Small Construction Sites

Fire can break out on most construction sites. There are around 11 construction fires every day. As you read this publication there is probably a fire on a construction site. Not only can people be killed or injured, but fires can also be financially devastating to those involved.

This page sets out some basic measures for construction fire safety and is aimed mainly at those managing and working on smaller sites where risks are relatively low (but it should not be assumed that risks are low merely because a site is small). More detailed guidance is also available aimed at higher risk sites and there is much in it that is relevant for any construction site. Its reference is given at the end of this information sheet.

Legal requirements

The Construction (Design and Management) Regulations 2007 (CDM 2007) came into force in Great Britain on 6 April 2007, and is divided into 5 parts:

  • Part 1 deals with the application of the Regulations and definitions.
  • Part 2 covers general duties that apply to all construction projects.
  • Part 3 contains additional duties that only apply to notifiable construction projects, i.e. those lasting more that 30 days or involving more than 500 person days of construction work.
  • Part 4 contains practical requirements that apply to all construction sites.
  • Part 5 contains the transitional arrangements and revocations.

Background to the new Regulations

Construction remains a disproportionately dangerous industry where improvements in health and safety are urgently needed. The improvements require significant and permanent changes in dutyholder attitudes and behaviour. Since the original CDM Regulations were introduced in 1994, concerns were raised that their complexity and the bureaucratic approach of many duty holders frustrated the Regulations underlying health and safety objectives. These views were supported by an industry-wide consultation in 2002 which resulted in the decision to revise the Regulations.

The new Regulations revise and bring together the CDM Regulations 1994 and the Construction (Health Safety and Welfare) Regulations 1996 into a single regulatory package.

The new regulations require measures both to prevent fires happening and to make sure all people on construction sites (including visitors) are protected if they do occur. The relevant fire safety sections are 38 to 41 inclusive which are,

Regulation 46 Enforcement in respect of fire

(1) Subject to paragraphs (2) and (3)

  • (a) in England and Wales the enforcing authority within the meaning of article 25 of the Regulatory Reform (Fire Safety) Order 2005(a); or
  • (b) in Scotland the enforcing authority within the meaning of section 61 of the Fire (Scotland) Act 2005(b)

shall be the enforcing authority in respect of a construction site which is contained within, or forms part of, premises which are occupied by persons other than those carrying out the construction work or any activity arising from such work as regards regulations 39 and 40, in so far as those regulations relate to fire, and regulation 41.

(2) In England and Wales paragraph (1) only applies in respect of premises to which the Regulatory Reform (Fire Safety) Order 2005 applies.

(3) In Scotland paragraph (1) only applies in respect of premises to which Part 3 of the Fire Scotland) Act 2005 applies(c).

Note. In an existing non domestic premises in which the The Regulatory Reform (Fire Safety) Order 2005 (RR(FS)O) or Fire (Scotland) Act 2005 applies and is undergoing contruction work the Order or Act is enforced by the Fire and Rescue Service (FRS).The Fire and Rescue Service is also the enforcing authority for sections 38 to 41 of the CDM 2007.

In a new build sections 38 to 41 of the CDM 2007 is enforced by the HSE.

Regulation 38. Prevention of risk from fire etc

(1) Suitable and sufficient steps shall be taken to prevent, so far as is reasonably practicable, the risk of injury to any person during the carrying out of construction work arising from

  • fire or explosion;
  • flooding; or
  • any substance liable to cause asphyxiation.

Regulation 39.Emergency procedures

(1) Where necessary in the interests of the health and safety of any person on a
construction site, there shall be prepared and, where necessary, implemented suitable and
sufficient arrangements for dealing with any foreseeable emergency, which arrangements shall
include procedures for any necessary evacuation of the site or any part thereof.

(2) In making arrangements under paragraph (1), account shall be taken of,

  • the type of work for which the construction site is being used;
  • the characteristics and size of the construction site and the number and location of places
    of work on that site;
  • the work equipment being used;
  • the number of persons likely to be present on the site at any one time; and
  • the physical and chemical properties of any substances or materials on or likely to be on the site.

(3) Where arrangements are prepared pursuant to paragraph (1), suitable and sufficient stepsshall be taken to ensure that,

  • every person to whom the arrangements extend is familiar with those arrangements; and
  • the arrangements are tested by being put into effect at suitable intervals.

Regulation 40. Emergency Routes and Exits

(1) Where necessary in the interests of the health and safety of any person on a construction site, a sufficient number of suitable emergency routes and exits shall be provided to enable any person to reach a place of safety quickly in the event of danger.

(2) An emergency route or exit provided pursuant to paragraph (1) shall lead as directly as possible to an identified safe area.

(3) Any emergency route or exit provided in accordance with paragraph (1), and any traffic route giving access thereto, shall be kept clear and free from obstruction and, where necessary, provided with emergency lighting so that such emergency route or exit may be used at any time.

(4) In making provision under paragraph (1), account shall be taken of the matters in regulation 39(2).

(5) All emergency routes or exits shall be indicated by suitable signs.

Regulation 41. Fire detection and fire-fighting

(1) Where necessary in the interests of the health and safety of any person at work on a construction site there shall be provided suitable and sufficient,

  • fire-fighting equipment; and
  • fire detection and alarm systems, which shall be suitably located.

2) In making provision under paragraph (1), account shall be taken of the matters in regulation 39(2).

(3) Any fire-fighting equipment and any fire detection and alarm system provided under paragraph (1) shall be examined and tested at suitable intervals and properly maintained.

(4) Any fire-fighting equipment which is not designed to come into use automatically shall be easily accessible.

(5) Every person at work on a construction site shall, so far as is reasonably practicable, beinstructed in the correct use of any fire-fighting equipment which it may be necessary for him to use.

(6) Where a work activity may give rise to a particular risk of fire, a person shall not carry out such work unless he is suitably instructed.

(7) Fire-fighting equipment shall be indicated by suitable signs.

Guidance on The Construction (Design and Management) Regulations 2007

The new regulations are supported by an Approved Code of Practice (ACoP).

The Approved Code of Practice (ACoP) has special legal status and gives practical advice for all those involved in construction work. If you follow the advice in the ACoP you will be doing enough to comply with the law in respect of those specific matters on which it gives advice and includes a copy of the Regulations.

The ACoP explains:

  • The legal duties placed on clients, CDM co-ordinators, designers, principal contractors, contractors, self-employed and workers.
  • The circumstances in which domestic clients do not have duties under CDM 2007 (but that the regulations still apply to those doing work for them).
  • Gives information on the new role of CDM co-ordinator – a key project adviser for clients and responsible for coordinating the arrangements for health and safety during the planning phase of larger and more complex projects.
  • Which construction projects need to be notified to HSE before work starts and gives information on how this should be done.
  • How to assess the competence of organisations and individuals involved in construction work.
  • How to improve co-operation and co-ordination between all those involved in the construction project and with the workforce.
  • What essential information needs to be recorded in construction health and safety plans and files, as well as what shouldn’t be included.

What the law requires in practice will vary depending on the risks. Erecting a simple steel framed building in the middle of a field will only require simple precautions because fire risks are low. Higher risk work such as refurbishing floors in an occupied office block, will need many more precautions because the risk of fire occurring and the difficulties of escaping from it are much greater.

Prevent fire occurring

Most construction fires have simple causes and can be dealt with by simple precautions. The following are particularly important:

  1. Make sure that LPG cylinders and other flammable materials are properly stored. LPG should be stored outside buildings in well-ventilated and secure areas. Flammable materials such as solvents and adhesives should be stored in lockable steel containers;
  2. LPG supplies should be turned off at the cylinder when not in use. This is particularly important out of hours. Serious explosions have occurred after site huts have gradually filled with gas because an LPG heater has not been turned off. Also make sure site huts are adequately ventilated and do not keep LPG in them if it is not needed;
  3. Make sure that LPG equipment and fittings are properly maintained. Damaged hoses and fittings or makeshift connections are extremely dangerous because they can easily lead to leaks in tough construction conditions;
  4. If there is any suspicion that LPG is leaking stop using it and check. Leaks can be identified by hissing, smell or using soapy water, but never with a naked flame. Only light up when you are certain that there are no leaks and that any vapour which has leaked has dispersed;
  5. Follow clear rules for hot work such as welding. Formal permit-to-work systems are often appropriate. In particular, make sure extinguishers are at hand and that sparks or heat cannot set fire to surrounding materials. After the work has finished (usually an hour later) check the worksite to make sure that there is no smouldering;
  6. Do not leave tar boilers unattended;
  7. Keep a tidy site and make sure rubbish is cleared away promptly and regularly;
  8. Avoid unnecessary stockpiling of combustible materials, e.g. polystyrene, and store what is necessary away from ignition sources. Limit what is taken onto site from the store to what is needed for a day’s work;
  9. Consider the need for special precautions in areas where flammable atmospheres may develop, such as the use of volatile solvents or adhesives in enclosed areas;
  10. Avoid burning waste materials on site wherever possible. Never use petrol or similar accelerant’s to start or encourage fires;
  11. Make sure everyone abides by site rules on smoking.
  12. Site rules for preventing fire are useless unless they are followed. Employers and construction managers should monitor their worksites and take appropriate action when breaches are found.

Preparing for fire if it happens

Fires can grow extremely rapidly. If a construction fire occurs the primary aim is to ensure that all those on site reach safety as soon as possible. Delay can be fatal. Site staff may need to fight a fire to enable their escape, but tackling larger fires is the fire brigade’s task.

Raising the alarm

  • If fire breaks out the alarm should be raised as soon as the first person discovers it.
  • The type of alarm needed can range from a simple shout of ‘fire’, to manual bells or klaxons or to sophisticated automatic systems. Whatever system is chosen make sure that it:
    • Can be heard by everyone working on site over normal background noise;
    • Will work when needed (check that existing building alarm systems have not been disconnected if you rely on them during refurbishment work);
    • Can be activated immediately (delay can be fatal).

Means of escape

Construction sites can pose particular problems because the routes in and out may be incomplete and obstructions may be present. Open sites usually offer plentiful means of escape and special arrangements are unlikely to be necessary. In enclosed buildings people can easily become trapped, especially where they are working above or below ground level. In such cases means of escape need careful consideration. Make sure that:

  • Wherever possible, there are at least two escape routes in different directions;
  • Travel distances to safety are reduced to a minimum;
  • Enclosed escape routes, for example corridors or stairwells, can resist fire and smoke ingress from the surrounding site. Where fire doors are needed for this make sure they are provided and kept closed (self-closing devices should be fitted to doors on enclosed escape routes);
  • Escape routes and emergency exits are clearly signed;
  • Escape routes and exits are kept clear. Emergency exits should never be locked when people are on the site;
  • Emergency lighting is installed if necessary to enable escape. This is especially important in enclosed stairways in multi-storey structures which will be in total darkness if the normal lighting fails during a fire;
  • An assembly point is identified where everyone can gather and be accounted for.

Fire-fighting equipment

The equipment needed depends on the risk of fire occurring and the likely consequences if it does. It can range from a single extinguisher on small low-risk sites to complex fixed installations on large and high-risk sites. Whatever equipment is needed make sure that:

  • Fire equipment is located where it is really needed and is easily accessible;
  • The location of fire-fighting equipment and how to use it is clearly indicated;
  • The right sort of extinguishers are provided for the type of fire that could occur. A combination of water or foam extinguishers for paper and wood fires and CO2 extinguishers for fires involving electrical equipment is usually appropriate;
  • The equipment provided is maintained and works.
  • Fire-fighting equipment should be checked regularly by a competent person – often from the manufacturer;
  • Those carrying out hot work have appropriate fire extinguishers with them and know how to use them.

Emergency plans

The purpose of emergency plans is to ensure that everyone on site reaches safety if there is a fire. Small and low-risk sites only require very simple plans, but higher risk sites will need more careful and detailed consideration. An emergency plan should:

  • Be available before work starts;
  • Be up to date and appropriate for the circumstances concerned;
  • Make clear who does what during a fire;
  • Where CDM applies be incorporated in the construction phase health and safety plan;
  • Work if it is ever needed.
  • On larger high risk sites fire drills may be appropriate.
  • On smaller sites, you should know what you need to do if there is a fire;
  • Managers need to make sure that everyone on their sites knows what to do;
  • Regular checks should be made to ensure that fire precautions are in place.

Providing information

Fire action notices should be clearly displayed where everyone on site will see them, for example at fire points, site entrances or canteen areas.

Check List

Emergencies

  • Are there emergency procedures, eg for evacuating the site in case of fire?
  • Do people on site know what the procedures are?
  • Is there a means of raising the alarm, and does it work?
  • Is there a way to contact the emergency services from site?
  • Are there enough suitable escape routes and are these kept clear?
  • Is the first-aid provision good enough?
  • Are suitable fire extinguishers provided?

Fire

  • Is the quantity of flammable materials, liquids and gases kept to a minimum?
  • Are they properly stored?
  • Are flammable gas cylinders returned to a ventilated store at the end of the shift?
  • Are smoking and other ignition sources banned in areas
  • Where gases or flammable liquids are stored or used?
  • Are gas cylinders, associated hoses and equipment properly maintained and in good condition?
  • When gas cylinders are not in use, are the valves fully closed?
  • Is flammable and combustible waste removed regularly and stored in suitable bins or skips?
  • Are suitable fire extinguishers provided?

References

The Construction (Design and Management) Regulations 2007 (CDM 2007)

Managing health and safety in construction. Construction (Design and Management) Regulations 2007. Approved Code of Practice L144 HSE Books 2007 ISBN 978 0 7176 6223 4

Health and safety in construction HSG150(Third edition) HSE Books 2006 ISBN 978 0 7176 6182 4

Fire safety in construction work HSG168 HSE Books 1997 ISBN 0 7176 1332 1

Workplace health, safety and welfare. Workplace (Health, Safety and Welfare) Regulations 1992. Approved Code of Practice L24 HSE Books 1992 ISBN 978 0 7176 0413 5

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March 17, 2011[Last updated: November 17, 2012]

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