Whilst a fire risk assessment process, hazards, people at risk and the evaluation of these risks will be highly specific to the premises at hand, this article aims to give a broad overview of the key considerations for providers of sleeping accommodation.
What is a fire risk assessment?
Landlord's have a legal duty to ensure that their rented property is safe from fire. A fire risk assessment is evidence that you have fulfilled your responsibilities.
Without one, you could be open to claims if there was a fire. What’s more, landlords of houses in multiple occupation (HMOs) are legally obliged to carry out fire risk assessments.
By conducting a fire risk assessment of your private or social rental accommodation you will be able to determine what the chance is of a fire starting, and any dangers to those in the immediate vicinity.
The assessment will be a methodical look at the premises, the activities carried out there and the likelihood that a fire could start and cause harm to those in and around the premises.
The aims of the fire risk assessment are unanimous:
- Identify any fire hazards
- Reduce the risk of those hazards causing harm to as low as reasonably practicable
- Decide what physical fire precautions and management arrangements are necessary to ensure the safety of people in the premises if a fire doesstart.
Who conducts a fire risk assessment?
In England and Wales the person who has the duty to comply with the Fire Safety Order and conduct a fire risk assessment is called the Responsible Person. This person has an absolute duty to comply with legislation.
In the case of blocks of flats and houses in multiple occupation, the fire safety legislation applies to common or shared parts. In these cases the responsibility for fire safety usually rests with the landlord who is responsible for conducting the fire risk assessment.
If there is more than one responsible person, you will have to work together to meet your responsibilities. If you are a responsible person but do not possess the necessary skillset to conduct the fire risk assessment, you will need to ask a ‘competent person’ to carry out that fire risk assessment on your behalf (e.g. someone with the necessary training/skills).
What legislation applies to you?
One of the problems for fire safety in sleeping accommodation is that there is often an overlap between two enforcing authorities: the local housing authority (1) and the local fire and rescue service (2). As a result, there are two types of risk assessment to consider for England and Wales:
(1) Housing Act 2004, which introduced the Housing Health and Safety Rating System
(2) *Fire Safety Order 2005. Responsibility for complying with the Order rests with the ‘responsible person’ (person who has control of the premises) who needs to carry out fire risk assessments in the common areas of HMOs, flats, maisonettes and sheltered accommodation (but does not apply to individual dwellings).
*This has been outlined in FireAngel’s interview with Ceri Flavell if you’d like to learn more.
Before undertaking a risk assessment, it is best practice to read the Local Authorities Coordinators of Regulatory Services (LACORS) guidance (2008). This offers guidance for landlords and fire safety enforcement officers in both local housing authorities (LHAs) and in Fire and Rescue authorities (FRAs) on how to ensure adequate fire safety in different types of sleeping accommodation.
Fire Risk Assessment Checklist For Sleeping Accommodation
LACORS Part B outlines the principles and methodology of fire risk assessment. This is particularly aimed at landlords, and follows the general methodology contained in HM Government Fire Safety Risk Assessment Sleeping Accommodation Guide.
The general 5 step risk assessment process is as follows:
1. Identify the fire hazards
3 things are needed for a fire to start - a source of ignition, fuel, and oxygen. You can reduce the chances of a fire occurring by ensuring that these do not come together.
Ignition - These could include cigarettes, matches, candles, portable heaters and cooking equipment.
Fuel - anything that burns. Common sources of fuel are furniture, soft furnishings, flammable liquids, paper and waste products. It is particularly important to identify sources that could cause a fire to spread to another fuel.
Oxygen - typically in the air around us, however it can also come from other sources. For instance, certain chemicals release extra chemicals when they burn (these will be marked with an ‘Oxidising’ label), as do some fireworks.
2. Identify people at risk
Any persons who are in and around the premises should be considered at risk, but there will be some people who require particular attention. These people who are at additional risk include:
- People who are asleep
- People with disabilities
- Employees who work alone or in isolated conditions
3. Evaluate, remove or reduce the risks
Evaluate - To evaluate the risk of a fire occurring, look at the premises and try to identify any instances where an accident could occur. There are three main ways in which a fire could start that you should bear in mind:
- Accidentally (e.g. by leaving on a gas hob)
- By an act or an omission (e.g. when electrical equipment isn’t maintained)
You’ll also need to consider the risk to people within the building being able to safely escape. For instance, if a fire starts on the lower floor of a building, does it affect the escape route for those on the upper floors?
Remove and reduce
Once you have identified these risks, there are various ways that you can remove or reduce these risks. Introducing a safe smoking policy in designated areas and ensuring that combustible items are stored away from potential ignition sources are two ways that you can do this (for more, refer to pages 17-19 of the Sleeping Accommodation Guide).
Depending on the kind of sleeping accommodation in question, the fire detection and warning systems differ. However, unanimously:
The fire detection system should comply with BS 5839: Pt 6.
Have appropriate fire fighting equipment - e.g. having an adequate number of portable extinguishers around the premises - although the FRS would never advise tenants tackling a fire themselves.
Escape routes need to remain usable and hazard-free at all times.
To determine whether your current routes are adequate, you should consider:
- The number of people in the premises
- The age and construction of the premises
- The escape time, and the number and complexity of escape routes/exits
- Assisted means of escape
- Whether lifts can be used
- Assembly points
- Emergency escape lighting
Are there clear signs and notices? These will include the actions to be taken in the event of a fire.
When will regular checks be carried out? E.g. escape routes and fire detection systems - these need to be carried out by a competent person
4. Record your findings, prepare an emergency plan and provide training
When the fire risk assessment has been taken you need to:
Record details of any hazards identified, and what you will do to reduce those risks
Prepare an emergency plan for dealing with any fire situation and include this in your records.
(This must be shared with all relevant persons and be available for any enforcing authorities so that it is clear what steps must be taken)
Share your emergency plan - e.g. via notices in bedrooms up or within tenancy agreement
If there are numerous owners involved in the building, you must liaise with them to coordinate safety measures so that the working practices of one does not negatively affect the other.
5. Review and update the fire risk assessment regularly
Finally, you should be constantly monitoring your findings to assess how effectively the measures are working. Most notably:
If there have been any significant changes to the premises or anything that suggests the assessment may be no longer valid, then you should review and revise where necessary.
Examples include: changes in how the premises are used, building alterations, reported problems or the presence of people with a disability that may affect their safe escape.
A more detailed guidance of the above 5 steps can be found in LACORS or Fire safety risk assessment: sleeping accommodation. Additionally, gov.uk provide a fire safety risk assessment chart which gives some more information that you can print off and use as a checklist.
What type of fire detection system to install?
The greater the risk of fire, the higher the level of fire safety system that should be installed. BS5839-6:2013 identifies the grades of alarm systems so you can identify which is most appropriate in your premises.
Once you have identified which grade of alarm system your property requires on the yellow grade scale, there are three categories relating to the level of protection that should be applied.
LD1 - Maximum Protection
- Alarms installed in all areas where a fire could start, for instance hallways, landings, living room, bedrooms and kitchens but not bathrooms, shower rooms or toilets.
LD2 - Medium Protection
- Alarms installed in escape routes and high risk areas such as hallways and kitchen/living room.
LD3 - Minimum Protection
- Escape routes such as hallways and landings.
Best practice would be to install Category LD2, but if you have any areas in your premises where the risk of a fire is high then LD1 needs to be considered.
Other assessment guides
You can download the following guides on risk assessments in:
- offices and shops
- factories and warehouses
- sleeping accommodation
- residential care premises
- educational premises
- small and medium places of assembly (holding 300 people or less)
- large places of assembly (holding more than 300 people)
- theatres, cinemas and similar premises
- open air events and venues
- healthcare premises
- animal premises and stables
- transport premises and facilities
You can also find guidance on: