s/he is at the scene, make a decision to
permit the equipment to be used by a single trained wearer to unlock and release the
prisoner from the cell, but not to enter the cell alone.
Order ref. 3803
Issue date 01/07/09
PSI 13/2009
11)
Page 2
Single wearers should not enter a cell alone.
Restrictions on Users
12)
It is a requirement of the Health and Safety at Work Act 1974 that all employees assist the
employer to comply with his/her statutory duty. Consequently all staff will be required to
wear CSRE unless they have a known medical condition which precludes this.
13)
Relevant conditions may include:





14)
Cardiac Conditions
Chronic Respiratory Conditions (e.g. Asthma, Bronchitis)
Claustrophobia
Musculoskeletal Conditions (e.g. joint and back problems) which would preclude
handling heavy weights
Pregnancy
CSRE is not designed to accommodate the wearing of spectacles.
Anyone whose vision is substantially impaired without the use of their spectacles, such as
to
prevent them from undertaking Cell Rescue procedures, should not wear CSRE.
Staff who wear spectacles should attempt the training, so that instructors can assess whether
their
vision, without the use of spectacles, is adequate to permit the safe use of CSRE.
Staff with beards must not use CSRE because the beard may interfere with the airtight seal
inside the ori-nasal mask, compromising the safety of the equipment.
Medical Examinations
15)
It is considered that all staff other than those with any of the relevant conditions referred to
above, should be sufficiently fit to use CSRE, therefore under normal circumstances staff
will not require a medical examination in order to use CSRE.
16)
Where staff have relevant conditions which might preclude their use of CSRE, Governing
Governors may arrange a medical examination by an Occupational Health Advisor in order
to assess whether the particular member of staff is fit enough or otherwise to wear CSRE
Role and Duties of the Orderly Officer (or equivalent)
17)
The Orderly Officer (or equivalent) must:

have received training as a wearer without donning CSRE to carry out the following
duties on control and safety procedures:

Communicate all information to a central point (Communications Room or ECR)

Ensure that the team normally consists of two trained wearers

In an emergency where the life of a prisoner is in imminent danger and only one
trained wearer is available ensure a dynamic risk assessment is undertaken before
any attempt to rescue the prisoner is attempted

Record the time that the CSRE is donned and the time that the wearers are
subsequently safely clear of the risk area
Order ref. 3803
Issue date 01/07/09
PSI 13/2009

Page 3
Instigate an emergency team (whenever practicable) to enter the risk area should
the first team get into difficulties or have been in the risk area for longer than 15
minutes
Training
18)
Sufficient time to carry out Initial and Refresher training in the use of CSRE will be
necessary to ensure safe use of the equipment. For safety reasons staff must not use the
equipment unless their training has been kept up to date.
19)
In determining the number of staff to be trained Governors must take into account local
contingency plans, in which an assessment should have been made of the number of
trained staff who must be immediately available at all times.
20)
Before bringing CSRE into use, Governors must ensure that a full risk assessment is
carried out at their establishment and that clear, concise Operational Instructions are
issued for the use of the equipment. Contingency Plans should be reviewed and updated
accordingly.
21)
Training of fire officers as CSRE Instructors will be undertaken prior to the issue of the
CSRE to individual establishments. It will be for governors to arrange the training of
sufficient staff to meet the requirement for CSRE to be immediately available at all times.
CSRE Issue, Maintenance, Servicing and Replacement
22)
The initial provision of CSRE to establishments will be undertaken by Central Stores at
Branston. The costs will be met from central funds.
23)
Secure storage cabinets will be available to establishments from Branston Stores at a cost
of XXXX per cabinet. It will be the responsibility of establishments to fit the storage
cabinets at appropriate locations using their own resources.
24)
CSRE does not require regular maintenance at establishment level; the only requirement
will be a visual inspection once per month by the fire advisor or any other member of staff
delegated for the purpose.
25)
After Six years, the CSRE will undergo a life validation inspection and test which will be
undertaken by the manufacturer.
26)
After use at an incident CSRE sets must be returned to the Manufacturer for recharging
and re-sealing via Central Stores at Branston, who will provide replacements.
27)
The cost of recharging used sets will be borne by establishments at (circa 2009) £170.00
per set.
28)
Establishments wishing to purchase additional sets above and beyond the level of the
initial issue will be able to do so via IPROC at a rate of (circa 2009) £730 per set.
Order ref. 3803
Issue date 01/07/09
PSI 13/2009
Page 4
Advice and Information
Contact Fire Safety Team in Asset Management.
0207 217 1803
(signed)
Michael Spurr
Chief Operating Officer
Order ref. 3803
Issue date 01/07/09