Emergency, health and safety compliance case study

Emergency and health and safety compliance rests on three legs; the law, the means, and enforcement. A firehose reel case study reveals some obstacles to compliance.

Firehose reels are among the most visible elements of public and occupational health and safety management, and of a reasonably safe workplace, as the OHS Act (see below), the National Building Regulations, and compulsory specifications (see below) require.

They stand in signal red as apparent testimony to adequate safety, emergency planning, and emergency response preparation. Yet many aspects of compliance with firehose law, the standard, the equipment, installation, maintenance, audit, and enforcement are problematic, reports Edmond Furter.

The law is apparently simple; maintain firehose reels that comply with SANS 543. The authorities, equipment, installers and registered auditors are readily available. The reels are on health and safety inspections lists, in full view of workers, Labour inspectors, and the public.

But a closer look at each of the legs of safety compliance, and at firehose reels themselves, reveal that some aspects of compliance exist only in theory, and that occasionally, even standards themselves are lowered.

The compliance triangle.
The compliance triangle.

Firehose reel law obstacles

The OHS Act in section 44 incorporates the National Building Regulations (NBR) under the Construction Regulations, making SANS 543 a compulsory specification.

The OHS Act requires firehose reels as directed by the local fire chief, who follows the NBR, and SANS 10400, and may check that the installation design was done by a fire engineer registered with ECSA, and who signs the occupancy certificate.

The National Building Regulations (NBR) are currently in revision, and would probably confirm the SANS revision.

NBR requirements for firehose reels prescribe that buildings of two or more storeys in height, or single-storey buildings of more than 250 m2 floor area, must have a hose reel for every 500m2.

A firehose must reach all the areas it intends to protect. Reduced reel size reduces hose length, thus more units may be needed to cover the same area. The fixed pipeline supplying the reels must be minimum 25mm diameter.

The NBR also refers to SANS 1475 on certification of maintenance contractors and their employees, involving the SA Qualification and Certification Committee (SAQCC Fire).

Public comment on the current firehose standard revision closed in January 2015, and SANS 543: 2015 will soon be published.

The new SANS 543 110314 for firehose reels with semi-rigid hose, will include some changes that could compromise safety, quality, and emergency response;
[] Hose bore is set at ’19mm or 20mm’, while fitting shanks of connectors, nozzles and taps are not specified by diameter, nor by the number of ribbings. Most hoses are 20mm, and most fittings are 19mm, making for a loose fit.
[] Clamps are not defined, despite the recommended working pressure of 1.2 MPa, and the number of leaking hoses fitted by common screw-type clamps.
[] Nozzle size is not specified. Most nozzles are much smaller than the ergonomic ideal of 105mm length and 38mm diameter.
[] Shut-off nozzle setting to spray or jet is optional, and many have only a jet setting.
[] Lever-operated nozzles are allowed, despite being cumbersome and incapable of spray setting.
[] Reel disc diameter maximum is reduced to 700mm. Some suppliers sell 570mm reels, allowing much shorter hoses.
[] The water supply spindle entering the reel, may be at T-connection (as in the past), or bent at a radius. The bend may cause wear on the bush, and could cause misalignment with the front end of the axle where the gooseneck connects.
[] Goosenecks have only one rib for a clamp to secure to the back of the hose.

The Department of Labour and the NRCS will be invited to send delegates to the technical committee, although the standard review is completed.

A compliant firehose reel compromised by abuse and obstruction. Some industrial conditions require robust and durable emergency equipment and systems.
A compliant firehose reel compromised by abuse and obstruction. Some industrial conditions require robust and durable emergency equipment and systems. Photo; Riskauditresults).

Firehose reel equipment obstacles

There are some basic equipment requirements in OHS Act section 10, including duties of manufacturers and others; (1) Any person who designs, manufactures, imports, sells or supplies any article for use at work shall ensure, as far as is reasonably practicable, that the article is safe and without risks to health when properly used, and that it complies with all prescribed requirements…”

OHS Act section 22; “Sale of certain articles prohibited. Subject to the provisions of section 10 (4), if any requirement [including a compulsory or incorporated standard] in respect of any article, substance, plant, machinery or health and safety equipment or for the use or application thereof has been prescribed, no person shall sell or market in any manner whatsoever such article, substance, plant, machinery or health and safety equipment unless it complies with that requirement…”

Suppliers have to include a maintenance manual. Employers have to appoint a monthly inspector to check the reel condition; fixed installation condition; leaks; cracks; bleaching; damage; rust; abnormal conditions; pressure; emergency seals; and missing or broken parts.

Firehose inspectors must record inspection date; site repairs; identification of components requiring reconditioning; and reconditioning arrangements.

Firehose reel equipment enforcement includes the National Regulator for Compulsory Specifications (NRCS) of the SABS, recently moved to the direct jurisdiction of the Department of Trade and Industry (DTI).

However the NRCS wrote to the SA National Consumers Union that “there does not appear to be a compulsory specification for firehoses.” They therefore do not list firehose equipment as one of their competencies.

“It would appear to us that the problem lies with the Department of Labour and local authorities,” said the NCRS (SANCU update 20.08.2013).

Suppliers who are SABS mark holders could be disciplined for abusing the mark, and some have been sent letters. However the SABS is generally reluctant to act against its clients, and the NRCS is generally lenient on products with the SABS mark.

Some imported electrical appliances and condoms with SABS marks, have been said to fail, or to be of low quality (see separate posts on SABS-marked electrical appliances, and DOH SABS-marked condoms).

Most SANS standards are overwritten, in whole or in part, from ISO standards to keep current with supply specifications. Chinese suppliers dominate some ISO standard bodies.

Typical SABS-marked firehose reels (FHRs) use simple screw-type steel clamps that are prone to strip, seal poorly, or fail under pressure. Screw-type clamps often have protruding sharp edges that could injure users.

Nozzles tend to turn in the hose, instead of opening the valve. Some get stuck when clogged by dirt. Some internal gooseneck pipe bends are insufficient, causing a pinch in the hose.

Some firehose nozzles are said to be made in Durban, and there was a promise that the shanks would be made longer, and double serrated, so that two clamps could be fitted on the hose.

However most nozzles are short, their 19mm diameter allows 0.5mm play inside 20mm bore hoses, and are single serrated by a bevel, further reducing the shank diameter and loosening the fit.

Most SA firehose suppliers are retailers only, with no maintenance service, and no direct liability or recourse.

A quick firehose reel test in an office environment. Emergency training and drills should include full unrollling and a pressure test.
A quick firehose reel test in an office environment. Emergency training and drills should include full unrollling and a pressure test.

Firehose reel enforcement obstacles

OHS Act enforcement rests with Department of Labour inspectors, but few inspectors have the skills to inspect or test fire equipment.

The DOL Chief Inspector had ordered a Prohibition Notice against a supplier of faulty units at some state-owned buildings, but the precedent is impossible to follow, since nearly all firehose reels in SA are either defective or non-compliant, said consulting auditor Johann Cilliers.

National Building Regulations enforcement includes building inspectors and local authorities, but they rely on inspection tags. Fire departments are usually consulted for design, not for testing. Firemen are not trained in testing first line emergency equipment, and seldom use it.

Local authorities may inspect emergency equipment, but they also rely on the maintenance record, signed and tagged by inspectors registered with SAQCC Fire.

The certification body had occasionally fined and suspended some members for malpractice, but they routinely sign off on the current equipment, thus setting a de facto standard.

There are ‘valid’ maintenance tags on some fire equipment that does not work. Few internal or third party health and safety practitioners, consultants or auditors have sufficient skills to test fire equipment, and all rely on the maintenance record.

Few employers or facilities managers test their reels and hydrants during fire drills.

“If one of the authorities failed to do their work, enforcement of the standard is compromised,” said a member of the committee. However, if one of the relevant authorities DID do their work, the standard would be enforced.

The emergency, health and safety compliance triangle

Problems in each of the three compliance pillars, or legs (law, resources, and enforcement), reveal some mutual shortcuts.

Employers and facilities remain liable to install and maintain reasonably safe and secure sites, even while the available equipment, services, skills, enforcement, or legislation itself (or all three) may be deficient, or on the cheap side of ‘reasonable’.

Insurance assessors investigate compliance after fire claims, including equipment specifications, NBR procedures, and maintenance in terms of SANS 1475-2. Insurers do not pay out if they find non-compliance.

Due to their cost, their administrative burden, and their false sense of safety, emergency, and insurance security, ineffective fire-fighting equipment may be worse in the hour of need, than none at all.

• The SABS National Committee on Fire Fighting Equipment, TC021/SC04, and the Firehose Reels workgroup that revised SANS 543: 2004 to SANS 543: 2015, included several suppliers, and officials of the SABS, SAQCC, FFETA, FPASA, SAESI, and FPA. The chairperson was Peter Cross. The current chairperson, after finalisation of the review, is Marius Atterbury.
• This post contains elements of relevant legislation, not all the relevant legislation, and does not constitute legal advice.

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One thought on “Emergency, health and safety compliance case study

  1. In rationalisation in spite of the challenges to compliance listed in the article, I am sure our courts, civil or criminal, will find people with deficient equipment liable (pater familia principle), and handsome damages would result.
    Insurance companies will gladly use “unsuitable or not fit for purpose” equipment as a valid reason to refute a claim.
    As Gallileo said when the authorities forced him to say that earth does not orbit around sun -” It orbits and that is the end of it.”
    Be careless and you will pay!!

    —- Editor notes; But Your Honour, I cannot find better equipment, and everyone’s equipment is deficient, and I am a reasonable man?

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