Are P50 Extinguishers Compliant?
Few products in fire safety generate as much confusion as the P50 service-free extinguisher, and the question of whether it is compliant is one we are asked regularly. The honest answer needs a little precision, because the word "compliant" is doing a lot of work, and the reality is more nuanced than a simple yes or no. The P50 is widely misunderstood, so it is worth setting out clearly what it does and does not conform to, and what that means in practice for a responsible person deciding whether to use one.
The short answer
A P50 is a legal, certified and Kitemarked extinguisher that meets the legal requirements placed on all extinguishers, and conforms to the construction standard and to most of the relevant British Standard. It is correct to say that it is non-compliant, but only in the narrow sense that it does not conform to two specific parts of the British Standards, while complying with BS EN 3 for construction and with the remainder of BS 5306. Understanding which two parts, and why, is the whole of the matter.
What the P50 does comply with
Every fire extinguisher sold in the UK must comply with the Pressure Equipment requirements, shown by the CE or UKCA mark, which is a genuine legal requirement and one the P50 meets. Beyond that, the P50 is certified to BS EN 3, the standard covering the construction and performance of portable extinguishers, and carries the BSI Kitemark along with its other approvals. In other words, on construction, on performance and on the legal pressure-equipment duty, the P50 stands on the same footing as a conventional steel extinguisher.
The two points of non-conformance
The non-compliance arises in two specific places, both of which follow from the P50 being built and maintained differently from a steel unit rather than from any deficiency in how it works.
BS 5306-3, the maintenance inspection
BS 5306-3 covers the commissioning and maintenance of portable extinguishers, and its annual inspection assumes a conventional unit, where the exterior of the cylinder holding the contents can be examined directly, which on a steel extinguisher is simply the outside of the cylinder. The P50 cannot be inspected in that exact way, because its inner flask is enclosed within the construction, wrapped in an aramid fibre weave and protected by an outer case, so the conventional external inspection of the pressure-bearing cylinder cannot be carried out as the standard describes. Maintenance of the P50 instead follows the manufacturer's instructions, which the standard itself recognises as the basis for maintaining any extinguisher.
BS 5306-10, the colour coding
BS 5306-10 sets out the recommendations for colour coding to indicate the extinguishing medium, using a solid continuous block of the colour that identifies the contents. The P50 indicates its medium through lettering in that colour rather than through a solid block in the conventional form, so it does not conform to this particular recommendation. This is a matter of how the medium is signalled on the body rather than anything to do with the extinguisher's effectiveness.
British Standards are not lawThis is the crucial point of context. British Standards are guidance and best practice rather than legislation, so an extinguisher that does not conform to parts of BS 5306 is not thereby illegal. The P50 is designed and works perfectly well as an extinguisher, it is entirely legal to use, and in some settings, such as areas of corrosive sea air where steel units corrode, its construction is arguably better suited than a conventional steel extinguisher.
What the responsible person must do
The legal duty sits in the Regulatory Reform (Fire Safety) Order 2005. Under Article 17, the responsible person must maintain all fire protective equipment in efficient working order and good repair, and that duty applies to a P50 just as it does to any other extinguisher. For the P50, that maintenance takes the form of an annual inspection carried out by a competent person, and competence here is achieved by following the manufacturer's training, provided by Britannia, after which the responsible person can carry out the annual check themselves without a service provider needing to attend. The extinguisher is then returned to the manufacturer at the ten year point for refurbishment, which extends its working life further. The duty to maintain is met, in other words, through a different route rather than not at all.
If you want to use P50s
For anyone considering P50s, two practical steps make the position clear and defensible. The first is to check with the insurance provider for the property, since insurers take an interest in extinguisher arrangements and most accept P50s but expect to be told. The second is to amend the fire risk assessment accordingly, recording the types of extinguisher in place, their suitability for the risks, and the maintenance regime, including the competent-person training that supports the annual inspection. With those two steps taken, the use of P50s rests on a clear and documented footing.
Why our view on this is impartialWe do not sell, supply or service any fire extinguishers, P50 or conventional, so we have no commercial interest in which you choose. When we assess your building, we can set out factually how P50s sit against the standards and the law, and make sure your fire risk assessment records them correctly, giving you an objective basis for the decision rather than a recommendation tied to a particular product.
The compliance question around P50s is, in the end, a question of detail rather than of legality, and the confusion around them tends to dissolve once the specifics are set out plainly. As independent assessors covering the North West, North Wales and the West Midlands, we are glad to give you a clear, impartial view on whether P50s suit your premises and how to document them properly.
Unsure where P50s leave you?
We can set out factually how P50 extinguishers sit against the standards and the law, and make sure your fire risk assessment records them correctly, with no products to sell you either way. If you would like to discuss it, please get in touch.
Get in touch Fire Risk AssessmentsThis article is provided for general guidance and does not constitute professional advice for any specific premises. It refers to the Regulatory Reform (Fire Safety) Order 2005, BS EN 3 and BS 5306, including parts 3 and 10. Considerable care has been taken to ensure accuracy at the time of writing, but standards and guidance change over time, and product specifications should be confirmed with the manufacturer. Fletcher Risk Management Limited provides Fire Risk Assessments, Fire Door Inspections and Fire Safety Training across the North West, North Wales and the West Midlands.