by MP for Aljunied GRC, Sylvia Lim
[Delivered in Parliament on 8 April 2013]
I am in general support of the rationale for the Bill. However, I wish to seek some clarifications on Clauses 17 and 18 which require designated buildings to provide emergency response plans and to have Company Emergency Response Teams. Specifically, I wish to ask what role SCDF will play to collaborate or partner with building managements to comply with the new requirements, and whether the burden being placed on fire safety managers under the new scheme is perhaps too onerous.
First, the new requirement for emergency, not just fire, plans
Clause 17 amends Section 21 of the Act to require owners or occupiers of designated buildings to have in place not just a fire emergency plan but an emergency response plan. The new requirement is supposed to obligate building management to cater for all emergencies, not just fires, that may cause injury or loss of lives. Earlier in his Second Reading speech, Senior Minister of State mentioned that the emergencies had to be “fire-related” though I did not see this specifically in the legislation so I would appreciate some clarification on this point. Clause 18 will amend Section 22 to require that buildings which are currently required to have fire safety managers shall also have competent Company Emergency Response Teams as part of emergency preparedness (Ministry of Home Affairs Press Release 14 Jan 2013).
The need to prepare response plans for emergencies is self-evident, and this is especially so in our high-density urban environment. In addition, the proximity of our homes, work places and recreational spaces means that when emergency plans are drawn up for buildings, they should be able to respond to not just critical incidents from within the building but those which could potentially come from nearby facilities and even the external natural environment.
Next, what is SCDF’s optimal collaborative role in emergency planning?
The law currently places the responsibility for emergency planning squarely on the building owners and occupiers. Under the Act as well as Fire Safety (Fire Emergency Plan) Regulations 2008, they have to prepare and execute the emergency plans, conduct regular drills, and gather tenants to form Fire Safety Committees. The role of the SCDF itself is reflected as issuing of guidelines about the contents of plans, reviewing records and so on. SCDF’s role appears to be as regulator and auditor. Under this Bill, building management will have an even more onerous statutory obligation, with wider coverage to include non-fire emergencies, which will require more specialized expertise. What will SCDF do to assist building management in drawing up the required emergency response plans?
Even though the building management should bear the primary responsibility for the plans, the benefits of SCDF being involved in drawing up the emergency response plans would be tremendous. SCDF could advise on matters which the building management has no knowledge or control over. Examples of such matters would include: the potential emergencies from outside the building which the management should plan for; whether there is potential to share emergency resources with nearby facilities; and even which open areas to use as assembly points, especially at our blistering pace of urban renewal. Worldwide it is increasingly recognized that public-private partnerships in emergency planning, involving both government and private organisations, will improve the quality and practicality of the emergency plans. At the same time, through joint efforts, SCDF would have a good grasp of the private sector expertise and resources available which could be tapped upon in national emergencies.
Could Ministry explain how SCDF will collaborate with the building managements to comply with the new requirement and to improve the quality of emergency plans? For instance, would SCDF provide a template for building managements to use and adapt?
Finally, the role of Fire Safety Managers and CERTs
Clause 18 will amend Section 22 to require buildings with fire safety managers to now have Company Emergency Response Teams (CERTs) with competent in-house staff. The proposed Section 22 (3A) states that it is the building owners or occupiers are required to maintain the CERTs. However, the MHA Press Release 14 Jan 2013 indicates that it will be the responsibility of Fire Safety Managers (FSMs) to ensure that the response plan guidelines are complied with, including upgrading the competencies of the in-house teams to form CERTs.
Is this task too onerous for the FSM to be held responsible for? The FSM in a building is likely to be a mid-level employee with several corporate roles e.g. he could be an occupational safety and health officer doubling up as an FSM. To place on him the responsibility of ensuring that competent CERTs are in place which comply with SCDF guidelines on emergency response seems too onerous.
Will the government assist building managements to comply with this new requirement for CERTs and if so, how? For instance, are there any plans to develop new training courses in emergency response planning to cater specifically to the new statutory requirement for CERTs?