Fire precautionary facilities and fire safety
Owners of HMOs are responsible for ensuring adequate fire safety measures to protect all occupiers. The regulations specify the following:
Appropriate fire precaution facilities and equipment must be provided of such type, number and location as are considered necessary.
Brief guide to HMO fire safety
HMOs can comprise a wide range of property types, occupancy arrangements and occupier type. Fire risks in HMOs can be complex and it is not always possible to offer a single solution to fire safety which can be applied broadly.
Fire safety solutions must instead be based on the level of risk at a particular property. Local authority officers will assess the property during any inspection using the LACoRS ‘HOUSING – FIRE SAFETY’ national guidance, to ensure the guidance has been applied.
You can read the LACoRS document online [PDF].
If an HMO meets the relevant standards in this guidance, the local authority should be satisfied that the HMO is reasonably suitable for occupation in terms of fire safety.
For HMOs with a common-way escape route (usually in bedsit-type shared houses, bedsits and Section 257 HMOs), owners should also have regard to the Regulatory Reform (Fire Safety) Order 2005 and the related Fire Safety Risk Assessment Sleeping Accommodation Guide.
The following information may be of use when interpreting what fire safety measures to provide to meet the recommendations in the LACoRS guidance. It is therefore imperative that the property usage is correctly identified so that the appropriate measures are put in place. Incorrectly identified properties may require additional works which could be expensive to complete if undertaken retrospectively. A change in the occupation type of a property, e.g. shared house to bedsit-type shared house, might also necessitate additional works to be undertaken.
Fire Risk Assessment
A suitable and sufficient Fire Risk Assessment is required which should be completed by a competent person, such as a fire risk assessor, and must be carried out in accordance with the Regulatory Reform (Fire Safety) Order 2005 as well as having regard to the Fire Safety Risk Assessment Sleeping Accommodation Guide and the national LACoRS guidance. The Fire Risk Assessment must extend into each unit of accommodation as well as incorporating any communal areas. The Fire Risk Assessment should be reviewed on an annual basis and any changes documented.
General fire safety principles
The fire safety approach adopted in the LACoRS guidance is to provide early warning of any fire to all occupiers and to ensure that they can safely evacuate the building to a place of safety.
The following information is taken from the LACoRS guidance document;
The usual escape route for HMO properties will be down the main staircase and out the front door. Therefore, this staircase and any associated halls and landings should be protected from fire as follows:
The doors to rooms leading onto the escape route, including bedroom doors, should be self-closing fire doors complying with BS EN 1154:1997 (e.g. hydraulic overhead closers), normally 30-minute fire resisting, fitted with intumescent strips and cold/brush smoke seals, hung on 3x steel hinges and should latch properly into the frame. Room door locks should normally be of a thumb turn type, e.g. Yale 81 or 91, on the inside.
(Cold/brush smoke seals restrict the passage of smoke and intumescent strips expand during a fire to seal any gaps around the door)
In some situations where there may be a smaller shared house HMO, good quality, well-fitting, solid timber doors of a minimum thickness of 44mm may be acceptable. The inspecting officer will advise accordingly.
The partitions separating rooms from the escape route should be fire-resisting, normally to a 30-minute standard. Similarly, the partitions between rooms should be fire-resisting, normally to a 30-minute standard.
Low risk rooms
There is usually no need to provide protection to bathrooms and shower rooms or WC compartments which open onto protected routes, unless there is an electrical source sited within the room.
Escape route safety
The escape route should be kept free from obstructions such as bicycles, pushchairs, furniture and stored items, and be free from anything that could start or fuel a fire such as combustible materials, cookers, portable heaters, gas bottles and unenclosed gas or electric meters.
Cupboards in the escape route or cupboards under the stairs should be lined inside to provide 30-minute fire resistance, including the door. Where a source of ignition is present within the cupboard, the door should also be fitted with intumescent strips and cold/brush smoke seals and it may be necessary to install a smoke detector. A ‘Keep Locked Shut’ sign should be fitted to each cupboard door where access is not required.
Exit from the property
The main escape staircase should lead directly to a final exit without passing through another room. When occupants get to the front door, they need to be able to open it without the use of a key, card or code. This usually means providing a ‘thumb- turn’ device on the inside of the door to replace the internal key-operated device. A key is still used when entering the house from the outside. The exit should lead to a place of ultimate safety away from the building (i.e. not in an enclosed yard or garden).
Automatic fire detection
The presence of a properly installed and maintained automatic fire detection and warning system will alert occupiers to the presence of a fire in its early stages. It will also enable them to evacuate to a place of safety before the escape routes become blocked by smoke or are directly affected by fire. It should also announce the presence of a developing fire in any hidden areas such as storerooms and cellars.
All HMOs must have an automatic fire detection and alarm system in place.
Types of fire alarm
The type of alarm required will depend on the type of property, how it is occupied, the number of storeys and various other factors.
Grade A and Grade D systems (BS 5839) are the usual type specified for HMOs and sometimes circumstances demand the installation of both (known as a mixed system).
Grade A system:
- Generally only required in larger properties
- This system comprises a set of electrically operated smoke and/or heat detectors, separate sounders and manual call points. These are all linked to a control panel
- Alarm bells or electronic sounders should achieve a minimum sound level in bedrooms of 75 dBA when all doors are shut, to arouse sleeping occupants
Grade D1 system:
- Required in smaller properties
- This system has one or more interlinked, mains-powered smoke and/or heat alarms each with a tamper-proof integral battery standby supply
- The alarms are normally powered from the local lighting circuit
- There is no control panel with this system and maintenance is simpler
Grades of automatic fire detection and warning systems are specified in BS 5839: Parts 1 and 6.
Testing of fire alarm
A logbook should be provided in the property and should be made available for inspection by the council. The logbook should demonstrate that maintenance of the fire alarm includes annual and periodic tests in accordance with BS 5839: Parts 1 and 6.
Floors and ceilings
In addition to providing a protected escape route, it is necessary to restrict the spread of fire and smoke from one unit of accommodation to another.
In most premises, floor/ceiling separation between units of accommodation (and between units and the escape route) should provide a standard of fire resistance of 30 minutes. However, in high risk areas such as basements, cellars and in mixed use buildings where there is also commercial accommodation it should be 60 minutes.
Basements and lower ground floors
A fire in a basement or lower ground floor will spread to the ground floor and may prevent occupants from getting out the front door. Even if a fire does not spread to this area, it may become filled with smoke. Therefore;
- The fire separation between the basement and the ground floor (including the staircase soffit and spandrel) should be 30-minute fire resisting
- A 30-minute fire resisting door should be fitted at the top of the basement stairs and another at the foot of the basement stairs
- There should be a separate exit from the basement/lower ground floor rooms
Cellars and unoccupied basements
Even if unoccupied, a cellar may present an increased risk of fire due to the presence of electric and gas meters, items being stored and general neglect. Therefore, these areas should also be separated with 30-minute fire resistance from the rest of the house.
In some premises, emergency lighting is installed to light the escape route if mains power fails (BS 5266) and where there is no effective borrowed light.
Where emergency lighting is installed, a logbook should be provided in the property and should be made available for inspection by the council. The logbook should demonstrate that maintenance of the emergency lighting system, in accordance with BS 5266, has been carried out.
A room where the only escape route is through another room is termed an ‘inner room’. If this is a bedroom, this arrangement poses a risk to its occupier if a fire starts unnoticed in the outer room. This arrangement should therefore be avoided, though additional fire precautionary work may be possible in certain circumstances to overcome the risk; for example, use of emergency escape windows might be possible.
In some situations, escape through a window is permitted if it meets certain requirements for height from the ground and size of opening. It should also lead to a place of ultimate safety.
The LACoRS guide recommends the provision of fire extinguishers on all floors, however, local authorities do not normally require them. This is due to the need for training of occupants, for regular maintenance and problems with extinguishers being maliciously set off or played with.
In the early stages of a fire, the safety of a building’s occupants can be affected by the properties of surface linings and the finishes of walls, ceilings and soffits. Rapid spread of flame across surfaces allows the fire to spread more quickly through the building, thereby reducing the time for escape. There should be no highly combustible wall, ceiling or soffit surfaces in the escape route; for example, wood panelling or polystyrene tiles.
Mixed commercial and residential use
A fire occurring at night in commercial premises under or within a residential dwelling may not be noticed until well developed.
- There should be 60-minute fire separation between the two uses; and
- Automatic fire detection in the commercial parts should be linked to the residential system
Fire resistance of furnishings
All soft furnishings supplied by the landlord to tenants must comply with the relevant safety tests as prescribed under the Furniture and Furnishings (Fire) (Safety) Regulations 1988 (as amended). All furniture must be labelled to show that it complies with these tests. These labels must not be removed.
Advice on fire and furnishings may be sought from Trading Standards; telephone 01243 777100.
Management and maintenance of fire safety
Whatever physical fire safety measures are provided in residential accommodation, their effectiveness will only be as good as their management and maintenance.
HMO accommodation will require ongoing attention to ensure fire safety measures remain effective.
Tenants’ obligations – means of escape from fire
Tenants are expected to take some responsibility for fire safety and maintenance of fire precautions within the property, for example;
- tenants should not wedge open fire doors
- over-door hooks, hangers or heavy items that prevent the door from properly closing or which distort the door, should not be hung on the doors
- smoke and/or heat alarms/detectors should not be covered, and nothing should suspend from the ceiling that might interfere with activation of an alarm or detector
- the landlord or agent should be notified of a fault with the alarm system or damage and disrepair to any fire safety measures
- tenants should not block halls and corridors with stored items, bicycles, furniture etc.
- tenants should minimise the risk of false alarms by opening windows or using mechanical ventilation when cooking
- candles and open flames should always be used with caution