Safety vs Security

[SheannJam]

I would welcome views on the following scenario as I’ve had differing opinions.

Context: A small school type provision for approximately twenty 14-16 year old challenging teenagers involved in gang related crime, high rates of absconding due to exploitation and many involved in the criminal justice system. 

The building is single story approx 200 m2 with large opening windows in all rooms. All occupants are able bodied. There is 1 fire exit door in an area at the south end of the building leading onto a yard area. This area is closely monitored. This fire exit can be accessed freely by anyone. However as it is in a supervised area it couldn’t be used without staff knowledge.

At the north end of the building is a door off the corridor immediately outside two classrooms leading to a staff area and another door leading outside. for safety and security they have coded locks on this first door leading into the staff area that in the event of a fire would be opened by staff. When students are in these areas staff are always either with them or present in the adjacent classrooms and available to open these doors if needed. This is detailed on the risk assessment and staff are trained on fire evacuation procedures. As stated staff use the door code multiple times a day and the same code is also used for staff entrance and exit doors. The reasoning for the keyless coded door locks is that there is a high risk of pupils either absconding or opening a door to allow an unauthorised person into the building. There are sometimes gang related disputes outside the school that spill inside which would pose a risk to everyone inside. The school did consider some kind of alert should the door be opened but as staff use it constantly it wouldn’t provide a workable solution. The risk of fire is low - there is no source of ignition or fuel in these areas (bins and storage of recycling were removed as a result of the risk assessment) and no increased source of oxygen. Although not continuously monitored as stated staff are always very close by during the school day and the area is regularly patrolled and so the opportunity for time for a fire to take hold is limited. The risk assessment has deemed that the risk of a child coming to harm from absconding or allowing access to the building to unknown people wishing to do harm to another pupil is greater than the risk of fire. The fire reform act says fire escapes need to be opened by anyone needing to use them. Does this mean each person needs to be able to personally open them or is it enough that someone is guaranteed to be able to open it for them? Is there a particular piece of legislation that details this? 

I’m assuming similar scenarios could be in centres for adults with learning difficulties, dementia, etc

[Messyshaw]

Hi Sheannjam.

You are right, this is not a rare situation in that there is a balance to be made between the personal safety of the individuals (especially vulnerable persons such as children) under the care of the management, versus the fire safety obligations of the Fire Safety Order.

The usual methods of ensuring everyone can self evacuate is not always possible in a range of care and other settings. I have worked extensively in mental health (including forensic and elderly mentally ill establishments) and have had input in youth custody, prison establishments and other secure HMG premises. These premises of course cannot use the usual 'push' bar type free to all means of escape.

It is worth examining the part of your post where you discuss the legislation. It may help if I paste Article 14 of the Regulatory Reform (Fire Safety) Order 2005 here (I have added the format changes):

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Emergency routes and exits

14.—(1) Where necessary in order to safeguard the safety of relevant persons, the responsible person must ensure that routes to emergency exits from premises and the exits themselves are kept clear at all times.

(2) The following requirements must be complied with in respect of premises where necessary (whether due to the features of the premises, the activity carried on there, any hazard present or any other relevant circumstances) in order to safeguard the safety of relevant persons—

(a)emergency routes and exits must lead as directly as possible to a place of safety;

(b)in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible;

(c)the number, distribution and dimensions of emergency routes and exits must be adequate having regard to the use, equipment and dimensions of the premises and the maximum number of persons who may be present there at any one time;

(d)emergency doors must open in the direction of escape;

(e)sliding or revolving doors must not be used for exits specifically intended as emergency exits;

(f)emergency doors must not be so locked or fastened that they cannot be easily and immediately opened by any person who may require to use them in an emergency;

(g)emergency routes and exits must be indicated by signs; and

(h)emergency routes and exits requiring illumination must be provided with emergency lighting of adequate intensity in the case of failure of their normal lighting.

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You can see that Article 14(2) (b) and (f) clearly state that persons must be able to escape as quickly as possible and more importantly in this example, its is not possible to lock doors in a manner that stops people using them in a emergency

However, its vital to read Article 14(2) carefully, as despite it saying you MUST comply with the list of requirements below, it also states WHERE NECESSARY. That 'where necessary' part is where the risk assessment part comes in. This part of the article allows some flexibility. However, where your risk assessment requires you to take an alternative path to the a to h list above, it is usually necessary for additional mitigating measures to be made.

If I was auditing the premises you describe, I would be looking for how you justify the coded locks. Firstly are they mechanical or electrical. If mechanical, is there a system of formal checks or maintenance to ensure the mechanisms work correctly and are not subject to wear. If electrical, additional and more frequent checks on the battery condition and whether its possible to fit an override - perhaps used by a swipe card etc. Is it not possible for staff to carry keys? key type locks are generally more reliable that coded locks

You mention staff training. I would be looking at induction training - especially instruction to temporary/supply staff. How do you ensure maintenance contractors can escape? (Are they escorted or are they given the code?). What is the system for informing staff when the code is changed (I assume for security reasons, this happens periodically? ), I would also expect numerous fire drills in a 12 month period to take into account the risks presented.

I would be looking at what sort of fire alarm is installed - if any. In particular,  manual call points are usually fitted in where people will leave the building. Is there a need to provide one at the locked staff door so if a student finds themselves here and no staff is available, the student can raise the alarm? I know you say staff will be available, but in reality, they may be dealing with the fire or other situation that has lead to the fire.  

Lastly despite the low fire loading you refer to, is there a heightened arson risk the taking into account the profile of the students? Have measures been taken to protect the means of escape? Closing the letterbox in the door? Fire detection, location of extinguishers etc? Of course, none of these arson measures may be necessary, its just a thought process I am going through

In summary, it is possible for 'staff opening' type fire exits to be in place under the Fire Safety Order, but mitigations will almost certainly be required especially in an education/special needs setting. Where children are involved, mitigating measures  MUST be robust and resilient (so they work on 101% of occasions), communicated to the necessary staff and formally recorded.  I would definitely consider more than one fire drill per annum (even if there is an attached school that has a different frequency of drills) and new/supply/temporary staff should be inducted in fire safety before they start work.

Good luck!

Obviously, my advice is generic in nature and is given in response to the information provided by the OP. Its is not intended to be a full and complete list of measures to be undertaken at this high risk premises and a full FRA should be maintained and acted upon