bob2813

@AnthonyB Thank you, that all makes sense now, I will go back to my Competent Person and ask him where he is getting his information from.

Was it ? umm, thats helpful to know, my Competent Person is saying I could do the test, so their is no financial incentive for him, and we have worked together for years and I trust him not to rip me off, although I am aware - wool and eyes - can happen. This thread states that BS5266: 1999 had it, but it was removed in 2005, not 2016, bit not that is matters, important point is that is was removed. It reads "Six monthly test of self contained and central battery systems by simulation of a failure of the normal lighting supply, for a continuous period of one hour. During the test check all luminaries for proper function." https://forum.iosh.co.uk/posts/t85842-Emergency-Lighting---6-Monthly-Test Why was it removed ????

Thank you for that extract. My Lacors Guidance (which I believe is current), s32.8 references BS 5266-8: 2004 (BS EN 50172: 2004) Emergency Escape Lighting Systems, however I understand that is the guidance I should follow, unless an amendment is made and published for the Lacors Guidance to cover updated documents. So I see no 6 month 1 hour test mentioned. I am currently following the Lacors/BS5266 maintenance guidance, so can't see and of my procedures are missing anything. I will have to go back and ask my competent person where he is getting his information from. What he is suggesting makes sense - the extra test can't be a bad thing, but unless its guidance I should legally follow, then it shouldn't apply, and neither should I follow it, do I interpret the situation correctly.

Question is - before I challenge his competence, is he correct, I cannot find any reference online to such an update. I am not sure if HMOs are his main line of business, and in the past have had sightly conflicting information from him on very minor issues, which has had to be fact checked. As as an aside, should my engineer be expected to folllow the 'letter of the law', he's competent, but not a Barrister in the Law.

I have always followed Lacors (2013 I believe this is the last revision/amend). I have an HMO, with non maintained Emergency Lighting, mains supplied, with back up battery. It states: monthly periodic flick tests performed and Logged by the manager or fire contact, with annual periodic tests certified by a competent person. The competent person has contacted me to say he has an update to guidance that states: every six months a 1 hour test to be performed by manager/fire contact (in addition to above tests). I will ask him how he has been informed of this update, and should it superseed the Lacors Guidance. Thanks.

Thank you for bringing that to my attention. I have professional indemnity insurance, including Public Liability, Negligence and Civil Liability, so providing I have complied with the Law those perils should be covered., and a call just now to my insurer confirms this. I can't see Insurers requiring anything above what the Law requires. So my orginal question - does certification and maintenance still need to be carried out ? if not required by Law.

I have 2x flats with self contained non maintained Emergency Bulkheads. My electrician has provided Emergency Lighting Completion Certificates for both flats ('For Small New Installations'). The GF flat has 2 lights in the one corridor, which opens into a small lobby, then onto the street, the FF and Loft flat has 3 lights covering stairs and landings, again opening out into the common lobby. 2x very small installations. A separate Fire Risk Assessement has been carried out. When handed the certificate (a 2 page document), page 2 the 'Compliance Checklist' was left blank. At the time no 'system plans' were available, nor any photometric data. I have queried this blank page 2, and the lack of information missing with the Electrician,who has stated he has enough experience to judge the system as compliant as it is, no further form filling or information required. He stated 'I have the Certificate' In addition on Page 1 it states: This Certificate is only valid when accompanied by current: a) Signed declaration. b) Photometric design data. This can be in any of the following formats but in all cases appropriate de-rating factors must be used and identified to meet worst case requirements. - Authenticated spacing data such as ICEL 1001 registered tables. - Calculations as detailed in BS 5266-1:2016, Annex D, and CIBSE/SLL Guide LG12. - Appropriate computer print-out of results. c) Test log book. So a legal document, that to be 'Valid' requires certain information to be present, after speaking to other competent installers it seems common practice to not provide Photometric Data ... where the install is deemed minor, and despite the Cert having the words 'small new installations' in the title. If the day ever came and a court required to see the Cert, what would I as RP reply when the court questioned the lack of Photometric Data, and a blank Page 2. Any thoughts appreciated.

Thank you. Yes I have read that Part of the Regulatory Reform (Fire Order), but my reading of it is that maintenance is only required where the equipment is provided for by Law, my FRA assessment has written that it is not required, and the assessor considers the borrowed light to be sufficient. If I put an Emergency Bulkhead in my bedroom for fun (or infact in an understairs cupboard - to illuminate the Consumer Unit,in case of a power outage as I have done), or in an Escape route at my behest - (ie not required to be fitted by any Law) - then Section 17 cannot apply ?? If by Law it is not required, then the only sort of commissioning certification that would be required would be covered under BS7671 certificates. In my mind it just doesn't seem clear that Fire Regulation Laws apply to these particular lights, yes they maybe covered by other Laws, ie Electrical Installation ... but that certification is covered.

Thank you for the reply. when needed The FRA has written that it is not needed, ie no requirement. I'd agree it isn't required (although doesn't do any harm) If there was no Emergency Lighting, the FRA has assessed that in the event of a Fire everyone can get out of the building Safely, having it installed is simply extra to requirements, so the lack of it would not be an infringment of those requirements. Can any one point me to where its states - that even if not required by law, where emergency lighting has been installed, over and above what is legally required, it still needs to be certified (commissioning and periodic certificates). Thank you for clarifying the differences between the Certificates.

Hi, What is the position for the RP, where a qualified FRA states their is no requirement for Em. Lighting (conventional/borrowed light adequate), but the RP has still gone ahead and fitted them. Lacors also states no requirement. 2x 3 bed HMOs less than 2 storeys each. Does the RP still need a competent person to provide commissioning certificates, and then ongoing annual test certificates (a periodic inspection and test cert. has though been provided). The Em. lights have been tested under BS7671 certificates. What are the differences between a Emergency Lighting Completion Certificate and a Periodic Inspection and Test Certificate. Thanks

Wedging of Fire Doors Can someone kindly point me to the actual legislation wording that defines this as Illegal in an *** please. (note this is not a licenced ***, but one that falls under The Houses In Multiple Occupation Regulations 2015) Someone has suggested it is in 14 and 15 of the RRO, but I cannot see it there. Thanks

Thanks for the reply. I would only use the principals and devise my own system I would be interested to know what you would replace the PPE with for a FRA for a rental property, FFE ?? for example.

Learning how risk assessments get produced, I see the Hierarchy of Control is a key element, this wikipedia article's diagram: https://en.wikipedia.org/wiki/Hierarchy_of_hazard_controls has PPE at the bottom of the diagram ... this is obviously aimed more at the work place, than a rental property such as an HMO. Is this diagram then relevant, could you swap out PPE and put in something more relevant for the type of premises being Assessed, would a hotels Assessment use such controls - what they swap out thr PPE for. Thanks.

Thank you for your reply. I drew up a test record sheet, each device's test 'event' recorded, with any comments included. I vacuumed all the Smoke Detector heads. I gave the whole system a visual check. There have been no changes to the system since the last check. There have been no false alarms since last system check. (completed log book present and correct) I tested all the call points, Smoke Detectors were tested with a Smoke Saber (used as per instructions), the Rate of Rise heat detector in the kitchen was tested with a hair dryer (my qualified electrician has previously used the same - I researched the efficacy of this method, knowing such devices as the Solo Detectors tester is made for the job, but understand a hair dryer is acceptable to test the detector). The previous Test certificates has a number of sections (12-16), which I printed a copy of and checked the system, against the 67 questions its asks. I have observed the actions of my Electrician on several previous tests, and feel competent enough - the system test was no different to what he performed - but most importantly he feels me to be competent, and to work under his supervision, as he does with other aspects of his skills. I have worked under his instruction for a good few years. I have video evidence as a diary of the test, with completed test forms. I do not have any qualifications, would a court expect to see those ?

I own a Licenced small HMO (3-6 persons), currently let to 4 persons. It has a Grade A LD2 alarm system, that is tested weekly, with 6 monthly test certificates attained from my NICEIC registered Electrician, holding the required experience and 5839 competencies, he also installed the system back in 2017. The system has had FRA's by an accredited company. As an aside - over the years my electrician has permitted me to perform 7671 1st fix tasks on a number of my own developments, that he has then subsequently completed the remaining work (CU and final connections) and then certified, judging me to be skilled enough to do the work to the required standard. During the last 6x Alarm System bi annual 6 month tests I have been onsite to witness and assist my electrician perform the test under his supervision. Due to Covid he was not able to attend the latest test (he is stuck abroad). It was however agreed between us that he felt on this occassion - I was experienced and skilled enough to run the test myself without him present, despite my understanding that the test needs to be completed by a suitably competent person, which it could be argued I am not (I am not registered or formaly trained by a suitable body) - my electricain though felt more than happy, and trusting of me to do this, and when complete would supply the test certificate, I would also test the Emergency Lighting which also required a certificate. I actually wanted him to witness it Live via Zoom, so there would be evidence of him witnessing the test. When I suggest that, he said there was absolutely no need as he trusted me completely to do the task. I then suggested that I would at least like him to witness a recording of it. I went off and understood a bit of a 5839 test, and that of the Lighting test. The test was performed and recorded, with this being sent digitally to my Electrician to review, along with a completed check list and my notes. Unfortunately - it appears that depsite several requests for him to review the evidence, he has not done so (ie not downloaded the files). Our relationship is professional, not that of friends, so feel reluctant to push him to download it, after all he is the competent one - and so has the last say - he trusts me and judges me to be skilled enough. He has now provided the test certificates, with his position noted as 'Qualified Supervisor'. Should I take it that he is satisfied, and my insisting on him reviewing the evidence is just being over pedantic.