Competent Persons, CPD and Legal Standing.

I am something of an autodidact, a self taught person, and therefore Continuing Professional Development seems to me like the most natural thing in the world for an engineer to be doing. Well, short of drinking coffee, arguing with one another and looking at the ceilings of restaurants rather than at our food.

The 29th of April 2025 saw an update to BS5839-1, and within Part 3 of Section 1 under terms and definitions we now have 3.13 competent person, defined as a person, suitably trained and qualified by knowledge and practical experience, and provided with the necessary instructions, to enable the required task(s) to be carried out correctly. Lovely, isn’t it? There’s a temptation to stick a checkbox in place of each of those commas, and have operatives refer to it before attempting what they’re doing. Perhaps such an aide memoir might have aided in avoiding the event that made a few of us considered getting a green heart tattoo. This definition already existed, and has been lifted from BS9991:2024 3.4, tinkered with a little and has been adorned with a note; maintenance of competence is likely to require continuing professional development (CPD). So, for those of you at the back, what is CPD, and what is it’s relationship with Competence?

The CPD Certification Service defines it as a commitment to ongoing lifelong learning. It involves learning experiences that help professionals develop and improve their practice, including building on strengths and addressing capability gaps. The sort of dirty joke I make about it is that I like to finds holes in my knowledge that I can stuff things into, for fun. But what we’re after is that we engineers keep our pencils sharp; its one thing to boast that you’ve been doing your thing ‘man and boy, 25 years at the coalface, since you lot were in nappies’ etc etc, but if the last time you were in a classroom or picked up a book was when you were 18 years old and you are presently 43, I might worry about what you have actually been doing for the last 25 years, particularly if you didn’t even truly grasp the idea of what you were doing then; I can certainly attest to having been both 18 years old and not in full grasp of the facts.

So, what does it look like?

Funnily enough, the way I record my CPD with the IET is mirrored exactly in how my 6 year old records her learning in year one of school. Its pretty straight forward; What did you do, what was involved, and have you reflected on it? So for example;

• Activity:

  • YouTube video titled How To Fry an Egg

• Description:

  • A start to finish tutorial involving egg breaking, pan heating and serving techniques

• Reflection:

  • I realised that my eggs were all over done because I was leaving the pan hot throughout, where as I now realise a better technique would be to drop the temperature halfway through and steam the top of the egg by adding a lid.

So, why do we do it? In short, because we have a duty of care, particularly those of us in life safety, and because we want to best deliver value to our customers. And also, why not strive to better ourselves?

But, we should also really be considering the relationship between our actions and our legal standing should the wheels ever fall off. Lets start with our trusty old steed the Electricity at Work Regulations 1989;

• Regulation 29, Defence.

  • In any proceedings for an offence consisting of a contravention of [regulations] it shall be a defence for any person to prove that he [read they] took all reasonable steps and exercised all due diligence to avoid the commission of that offence.

  • Sounds like having records stretching back all those 25 years showing that you spent at least 30 hours a year reading manuals and guidance, having discussions and attending seminars, when you’re dragged up in front of the man [person] in the wig and his [their] mate, the expert witness might be handy.

We might have to take a moment here to discuss the word ‘regulations’. As ever, the English language is doing its thing [being five other languages wandering around in a trench coat having gained enough sentience to try and outwit the very populace that keeps it alive], so its very important that we know our onions. The Electricity at Work Regulations 1989 are statutory, and as such have been passed by government and/or legislative bodies and as such are tied in with actual law, whereas the IET Wiring Regulations BS7671:2018+A3:2024, the big [presently] brown book [and its tuck in printouts] is non-statutory, and is considered guidance. But, can we do whatever we like when it comes to guidance? Can guidance simply be ignored? I mean, it is simply compiled by the hitherto experts in that particular subject, reconsidered every five years based upon learned experience, industrial advancement or in response to a genuine human tragedy. But of course it is Friday afternoon, the sun is over the yard arm, and we know better.

So, to avoid confusion lets have a look at the Daddy that is The Health and Safety at Work Act 1974, and the role of the guidance you are being accused of ignoring because someone has had a bolt or died of smoke inhalation;

• Section 17 use of approved codes of practice in criminal proceedings

  • (1) A failure on the part of any person to observe any provision of an approved code of practice shall not of itself render him [read they] liable to any civil or criminal proceedings, but where in any criminal proceedings a party is alleged to have committed an offence by reason of a contravention of any requirement or prohibition imposed by or under any such provision as is mentioned in section 16(1) being a provision that there was an approved code of practice at the time of the alleged contravention, the following subsection shall have effect with respect to that code in relation to those proceedings.

  • (2) Any provision of the code of practice which appears to the court to be relevant to the requirement or prohibition to have been contravened shall be admissible in evidence in the proceedings; and if it is proved that there was at any materials time a failure to observe any provision of the code which appears to the court to be relevant to any matter which it is necessary for the prosecution to prove in order to establish a contravention of that requirement or prohibition, that matter shall be taken as proved unless the court is satisfied that the requirement or prohibition was in respect of that matter complied with otherwise than by way of observance of that provision of the code.

Or the muscular Uncle that is the Fire Safety Act 2005, that highlights all that is required by a Responsible Person, which you might assume is simply the owners of or those in charge of a building or such, but it also takes a look at Dutyholders (2.18) that defines them as having the same duties as Responsible Persons, the following is taken from 2.19 as an example;

• contractors who maintain fire protection systems and equipment (such as fire extinguishers, emergency lighting and fire alarm systems). In this case, they only have duties, under the Fire Safety Order, in relation to maintenance of systems and equipment they are contracted to maintain.

• Contractors whose work may affect other fire safety elements of the building (ie where installing cables or pipes through compartmentation)

• external consultants contracted to carry out fire risk assessments, as their contract relates to the safety of the premises.

So what we’re saying is, compliance with British Standards might be there to help you meet the guidance of the Approved Documents which are there to help you meet in part the guidance of EAWR 1989 it is all ultimately leading up to helping you meet the requirements of acts of parliament which are law, against which you shall be tried. How do we prove our duty of care? Lets look our handy checklist;

• Are we;

  • suitably trained and qualified by

    • knowledge?

    • practical experience?

  • provided with

    • the necessary instructions, to enable the required task(s) to be carried out correctly?

• And if I may, could I also add;

  • Do I want to

    • Do a good job?

    • Be better today than I was yesterday?

  • Am I

    • the right person to be executing this task?

There is a cultural irony at play here, akin to the Dunning-Kruger effect, in that the hearts and minds of those we need to convince ain’t out here reading blogs, or else we wouldn’t have a problem. And that’s not beginning to touch on the concerning sociopathy of those that literally do not care if people get hurt [Matt shudders existentially]. So, it is up to us nerds to mobilise and have a quiet word, here or there, with our right honourable colleagues out there in the field.

Cultural change is slow, attentions spans are dwindling. But, an avalanche is but a collection of little bits of snow, so maybe a quiet word here, a grain of shame there, and as a village, we’ll get there. In the short term though, make sure you’re recording your CPD, in case you meet the person in the wig and their mate.

Wireless Fire Alarm Systems

Wireless fire alarm systems are a great way of quickly improving your fire safety compliance with minimal interruption; a single installer could install a system of up to 50 devices in a day!

These types of systems are ideal for finished buildings as a retrofit solution or within buildings that hard wiring is unsuitable, for instance in heritage or buildings of architectural buildings that need to be preserved.

At SEFE we are well versed with most wireless fire alarm manufacturers on the market, such as but not limited to EMS Firecell, EMS Smartcell, Apollo Reach, Hyfire Taurus, Hochiki EKHO and Zerio Plus by Electro Detectors. Based in East Sussex, we are well placed in install in Kent, London, West Sussex and Surrey.

Get in touch for a free estimate.

Fire Alarm Servicing & Honest Reporting

Having high standards can make one unpopular. AT SEFE we take great pride in attention to detail and thoroughness. But, it does mean that frequently we run into a familiar situation; we’re the first to have actually paid attention in a while. And it isn’t fair for the customer, to have the figurative rug pulled from under them when suddenly issues that hadn’t been known to exist are suddenly revealed. And these issues might bring with them additional cost, like the least popular relative bringing a new obnoxious partner to a family do.

But, we do it for good reason. A little while ago I serviced the fire detection and alarm system at a hotel, and the wiring wasn’t properly installed. In essence, it was supposed to be a loop, the cabling intended to leave the control panel, go around the whole system and return to the panel, the idea being that this gives contingency; a break in the cable would mean that the two halves are still both connected to the panel. But, it left the panel and ended in the fabric of the building somewhere, and some nefarious individual had put little links within the panel, tricking the machine into thinking the wiring was correct. I reported as such and recommended correcting the wiring, and was readily dismissed by the owner.

And then, within weeks, a drunken hotel guest ripped down what happen to be the second point in the sixty point system, broke the cabling, and suddenly the system had fifty eight devices missing. The hotel was immediately down to 3% of its coverage.

So, whilst it might seem as though we’re only delivering bad news, we’re just trying to get ahead of the unfortunate occurring.

If you would like us to deliver you some bad news (which is just good news viewed in the wrong light, when it comes to life safety and compliance), book a fire alarm service and inspection with us. We cover East Sussex, Kent and London.

Fire Alarm - Categories of Coverage, and What to Expect.

So, the local authority has been around, asked you to have a Fire Risk Assessment performed, and now you need to get a fire alarm installed. They have a suggested a Grade and Category, but what does it all mean?

Let me get one thing straight up top; your Fire Risk Assessor might not be a fire alarm designer (Risk assessors, feel free to come at me, communication links are at the top.) I have faced a number of awkward scenarios in which the risk assessor has briefly described what sort of coverage the property requires, which effectively hamstrings my designs. And then, when I question this on the customers behalf, I’m either totally ignored, or the risk assessor emails the word LEGISLATION at me without any further explanation and their email signature magically has a few more post nominals on it.

I’m not digging out risk assessors by any means, but the layperson might be better off grouping them in with building surveyors; “Foundations look alright but get a builder to check. Electrics look already but get a sparks in. Boiler looks fine but best get a gas safe engineer in to be sure.” The service they provide is useful and essential and I’m not by any means trying to underline it, but they are expected to wear a great deal of hats and in my opinion fine detail is left to specialists. I do a lot of the converted townhouse in flats style systems of varying scales, of which the risk assessor will only have inspected the common ways. So, to recommend that a heat detector needs to be installed behind a door they haven’t opened, isn’t helpful, as there’s a good chance the entire top half of the building would have to be an inferno before that device would trigger.

My spleen suitably vented, lets get into it.

Depending upon the complexity of your building, you will either be recommended a Grade D (domestic style devices, see Aico, Fire Angel, Hispec etc) or a Grade A (commercial style with control panel). That aside, lets look at categories of coverage, and what they mean for your building. We are protecting Life in this blog so expect the letter L, add a D if a domestic system, and a number for coverage amount. You would also do well to consider the fire triangle (oxygen, ignition source and fuel).

• Category L1 or LD1

  • You will have a suitable detector anywhere with the potential for fire. This may exclude very small cupboards unless there’s something that could ignite (electrical stuff probably) and something to burn (stored goods such as linen, chemicals, stationary etc). Whether domestic or non-domestic, we’re smothering the place in detection, as we are after a very quick alert to the presence of fire.

    • Some buildings get what is called an L1+ or such system in them, due to their nature. Irreplaceable heritage buildings, uninsurable power plants or hyper-continuity minded data centres, to name but a few.

• Category L2 or LD2

  • L2 - Non Domestic

    • This system is an L3 system (see below) with additional detection in areas of high risk, which should be determined by your risk assessor but hardly ever is (once again, risk assessors you know where to find me). Expect additional devices in high risk areas such as the plant room, boiler house, laundry room, kitchen, staff kitchen, etc. Moderately easy to determine if you consider the fire triangle.

  • LD2 - Domestic

    • Owner owned. Tenanted rental.

      • Circulation areas (your hallway and stairs, escape routes) and in all specified high risk rooms including kitchen and main habitable room, living room usually.

    • HMO

      • Circulation areas (your hallway and stairs, escape routes) and in all specified high risk rooms including kitchen and main habitable room(s). In an HMO usually ones bedroom gets used also as a living room and/or a miniature flat of its own, there will often be a load of extension leads in play and moody electrical goods from Amazon. Larger HMO’s actually fall under the non-domestic standard, so keep an eye out for that.

• Category L3 or LD3

  • L3 - Non Domestic

    • Commercial properties

      • Designed to let occupants of the building know that a fire has occurred, early enough that they can escape safely before their escape route becomes compromised. We will be considering escape routes (not limited to corridors, literally any route you might take to a point of eventual safety) and rooms that lead onto them. In essence we have detection monitoring the compartmental fire doors that surround the escape routes, so expect a device near the door rather than in the centre of the room. We would always have included lift shafts and lift lobbies here, and BS6839-1:2025 fresh off the presses now includes the low risk little lobbies you get halfway down corridors, and in hotels you can now expect a smoke detector in the room with a sleeping occupant rather than a heat detector by the door; spontaneous human combustion is apparently on the up.

    • Shared common ways or stairwells within blocks of flats

      • Hold the phone! Whilst one might assume otherwise, these areas fall under 5839-1 for non-domestic premises, creating an incredibly petty and pedantic bugbear of mine when the recommended categories are LD rather than simply L. Also creates an argument about whether we’re after sound pressure levels of 75db at the bedhead with the door closed as per 5839-1 or 85db at the doorframe as per 5839-6, and whether a sounder in the room is the correct action or having it in the hallway suffices, and the budgetary headaches this creates.

      • In any event, expect a smoke detector and call point on each floor of the stairs but not the turns unless they’re huge, and heat detectors within the flat monitoring areas that affect the escape route. If the flat is a duplex, one can expect a heat detector on each landing at least, and if the flat goes beneath the ground floor hallway, a heat detector there too. The assumption is that the heat detector would be monitoring the front door, but a heat detector in that specific location might be as useful as an ablutionary orifice at the bend in your arm.

  • LD3 - Domestic

    • This is just your circulatory areas / escape routes. Please bare in mind that an escape route is anywhere that leads to a place of eventual safety, so if your kitchen leads into the garden, you’ve got French doors in the lounge or a large window in your bedroom with a metal staircase outside it, you might end up with automatic detection in the vicinity.

• Category L4 - Non-domestic

  • The non-domestic equivalent of LD3 and where we leave the domestic categories. We’re just covering the escape routes on their own, with the 2025 addition of any shaft like structure (lift, dumb waiter, electrical/mechanical riser, etc) included. Whilst important to cover these routes, these systems always feel a bit like value engineering to me. It might genuinely be the most effective and reasonably practicable amount of coverage for the building, but I would personally give the assessment another read over, ensure I were to conduct a thorough survey, and have a word in the Fire Engineers shell-like before adding my signature to the design.

  • Category L5

    • These systems are very much an engineered design that form a part of the specific fire strategy of that building and would usually be the remit of a Fire Engineer, rather than something a Fire Alarm Designer would suggest, such as in an Airport or a Train Station.

      • I will eat some crow here by saying that following the Grenfell tragedy, a Fire Risk Assessor might suggest for a high risk building an L5 system that is an L3 system, but we’re also covering areas that THE SOLID PETROLEUM CLADDING THE ENTIRE BUILDING IS COVERED IN CREATING A FLUE LIKE STRUCTURE SEEN ALSO IN SAMURAI SWORD SMELTING (THEY REALLY DID THAT (JESUS OF NAZARETH AND HIS PARENTS MARY AND JOSEPTH ON A TANDEM PUSH BIKE WE REALLY DO NEED TO TAKE A GOOD LOOK AT OURSELVES)) interacts with or might allow fire ingress, such as via external windows or vents. Big one for wireless systems that.

If you would like a fire alarm designed, the verification of a design and/or the commissioning of your fire alarm, please get in touch.