Construction fire safety plan: the Joint Code of Practice sections reviewers open first

A construction phase fire safety plan is one of the few documents on a project that two different readers open for two different reasons. The principal contractor's insurer opens it to check the project against the Joint Code of Practice before confirming cover. The client's adviser opens it to check the same thing before confirming the contract is being run properly. Neither reads it cover to cover. Both go straight to the same handful of sections, and a plan that is thin in those sections gets questioned however good the rest of it is. This post is about which sections those are, what each has to show, and the ordinary ways a plan drifts away from the site it is supposed to describe.

A code insurers wrote, not a regulation

The Joint Code of Practice is not a statutory instrument. It is industry guidance, published by the Fire Protection Association with the Construction Leadership Council, now at its 10th edition incorporating Amendments 1 and 2, and it carries weight because the insurance market built its construction-phase cover around it. Most contract works policies require compliance with the Code as a condition of cover, and most main contractor and client requirements documents require the same by reference, so a plan that does not follow its structure is one the broker and the client's adviser will both query. Alongside it sits HSE's HSG168, Fire safety in construction, now in its 3rd edition: the regulator's own guidance, and the document an HSE inspector is most likely to have in mind on a site visit. Neither replaces the legal duty: CDM 2015 (SI 2015/51) requires the principal contractor to prepare a construction phase plan, under regulation 12, setting out site rules and arrangements for managing the significant risks of the work, and fire is one of those risks on any site with hot works, temporary electrics, combustible insulation or timber frame. The two codes are how that duty gets written up in enough detail to be checked.

Where part of a building is occupied while construction continues elsewhere, a phased school, hospital or retail scheme being the common case, the Regulatory Reform (Fire Safety) Order 2005 also applies, to the occupied part and its own responsible person. The construction phase plan then has to show how the site's arrangements interface with that responsible person's: whose alarm the site reports to, whose evacuation routes the hoarding does not block, and who tells whom when a hot works permit is issued near the shared wall. A plan that treats the whole project as one undifferentiated construction site when half of it is occupied is the first thing a careful reviewer will pick up.

What the plan has to contain

• A named fire safety coordinator, appointed in writing, with the authority to stop work and a briefing record, not just a title added to an existing role.
• A site-specific fire risk assessment that changes as the building does. The escape route past one completed staircase is not the escape route once a second is usable, and an assessment written at mobilisation and never revisited describes a site that no longer exists.
• Means of escape and travel distances for the construction phase, on a site plan reissued as access routes, hoarding and staircases change, not left as the tender-stage drawing.
• A hot works procedure and permit register, with the fire watch during and after the work and the extinguisher at the point of work, not at the store.
• Compartmentation and fire-stopping sequencing against the programme, so the plan states when temporary fire stopping is needed at a penetration awaiting its permanent treatment.
• Control of flammable materials, LPG and temporary heating, with a register of what is stored where, in what quantity, and how far from the boundary and any occupied space.
• Site security against arson: perimeter security, lighting, skip and waste storage away from the structure, and out-of-hours checks.
• Liaison with the fire and rescue service: a site plan held at the gate showing access, water supplies and commissioned fire systems, kept current as the layout changes.
• Fire point and extinguisher provision matched to the hazards present, checked and recorded, not installed once at mobilisation.
• Training and drills, recorded, briefed to every new starter and repeated at a stated frequency.

The sections reviewers open first

Where it gets missed on real sites

A fire safety plan is rarely abandoned outright. It drifts, in a handful of ordinary ways.

1. The coordinator is named but never briefed. The role sits with the site manager by default, nobody tells them what the appointment actually requires, and the first they hear of it is when an auditor asks to see the briefing record.
2. The escape plan is the tender drawing. The staircases, hoarding and access roads have all moved since the plan was issued, and the document in the site office describes a building that no longer matches the one standing.
3. The hot works permit is issued, but the fire watch is not kept on afterwards. The work finishes, the operative moves to the next task, and the smouldering material that starts a fire two hours later is exactly what the post-work watch exists to catch.
4. Fire stopping is treated as snagging. A service penetration is left open "to come back to" once first fix is complete, the compartment line is broken for weeks, and nobody has recorded that a temporary measure was needed in the meantime.
5. The liaison pack is not updated. The road the fire service would use is now the site compound, the plan at the gate still shows the old access, and nobody has told the local fire station the layout has changed.
6. Training happens at induction and nowhere else. New subcontractors joining mid-programme never get the briefing, and the drill record shows one entry from eighteen months ago.

None of these is a decision to ignore fire safety. They are what happens when the plan is written once, filed, and left to describe a site that keeps moving without it.

Keeping the plan alive

The plan needs a stated review trigger, not just a review date. A change in building height or occupied status, a new staircase or escape route becoming usable, a change to the construction programme that moves hot works or fire stopping, a new subcontractor bringing flammable materials onto site, or any incident or near miss, should each trigger a review of the sections that change: the escape plan, the liaison pack, the materials register. Reviewed on a fixed six-monthly date and nothing else, the plan will always be behind the site it describes.

Where this sits in our library

The Construction Site Fire Safety Pack carries the construction phase fire safety plan as a full worked example cited to the JCoP 10th edition with Amendments 1 and 2 and HSG168, with the coordinator appointment, hot works procedure and register, compartmentation tracker, flammables and LPG register, arson checklist, drill record and fire service liaison pack behind it, plus the Regulation 38 handover schedule that carries the fire safety information forward at completion. The RAMS Library and the toolbox talk libraries supply the hot works method statement and the induction and drill briefings that sit alongside the plan. If you want to see how our documents are cited and cross-referenced before buying anything, the free ITP is the place to start.