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What is a construction phase fire plan, and who has to write one?

A construction phase fire plan is the written set of arrangements for fire on a site while it is a site: how the alarm is raised, where people go, where the extinguishers are, who may issue a hot works permit, where the skips and the gas cylinders live, and who the fire and rescue service should ring. The fire risk assessment says what could burn and who is at risk; the plan says what the site does about it.

The principal contractor writes it, usually the site manager or the person they name as site fire safety coordinator, before set-up and again at every stage where the building changes. The designer's fire strategy feeds it and the occupier of a live building contributes to it; neither of them writes it.

Where the duty comes from

The Regulatory Reform (Fire Safety) Order 2005 applies to a construction site as a workplace, in England and Wales. Every employer on the site is a responsible person for its own people (article 3(a)); the principal contractor carries the same duties as the person in control of the premises (article 5(3)), and the Order makes them co-operate (article 22). In practice the principal contractor writes the assessment and the plan and the others work to it. Article 9 requires a suitable and sufficient fire risk assessment, with the significant findings recorded — the findings, and the measures taken or to be taken (article 9(7)); article 11 requires arrangements for those measures. Scotland and Northern Ireland have their own fire safety law of the same shape.

CDM 2015 puts four specific duties on every contractor in control of the work, the principal contractor first among them, who coordinates the rest. Regulation 29 requires steps to prevent the risk of injury from fire; regulation 30 requires emergency procedures that are prepared, made known and tested; regulation 31 requires emergency routes and exits kept clear, signed and lit; regulation 32 requires fire detection and fire-fighting equipment suited to the site. HSG168 is HSE's guidance on meeting them, and the construction phase plan under regulation 12 has to set out the arrangements. The fire plan is that plan's fire section written out in full.

The Joint Code of Practice on fire prevention on construction sites is not law. It is the insurers' code, and on most contracts of any size the policy or the contract makes compliance with it a condition of cover. Where it applies, it requires a written site fire safety plan, a named person responsible for fire, a permit system for hot works with a fire watch afterwards, and controls on temporary accommodation, waste, security and timber frame. A site with no plan on a Joint Code contract has a problem with the insurer before it has one with the regulator, which is the honest reason most sites have one.

What goes in it

The people: the coordinator, a deputy, the fire marshals and their areas, the occupier's responsible person, the fire service contact. Detection and alarm: what it is, where the call points are, when it is tested, what happens when detection in a live building is isolated. Escape and muster: the routes at this stage marked on a drawing, the muster point, who calls the roll and from which sheet. The fire points and the weekly check that keeps them there. Hot works: who issues permits, who keeps the register, the latest finish before the end of the shift and the fire watch period, written in from the current edition of the Joint Code or the insurer's letter. Combustibles, flammables and waste, with the separation distances and quantity limits from the same sources. Then the cabins, the timber frame, security and arson, each with a checklist behind it, and the fire and rescue service: appliance access, water, the information kept at the gate.

The two mistakes

The first is the plan that describes any site: copied from the last job, with the muster point in the wrong car park and a stair not yet built. The second is the plan that was right at set-up and never touched: the frame went up, the routes moved, and the plan still shows week one. Review it at every stage change, after every activation and whenever the assessment changes, and record the review even when nothing changed.

What a template does not do

A template gives the plan its headings, the questions a coordinator has to answer, and the cross-references to the permits and records behind each answer. It does not know your building, your insurer's conditions or the distance your timber frame designer requires, and it prints none of those as a figure. A competent person writes the plan for the site and keeps it current; no document makes anyone compliant. Why we will never call a document "compliant".

Documents for this work