Guidance for fire safty in accommodation premises

1. Legislative Framework and Joint Working

Fire safety in residential accommodation is governed by two primary pieces of legislation in England and Wales: the Regulatory Reform (Fire Safety) Order 2005 (FSO) and the Housing Act 2004. The FSO applies to the common parts of HMOs, flats, maisonettes, and sheltered accommodation, placing duties on a "responsible person"—typically the landlord or managing agent—to conduct a fire risk assessment (FRA) and implement general fire precautions. Conversely, the Housing Act 2004 utilizes the Housing Health and Safety Rating System (HHSRS) as the principal tool for assessing fire hazards within individual units of accommodation and common areas.

Because this creates a dual enforcement regime, local housing authorities (LHAs) and fire and rescue authorities (FRAs) operate under a national protocol to ensure a coordinated approach. Generally, LHAs lead on single-family dwellings and most HMOs, while FRAs lead on hostels, hotels, and multi-occupied accommodation owned by the LHA.

2. The Fire Risk Assessment (FRA) Process

Both documents emphasize that fire safety must be dictated by a methodical FRA. The process follows five essential steps:

1. Identify fire hazards: Look for sources of ignition (heat), fuel (combustibles), and oxygen.

2. Identify people at risk: Pay particular attention to those especially vulnerable, such as people asleep, disabled persons, children, or lone workers.

3. Evaluate, remove, or reduce risk: Prioritize removing hazards before implementing protective measures like alarms or fire doors.

4. Record, plan, inform, and train: Record significant findings (mandatory for premises with five or more employees or those that are licensed), develop an emergency plan, and provide training.

5. Review: Revise the assessment if there are significant changes to the building’s use or layout, or after a "near miss".

3. Fire Hazards and Preventative Measures

The foundational strategy for prevention is the systematic separation of flammable materials from ignition sources.

Housekeeping and Storage Effective housekeeping reduces the likelihood of fire and prevents escape routes from being blocked. Combustible waste must be removed regularly and stored in suitable containers; external wheeled bins should be secured at least 6 metres away from the building to prevent arson. High-risk areas like laundries require regular cleaning of exhaust filters to prevent lint fires. In kitchens, extraction ducting and grease traps must be cleaned to prevent fat fires.

Equipment and Dangerous Substances

• Heating: Fixed convector or fan heaters are preferred over radiant or naked-flame heaters.

• Electrical Safety: Faulty equipment is a leading cause of accidental fires; all portable appliances should undergo Portable Appliance Testing (PAT), and fixed installations must be inspected every five years by a competent engineer.

• Dangerous Substances: Highly flammable liquids (e.g., solvents) should be kept to a minimum (up to 50 litres in a fire-resisting cabinet). LPG cylinders must be stored upright in well-ventilated locations away from ignition sources.

Structural and Management Controls Owners must control "hot work" (e.g., welding) through a permit-to-work system to ensure monitoring for at least an hour after work finishes. Arson prevention measures include well-lit perimeters, secure letterboxes with metal containers on the inside, and removing entry rights for dismissed staff.

4. Automatic Fire Detection and Warning (AFD)

Early warning is vital because sleepers are slow to respond and easily disorientated. Systems are graded from A to F based on complexity, and levels of coverage (LD1 to LD3) denote which rooms are protected.

• Grade A Systems: Include a central control panel, manual call points, and interconnected detectors; these are standard for larger HMOs of five or six storeys.

• Grade D Systems: Consist of mains-powered smoke alarms with integral battery backup, interlinked to sound throughout the property.

• Recommended Coverage: For most normal-risk houses of up to four storeys, an LD3 system (detectors in escape routes only) is the benchmark. Bedsit HMOs often require a mixed system to prevent false alarms: interlinked heat detectors in rooms and smoke detectors in escape routes, with a separate non-interlinked smoke alarm in each bedsit to protect the sleeper.

  
  

Manual call points should be red, fitted at 1.4m height, and positioned so that no one has to travel more than 45m to reach one. Systems must be tested weekly (activating a different call point each time) and professionally serviced every six months.

5. Fire Separation and Compartmentation

Compartmentation restricts the spread of fire and smoke from one unit of accommodation to another.

Structural Benchmarks The standard for fire resistance in normal-risk residential buildings is 30 minutes for walls, floors, and ceilings. However, 60 minutes of separation is required between commercial and residential uses, above high-risk boiler rooms, and between basements and ground floors. Any breaches in fire-resisting partitions for services (pipes, cables) must be fire stopped with proprietary products.

Fire Doors Fire-resisting doors (specified as FD30S) are essential in partitions enclosing protected routes. They must be fitted with intumescent seals (which expand when heated) and smoke seals (to restrict cold smoke). In multi-occupied buildings, these doors must be fitted with approved self-closing devices to ensure they engage their latches. Existing solid timber or panelled doors may be acceptable in lower-risk, two-storey properties if they are sound and close-fitting.

6. Escape Routes and Design Principles

Occupants must be able to reach a place of ultimate safety unaided.

Travel Distances Suggested travel distances are benchmarks based on risk level. In normal-risk premises:

• Bedroom to a protected route: 9m.

• Single direction of travel (e.g., dead ends): 18m.

• More than one escape route provided: 35m.

Inner Rooms and Galleries An "inner room" (where the only escape is through another room) is hazardous. It is only acceptable if it is not used for sleeping (unless AFD is in the access room), accommodates no more than 60 people, and has a vision panel or a 500mm ceiling gap for smoke visibility. Galleries must have at least 50% of the floor area unobscured and be situated close to the room exit.

Escape Windows In low-risk houses of no more than two storeys, escape windows from first-floor rooms may be an alternative to a protected route. To be acceptable, they must have an unobstructed openable area of at least 0.33m² (min 450mm height and width) and be no more than 1.1m above the floor.

Stairways and Basements Protected stairways should lead directly to a final exit. External stairways must be protected by fire-resisting glazing for any windows or doors within 1.8m horizontally or 9m vertically. Basements used by more than 60 people or containing high risks require at least two protected escape stairways.

7. Firefighting Equipment and Fixed Facilities

Portable Equipment For Class A risks (wood, paper), provide one water-based extinguisher for every 200m² of floor space, with a minimum of two per floor. Extinguishers should be located on escape routes near exits, with a max travel distance of 30m. Fire blankets should be provided in all kitchens and mounted 1.5m high.

Fixed Installations Automatic water suppression systems (sprinklers) are highly effective. Their installation can allow for "design freedoms," such as relaxed requirements for fire separation or extended travel distances, though AFD requirements can never be relaxed. Taller buildings (over 18m) require firefighting shafts and lifts, rising mains, and smoke control systems to assist the fire and rescue service.

8. Emergency Infrastructure: Lighting and Signage

Emergency Escape Lighting Required for internal routes without windows, windowless toilets over 8m², or areas used during darkness. In most residential settings, a three-hour duration (NM/3) non-maintained system is appropriate. Maintenance includes a monthly function test and an annual full discharge test.

Signs and Notices Directional escape signs must be pictograms; text-only signs are not compliant. In simple houses, signage is usually unnecessary, but in larger HMOs with complex layouts, signs must lead occupants to the final exit. Mandatory notices include "Fire door - keep shut" labels and "Fire Action" notices detailing emergency procedures, often posted on the back of bedroom doors.

9. Management, Maintenance, and Training

Good management ensures that physical precautions remain effective over time.

Record Keeping A dedicated log book should record all maintenance, tests, and drills. This should include details of significant FRA findings, false alarms, and PAT testing results. If five or more people are employed, significant findings must be legally recorded.

Training and Drills All staff must receive induction training and regular refreshers covering alarm recognition, escape routes, and the importance of fire doors. Fire Marshals require advanced training in search procedures and liaising with the fire service. Fire drills should be held at least annually to test the emergency plan and identify weaknesses in the evacuation strategy.

Ongoing Maintenance (LACORS Checklist)

• Daily: Check escape routes are clear and fire alarm panels show "normal".

• Weekly: Test a different manual call point and check fire extinguishers.

• Monthly: Test emergency lighting and check fire door seals.

• Six-monthly: Have the fire alarm system serviced by a competent person.

• Annually: Conduct a full discharge test of emergency lighting and a professional service of all extinguishers.

10. Case Studies of Residential Premises (LACORS focus)

Single Household Occupancy (1-4 storeys) Standard houses do not require a full 30-minute protected route if they have sound conventional construction and interlinked AFD (Grade D, LD3). Escape windows can provide a secondary route from first-floor bedrooms.

Shared Houses Defined as houses let to an identifiable group (e.g., students) as joint tenants with exclusive possession of the whole property.

• Two Storeys: Require interlinked AFD in escape routes, kitchens, and lounges.

• Three Storeys: Generally require 20-30 minutes of fire resistance for escape routes and solid, self-closing doors.

Bedsit-Type HMOs Lettings where occupants live independently with their own cooking facilities.

• Risk Profile: Highest risk due to independent living.

• Protection: Mandatory 30-minute protected route and FD30S doors.

• AFD: Mixed systems are standard to ensure local warning for sleepers without triggering whole-house false alarms from cooking.

Buildings Converted to Flats Converted buildings that do not meet 1991 Building Regulations require 30 minutes of fire separation between units. A mixed AFD system is recommended: a whole-house Grade A system with heat alarms in flats interlinked to common parts, and a separate Grade D smoke alarm within each flat for life safety.

Back-to-Back Houses These present a higher risk because they have only one exit, and the route often passes through a risk room. Solutions rely on suitable escape windows from the first floor and 30-60 minutes of fire separation across the staircase to protect upper floors from ground-floor fires.

By following the structured guidance from the DCLG and LACORS documents, owners and managers can create a robust fire safety strategy that accounts for the specific structural risks and occupancy patterns of their residential buildings, ensuring both legal compliance and the protection of lives

Whilst every effort has been made to ensure the information within these pages are accurate and not misleading, LESH Consulting Ltd cannot accept any liability for any loss or liability arising from the use of any such information.