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HOUSING – FIRE SAFETY
Guidance on fire safety provisions 
for certain types of existing housing




Foreword by Communities and Local Government ministers
Fire safety within the home is an extremely important issue, especially 
in mixed use premises and where unrelated occupiers, who live 
independently from one another, share common areas of the same 
building. This area of law is covered by both the Housing Act 2004 
and the Regulatory Reform (Fire Safety) Order 2005.
We welcome this guidance which helps to manage the relationship 
between the Housing Act 2004 and the Fire Safety Order by offering 
advice and assistance to enforcers, landlords, managing agents and 
tenants, amongst others, on ways to make residential buildings safe 
from fire, regardless of which piece of legislation is relevant. When it 
comes to fire safety, everyone involved has an interest.  
So we would encourage all those with an interest in these types 
of premises to read this guidance, ensure they are aware of their 
responsibilities to carry out a fire risk assessment, and make sure their 
property has adequate and appropriate fire safety measures in place.
Iain Wright MP
Parmjit Dhanda MP
Under Secretary of State 
Under Secretary of State with 
with responsibility for housing
responsibility for fire safety
 
housing – fire safety
1

Contents
Acknowledgements
Part D: case studies of practical fire safety solutions in 
various catagories of premises 
36
Part A: introduction 
4
33. Introduction 
36
1.  Purpose of guidance 
4
34. Single household occupancy buildings 
37
2.  Scope of this guidance 
5
35. Shared houses 
39
3.  Intended readership and layout of the 
36. Bedsit-type HMOs (lets) 
43
  guidance 
6
37. Buildings converted into self-contained 
  flats 
46 
Part B: fire risk assesment 
7
38. Flats in multiple occupation 
49
4.  Introduction 
7
39. Back-to-back houses 
50
5.  What is fire risk assessment? 
7
6.  Suggested method for carrying out fire 
Appendix 1: legislation and statutory guidance  52
  risk assessment 
7
A.7 The Housing Act 2004: part 1 – housing health 
and safety rating system 
52
Part C: general principals of fire risk reduction  10
A.31 The Housing Act 2004: part 2 – licensing of 
7.  Introduction 
10
houses in multiple occupation  
55
8.  General fire safety principles 
11
A.45 Management of Houses in Multiple Occupation 
9.  Escape routes 
11
Regulations 2006 
59
10. Habitable basements 
14
A.51 The Regulatory Reform (Fire Safety) Order 
11. Unoccupied basements/cellars 
14
2005 
59
12. Inner rooms 
15
A.61 The Furniture and Furnishings (Fire) (Safety) 
13. Galleries 
15
Regulations 1988  
61
14. Escape windows 
16
A.67 The Gas Safety (Installation and Use) Regulations 
15. Protected routes/stairs 
16
1998 
61
16. Exit doors 
18
A.73 Electrical Equipment (Safety) Regulations 
17. Secondary means of escape 
18
  1994 
62 
18. External stairways 
19
19. Fire separation/compartmentation 
19
Appendix 2: Protocol between local housing 
20. Floor/ceiling partitions 
21
authorities and fire and rescue authorities to improve 
21. Fire doors 
21
fire safety 
63
22. Automatic fire detection and warning systems 
Appendix 3: Example form for recording significant 
(AFD) 
23
findings from the fire risk assessment 
70
23. Lighting of escape routes 
26
24. Emergency escape lighting 
27
Glossary 
71
25. Fire fighting equipment (portable) 
28
Some useful fire safety terms
26. Automatic water suppression systems 
29
Bibliography 
74
27. Fire safety signage 
30
28. Surface finishes 
31
Further acknowledgements 
76
29. Floor coverings 
32
 
30. Special provisions relating to back-to-back 
  houses 
32
31. Mixed commercial and residential use 
33
32. Management and maintenance of fire 
  safety 
33
2
housing – fire safety

Acknowledgements  
LACORS extends particular thanks to Kevin Thompson, 
author of this guidance and would also like to express its 
sincere appreciation to the following who made significant 
contributions:
The Chartered Institute of Environmental Health (CIEH) 
with particular thanks to Andrew Griffiths
The Chief Fire Officers Association (CFOA) with particular 
thanks to Paul Dryden,
Communities and Local Government, with particular 
thanks to Brian Martin and Rhian Blackman. 
DASH (Decent and Safe Homes, East Midlands) with 
particular thanks to Martin Brown of Derby City 
Council,
The National HMO Network Steering Group, with 
particular thanks to John Venables.
The National Landlords Association (NLA) with particular 
thanks to Elizabeth Brogan
The Yorkshire Fire and Rescue Authorities and Local 
Authorities with particular thanks to Paul Rotherham
In preparing this guidance, LACORS wish to make it clear 
that:
  (i) Legislation may change over time and the advice    
given is based on the information available at the  
time the guidance was produced. It is not necessarily 
comprehensive and is subject to revision in the light of 
further information; 
  (ii) Only the Courts, the Residential Property Tribunal or 
Lands Tribunal can interpret statutory legislation with 
any authority; and 
  (iii) This advice is not intended to be a definitive 
guide to, nor a substitute for, the relevant law and 
independent legal advice should be sought where 
appropriate.
 
housing – fire safety
3

Part A:  introduction
solutions which will comply with that framework. The 
regulatory framework is summarised in paragraphs 
1.6-1.8 and a more comprehensive explanation is 
1.  Purpose of this guidance 
offered in Appendix 1.
1.1  This document contains guidance for landlords 
1.5  The guidance will be kept under review and further 
and fire safety enforcement officers in both local 
guidance may be issued. Any comments or enquiries 
housing authorities (LHAs) and in fire and rescue 
should be addressed to LACORS at housing@lacors.
authorities (FRAs) on how to ensure adequate fire 
gov.uk. Please note that LACORS will be unable to 
safety in certain types of residential accommodation. 
respond to queries from individual landlords and 
It offers practical advice on fire risk assessment and 
managing agents. Landlords with queries about fire 
contains case studies with suggested fire safety 
safety regulation should contact their local council or 
solutions. Appendix 1 provides an overview of the 
fire and rescue authority.   
legal framework in relation to fire safety, but landlords 
should be able to comply with fire safety requirements 
without a detailed knowledge of the legal framework. 
1.6   The Housing Act 2004 brought in a new system 
Where necessary, advice on enforcement matters 
of regulation for fire safety in existing residential 
can be sought from the LHA, FRA or appropriate 
premises by way of the housing health and safety 
landlord associations. The content of this document 
rating system (HHSRS), licensing provisions for houses 
is intended as guidance only. Definitive interpretation 
in multiple occupation (HMOs) and management 
of the legislative requirements can only be made by 
regulations for HMOs. In practice the HHSRS is the 
the relevant court or tribunal. The guidance applies 
principal tool used to assess and regulate fire safety 
to England, but Welsh statutory requirements are 
standards, but HMO licensing conditions will reflect 
very similar and so the general guidance on fire risk 
HHSRS assessments. The responsible person for the 
assessment may also be relevant in Wales.
purposes of fire safety provision and maintenance at 
the residential accommodation is the person having 
control – usually the landlord, or alternatively in HMOs 
1.2  This guidance does not introduce new standards or 
the manager. Previous fire safety guidance for HMOs 
regulations but builds upon existing good practice 
contained in the Department of Environment Circular 
and guidance currently in place around the country. 
12/92 has been withdrawn.
It aims to provide landlords and enforcing officers 
with assistance in complying with the legislative 
requirements in a consistent and reasonable manner. 
1.7  Alongside the Housing Act 2004, the Regulatory 
The guidance was subject to an extensive consultation 
Reform (Fire Safety) Order 2005 (FSO) introduced 
exercise and the final content has received input from 
duties in relation to fire safety in the common areas 
a large number of LHAs, FRAs and landlords as well 
of HMOs note 1, flats, maisonettes and sheltered 
as Communities and Local Government and the Chief 
accommodation in which personal care is not 
Fire Officers Association.
provided. The duty is placed on the responsible 
person, who is required to carry out a fire risk 
assessment and take specific action to minimise the 
1.3  This document does not set prescriptive standards 
risk of fire in the common parts. ‘Responsible person’ 
but provides recommendations and guidance for 
means “the person who has control of the premises in 
use when assessing the adequacy of fire precautions 
connection with the carrying on of a trade, business or 
in these types of premises. Alternative fire risk 
other undertaking”. In practice this will usually be the 
assessment methods may be equally valid in order 
landlord, but in the case of absentee landlords where 
to comply with fire safety law, and alternative 
the “carrying on of the business” is undertaken by a 
approaches to individual fire safety solutions may be 
managing agent it may be the managing agent. These 
acceptable.
provisions are enforced by fire and rescue authorities.
1.4  There is currently no national guidance available to 
 
note 1: the order will not apply to some HMOs which 
landlords to help them understand and comply with 
are occupied as ‘shared houses’ – see paragraph 35 
the regulatory framework. This document aims to 
for further guidance.
provide that assistance. It also offers guidance to 
enforcing officers on both the regulatory framework 
itself and on recommendations for some fire safety 
4
housing – fire safety

1.8  There is therefore a dual enforcement regime in 
• single household properties; 
place in multi-occupancy premises. In order to avoid 
• shared houses; 
duplication and the potential for conflict, the Fire 
• bedsit HMOs; 
Safety Protocol established a framework for joint 
working arrangements between these two sets of 
• purpose-built flats and buildings converted into self- 
authorities and is being adopted locally around the 
contained flats to a standard not in compliance with  
country to good effect. The protocol is included in 
the Building Regulations 1991; 
this guidance at Appendix 2. In premises occupied by 
• sheltered accommodation in which personal care is  
single households, only the HHSRS (housing health 
not provided; and
and safety rating system) will apply.
• small hostels to which the HM Government Sleeping  
Accommodation Guide is inappropriate (application  
1.9  Guidance to fire and rescue authorities under the 
will be determined by the LHA and FRA jointly under  
FSO has been issued in the HM Government Fire 
the terms of the Fire Safety Protocol).
Safety Risk Assessment Sleeping Accommodation 
Guide, published by Communities and Local 
2.2  It should be noted that the guidance applies to the 
Government (CLG) in May 2006. Guidance for local 
above types of premises regardless of tenure (i.e. 
housing authorities under the Housing Act 2004 is 
whether owner-occupied, social housing or private 
contained in the HHSRS Operating Guidance and 
rented sector). 
HHSRS Enforcement Guidance, both issued by CLG 
in February 2006. In order to underpin the fire safety 
2.3  This guidance does not apply to properties 
protocol and offer practical guidance to enforcing 
constructed or converted to a standard in compliance 
authorities and landlords, several local and regional 
with the Building Regulations 1991 or later (and which 
guides have also been developed around the country. 
still comply). Buildings converted and maintained to 
Some excellent work has been done in this respect, 
a standard meeting those regulations will not require 
but it has been widely recognised that a single set 
additional fire safety measures unless occupied in 
of national, risk-based guidance is needed to bring 
a manner other than intended under the original 
together and build upon this regional work and inform 
construction or conversion scheme (for example 
LHAs, FRAs and landlords in their application of fire 
occupation of a single household flat as a flat in 
safety solutions. Such guidance will help to simplify 
multiple occupation or where some other additional 
the dual enforcement approach and bring some 
risk has been subsequently introduced). Where a 
national consistency. However, it should be noted that 
building did comply but has deteriorated significantly 
housing design varies across the country and there 
through lack of maintenance, damage or other 
are certain types of houses specific to certain regions 
alteration then it may require additional measures 
which require a specialist solution. In such cases, 
and this guidance should be applied. Where building 
local guidance may be more comprehensive that that 
regulation standards are subsequently raised it is 
contained in this guide.
not currently envisaged that further works would be 
 
necessary.
 
LACORS has produced this guidance in partnership 
with the Chief Fire Officers Association and the 
2.4  This guidance is also not intended to apply to:
Chartered Institute of Environmental Health in order 
to meet the above objectives. The guidance has 
• guest houses and bed and breakfast accommodation 
undergone extensive consultation and received input 
used by tourists/visitors. However, this type of 
from many LHAs, FRAs and landlord associations 
accommodation is sometimes used to accommodate 
as well as individual landlords, housing and fire 
single homeless persons as their sole home. In such 
professionals.
cases this guidance may apply and the terms of the 
 
Fire Safety Protocol should be adhered to determine 
enforcement responsibilities (see Appendix 2); 
2.     Scope of this guidance 
• hotels and motels;
• large hostels for which the HM Government Suite 
2.1  This fire safety guide is intended for buildings which 
of Guidance is more appropriate (see note in 2.1 
have been constructed or adapted for use as domestic 
above);
dwellings, and covers a range of existing residential 
• refuges such as family accommodation centres and 
premises including:
halfway houses;
housing – fire safety
5

• residential health and beauty spa centres;
3.2  The guidance is laid out as follows:
• residential conference, seminar and training centres;
 
Part A: the introduction should be read by everyone 
• student halls of residence (including those managed 
using the guide as it lays out the purpose, scope 
by commercial providers) and areas of sleeping 
and application of the guidance and the intended 
accommodation in other training institutions 
readership.
including military barrack-style quarters;
• areas of buildings in boarding schools that provide 
 
Part B: outlines the principles and methodology of fire 
sleeping accommodation;
risk assessment. This is particularly aimed at landlords 
• seminaries and other religious colleges;
and is intended to offer them guidance and assistance 
in a simple format in order to de-mystify the fire risk 
• sheltered accommodation where personal care is 
assessment process. It may also be useful to new 
provided;
enforcement officers or those returning to this area of 
• residential care homes;
work.
• holiday chalets and complexes, camping and 
caravan parks (except privately owned individual 
 
Part C: outlines the general principles of fire safety 
units); and 
in residential accommodation. This part informs 
• areas in workplaces where staff ‘sleeping-in’ is a 
the reader how various fire safety precautions may 
condition of employment or a business requirement, 
be applied to reduce risk, and is a useful guide to 
as in hotels; but not including tied accommodation 
all readers as it explains why the various fire safety 
such as separate flats, houses, apartments, HMOs 
precautions are recommended.
and accommodation above pubs.
 
Part D: offers example case studies for various types 
 
These types of accommodation fall under the 
of premises. The studies are intended to bring the 
Regulatory Reform (Fire Safety) Order 2005 and 
principles in Part C to life. The studies given are 
detailed fire safety guidance for them is contained 
examples of fire safety solutions. Other solutions may 
in the HM Government Fire Safety Risk Assessment 
be equally valid. The studies must not be used as 
Sleeping Accommodation Guide.
‘off-the-peg’ solutions and should always be read in 
conjunction with Part C.
3.  Intended readership and layout of the guidance 
 
The appendices are intended as a reference source for 
all readers and include:
3.1  This guidance is aimed at those who manage, give 
• a detailed explanation of the regulatory framework 
advice, enforce standards or live in existing residential 
for fire safety;
accommodation falling within the scope of this guide. 
• the Fire Safety Protocol which establishes the 
 
principles and describes the joint working 
 
Typically this will include:
arrangements between LHAs and FRAs; and
• private sector housing providers (landlords);
• an example form for recording the findings of 
the fire risk assessment which landlords may find 
• social housing providers;
particularly useful. 
• managing agents or facility managers;
• enforcement officers in local housing authorities;
 
The glossary is intended as a plain English guide to 
• enforcement officers in fire and rescue authorities;
some terms used in the guidance. 
• advice agencies;
• residential leaseholders;
 
The bibliography offers sources of further reading for 
• owner-occupiers (where appropriate);
those seeking greater detail or researching the source 
• freeholders (where appropriate); and
of some of the guidance. 
• tenants in the accommodation types covered by the 
    
guidance (where they have an enquiry or dispute 
relating to fire safety standards in their home).
6
housing – fire safety

Part B: Fire risk assessment
5.  What is a fire risk assessment?
4.  Introduction 
5.1  A fire risk assessment is an organised and methodical 
look at the premises, the activities carried on there and 
the likelihood that a fire could start and cause harm to 
4.1  Where it applies the Regulatory Reform (Fire Safety) 
those in and around the premises.  
Order 2005 (FSO) places a duty on the responsible 
person to take general fire precautions to ensure, 
as far as is reasonably practicable, the safety of 
5.2  Most premises covered by this guide will be relatively 
the people on the premises and in the immediate 
small and will have a straightforward and simple 
vicinity. ‘Responsible person’ means “the person who 
layout, and little fire safety expertise is likely to be 
has control of the premises in connection with the 
required to carry out the risk assessment. In larger 
carrying on of a trade, business or other undertaking”. 
buildings or where the building contains different uses 
In practice this will usually be the landlord, but in the 
(for example, residential accommodation alongside 
case of absentee landlords where the “carrying on of 
or above a separate commercial use) then specialist 
the business” is undertaken by a managing agent it 
advice may be required.
may be the managing agent. 
 
5.3  The aims of the fire risk assessment are:
4.2  The responsible person must carry out a fire risk 
• to identify the fire hazards;
assessment for the purpose of identifying the general 
• to reduce the risk of those hazards causing harm to 
fire precautions and other measures needed to 
as low as reasonably practicable; and
comply with the FSO. Although under the FSO this 
• to decide what physical fire precautions and 
requirement only applies to the common parts of 
management arrangements are necessary to ensure 
premises, in practice the responsible person will need 
the safety of people in the premises if a fire does 
to take into account the entire premises – including, to 
start.
some extent, the units of accommodation themselves. 
While the FSO has limited application to certain types 
of property (see paragraph 35), the principles of fire 
5.4  The terms ‘hazard’ and ‘risk’ should be understood in 
safety risk assessment apply across the board, and 
the context of this guidance:
their application should ensure compliance with all the 
• hazard: anything that has the potential to cause 
legislation.
harm
• risk: the chance of that harm occurring.
4.3  Having identified the general fire precautions that 
are necessary and having implemented them, the 
responsible person must put in place a suitable system 
6.  Suggested method for carrying out a risk 
of maintenance and appoint competent persons to 
assessment 
implement any procedures that have been adopted. 
This could, for example, be a premises manager or 
agent, who need not necessarily be permanently on 
6.1  The guidance offered here follows the general 
the premises but would ensure that the responsible 
methodology contained in HM Government Fire Safety 
person’s duties were observed. 
Risk Assessment Sleeping Accommodation Guide, but 
alternative approaches may be equally acceptable.  
4.4  Guidance on fire risk assessments follows in this 
section. More detailed guidance can be found in HM 
6.2  The assessment method suggested in this guide shares 
Government Fire Safety Risk Assessment Sleeping 
the same approach as that used in general health 
Accommodation Guide, which is available on the CLG 
and safety legislation, and it can be carried out either 
website at www.communities.gov.uk/firesafety.       
as part of a more general risk assessment or as a 
separate exercise. 
6.3  The fire risk assessment should be carried out in a 
practical and systematic way and enough time must be 
allocated to the exercise. In some larger premises and 
those with mixed uses, it may be helpful to divide the 
housing – fire safety
7

building into rooms or a series of assessment areas using 
Things that will burn reasonably easily and are in large 
natural boundaries (for example kitchens, offices and 
enough quantity to provide fuel for a fire or cause it to 
stores; and corridors, stairways and external routes). 
spread to another fuel source are potential hazards. In 
premises covered by this guide they may include the 
6.4  The process can be broken down into five steps:
following, but this list is not exhaustive:
1. Identify fire hazards (paragraph 6.5).
2. Identify people at risk (paragraph 6.10).
• furniture, furnishings, textiles, bedding, clothing and 
curtains note 4;
3. Evaluate, remove or reduce risk and protect    
 against remaining risk 
• laundry;
note 2 (paragraph 6.14).
4. Record, plan and inform or train (paragraph 6.20).
•  accumulations of unwanted mail, waste paper, 
cardboard, newspapers and magazines (including 
5. Review (paragraph 6.25).
that awaiting recycling collection);
• waste storage and refuse containers;
 
note 2: Part D of this guidance contains various 
• flammable liquid-based products such as paint, 
example case studies which may help inform on 
varnish, thinners, adhesives, white spirit, methylated 
appropriate precautions to remove, reduce and 
spirit and cooking oils;
protect against risk.
• liquefied gas (LPG), paraffin, heating oils and petrol;
• paper products, packaging materials, stationery, 
6.5  Step 1: identify the hazards within the premises
advertising material and books;
• decorations for seasonal and religious occasions;
6.6  For a fire to start, three things are needed: a source 
• plastics and rubber such as videotapes, polyurethane 
of ignition, fuel and oxygen. If any one of these is 
foam-filled furniture and polystyrene-based display 
absent, a fire cannot start. Taking measures to avoid 
materials; and
the three coming together will therefore reduce the 
chances of a fire occurring.
• wall, floor and ceiling coverings and surface finishes.
 
6.7  Sources of ignition: identify potential sources of 
 
note 3: electrical and gas installations and appliances 
ignition, i.e. sources of heat which could get hot 
are subject to regulations which impose installation 
enough to ignite any materials around them. In 
and maintenance requirements (the Gas Safety 
premises covered by this guide they may include:
(Installation and Use) Regulations 1998 and the 
Electrical Equipment (Safety) Regulations 1994) (see 

• smokers’ materials such as cigarettes, matches and 
Appendix 1, paragraphs A.67 and A.73). Compliance 
lighters (if people smoke within the premises); 
with these regulations will reduce the risk presented 
• naked flames, for example candles and night lights;
by some of the items listed above.
• electric, gas or oil-fired heaters (fixed or portable);
• boilers;
 
note 4: furniture and furnishings are subject to the 
• cookers, toasters and other kitchen equipment 
Furniture and Furnishings (Fire) (Safety) Regulations 1988 
(especially when shared);
(see Appendix 1, paragraph A.61). Compliance with 
these regulations will reduce the risk these items present.

• faulty or misused electrical equipment;
 
• electric blankets, computers, TVs, washing machines 
and dryers;
 
Particular care should be taken when premises are 
undergoing alteration, repair or redecoration. During 
• lighting equipment (fixed and movable), for example 
such times flammable materials that would not 
halogen lamps and table lamps;
normally be present may be stored in the premises, 
• the electrical installation itself note 3;
possibly in escape routes or in rooms which are 
• the gas installation note 3;
otherwise unused. Care should be taken as to where 
• arson attack; and
and how these products are stored. Premises which 
• in larger or mixed use properties, any plant rooms, 
normally have good fire precautions and present a 
lift motor rooms and so on. 
low fire risk may have their fire safety compromised by 
temporary careless storage of these products or by the 
disabling of fire precautions during the period of the 
6.8  Sources of fuel: anything that burns is fuel for a fire. 
works.
8
housing – fire safety

6.9  Sources of oxygen: in premises covered by this guide 
• ensure electrical sockets are adequate in number 
the oxygen source will be the air in the building. 
and sited appropriately to avoid overloading and 
Where only normal natural domestic ventilation is 
trailing leads;
provided the risk will generally be normal.
• ensure electrical, mechanical and gas equipment 
is installed, used, maintained and protected in 
6.10 Step 2: identify people at risk
accordance with the manufacturer’s instructions; 
• ensure all furniture complies with the Furniture and 
Furnishings (Fire)(Safety) Regulations 1988;
6.11 It is necessary to identify those who will be at risk if 
there is a fire and where they are likely to be found. 
• ensure combustible items such as furniture, laundry 
In premises covered by this guide these will generally 
and decorations are stored properly and are kept 
be residents and their visitors and anybody working 
away from potential ignition sources such as 
in the premises such as a caretaker or cleaner and 
cookers, heaters and boilers;
any visiting contractors. Only in buildings with mixed 
• ensure refuse is properly stored and disposed of; and 
residential and commercial use are there likely to be 
• in crowded accommodation, provide adequate 
other people to consider. 
shelving and cupboard space so that everyday items 
are not in proximity to cookers, heaters and so on. 
6.12 The risk assessment should consider people at risk, 
who may include:
6.17 Having taken measures to remove or reduce fire 
• people asleep (who will be disorientated and slow to 
hazards as far as is practicable, arrangements need to 
respond);
be put in place to protect people from the remaining 
• people who are unfamiliar with the premises (guests 
fire risk as far as is reasonably possible by ensuring 
and visitors);
that adequate fire precautions are in place to warn 
people in the event of a fire and to allow them to 
•  people with disabilities (including mobility 
escape to a place of safety. 
impairment and hearing or vision impairment);
• people who may have some other reason for not 
being able to leave the premises quickly (such as 
6.18 The general principles of fire risk reduction are 
parents with young children); 
outlined in Part C, where guidance is also given on 
what measures should be implemented and to what 
• people who are sensorially impaired due to alcohol, 
standards, based on overall fire risk assessment. 
drugs or medication;
• unaccompanied children and young people;
• anyone working in enclosed, isolated parts of the 
6.19 Case studies of various types of premises and how 
building; and
these precautions could be employed to reduce fire 
risk are given in Part D.
• anyone who has difficulty understanding English.
6.20 Step 4: record, plan, inform, instruct and train
6.13 In evaluating the risk to people with disabilities it may 
be necessary to discuss their individual needs with 
them or seek professional advice.
6.21  It is a good idea for everyone to keep a written record of 
their fire safety risk assessment. If you have five or more 
employees (including any who work part-time and not 
6.14 Step 3: evaluate, remove or reduce risk and 
necessarily at the particular premises being risk-assessed), 
protect against remaining risk 
and if the premises are licensed, or if an alterations 
notice is in force (see Appendix 1, A.57) the law says 
6.15 Hazards should be removed where it is practicable to 
you must make a written record of your risk assessment. 
do so, and where they cannot be removed they should 
In these cases it is the “significant findings” of the risk 
be reduced as far as possible. What is considered 
assessment that must be recorded. Significant findings 
reasonable in a particular case will depend on an 
are the actions to be taken as a result of the assessment 
evaluation of the potential to cause harm and the 
and details of anyone at particular risk. Significant 
chance of that harm occurring. Some simple examples 
findings should include details of:
are given below: 
• the fire hazards that have been identified (but ignore 
• replace portable heating appliances with fixed 
trivial things such as a tin of solvent-based glue);
convector heaters or a central heating system; 
• the actions taken, or which will be taken, to remove 
housing – fire safety
9

or reduce the chance of a fire occurring (preventive 
Part C: General principles of fire risk
measures);
reduction
• persons who may be at risk, particularly those 
especially at risk; 
• the actions taken, or which will be taken, to reduce 
7.  Introduction  
the risk to people from the spread of fire and smoke 
(protective measures);
7.1  Existing residential accommodation comprises a wide 
• the actions people need to take if a fire occurs. This 
range of property types, occupancy arrangements and 
will include any special arrangements made with staff 
occupier type. Fire risks in rented accommodation, and 
such as housekeepers or others (the emergency plan);
in particular in houses in multiple occupation (HMOs), 
• any information, instruction and training identified 
can be complex. HMOs often provide accommodation 
as being needed, and how it will be given; and
for people from a wide range of backgrounds and 
may house vulnerable or disadvantaged groups. In 
• any discussions that have taken place with residents 
some HMOs there is a high occupancy turnover rate 
(or, if appropriate, with staff). 
with little social interaction or cohesion between 
occupiers. The mix of often poor-quality, low-cost 
 
It is recommended that a record of the significant 
housing and vulnerable occupants can lead to a higher 
findings of the fire risk assessment is kept in all cases, 
than normal fire risk. 
even where it is not a requirement to do so. An 
example template is shown in Appendix 3 – however, 
7.2  With these varying factors applying it is not credible 
any alternative format will be acceptable provided it 
to offer a single solution to fire safety which can be 
contains the information above.
applied broadly. Fire safety solutions must instead be 
based on the level of risk presented by an individual 
6.22 An appropriate emergency plan should be put in place. 
property and its mode and level of occupation. Often 
In most residential accommodation this is unlikely to 
alternative solutions are available which will provide an 
extend beyond advising residents what to do in the 
equally acceptable level of fire safety for a particular 
event of a fire or fire alarm and how to contact the fire 
property, and sometimes identical properties may need 
and rescue service. In large or mixed use premises a 
different approaches due to differences in the types of 
more sophisticated plan may be necessary. 
occupation or the needs of the occupants. 
6.23 The responsible person must provide any employees 
7.3  This risk-based approach is enshrined in current fire 
with appropriate information and training on risks 
safety legislation, in particular the housing health and 
identified in the risk assessment and information on 
safety rating system and the Regulatory Reform (Fire 
fire safety measures and procedures for the premises. 
Safety) Order 2005 (see Appendix 1, paragraphs A.7 
and A.51). 
6.24 There is no requirement under the FSO to provide 
training to residents, but providing them with basic 
7.4  However, some basic fundamental principles apply to 
information on fire precautions is a simple and 
fire safety generally, and these must be applied flexibly 
effective way of reducing fire risk in the premises.
to meet the needs of a particular property. These 
principles are outlined in this chapter and are brought 
6.25 Step 5: review
to life in the case studies in Part D.
6.26 The risk assessment and the general fire precautions 
7.5  A risk assessment carried out on premises constructed 
in the premises should be reviewed regularly. There is 
or converted to a standard which would meet the 
no specific timescale for this other than where there is 
requirements of the Building Regulations 1991, 
a reason to suspect that it is no longer valid or where 
approved document B is unlikely to conclude 
there has been a significant change in the premises.
that additional fire safety measures are required. 
Premises constructed/converted to that standard 
and subsequently maintained as such are likely to 
6.27 In practice the fire precautions should be kept under 
have adequate fire safety measures. The exception is 
constant review. Where problems are identified they 
where the premises are occupied in a manner other 
should be dealt with as soon as possible.
than that intended under the original construction 
10
housing – fire safety


or conversion scheme (for example, occupation of a 
9.  Escape routes 
single household flat as a flat in multiple occupation, 
or where some other additional risk has been 
9.1  This section provides guidance on the general 
subsequently introduced). Where a building did 
principles relating to escape routes along with 
comply but has deteriorated significantly through lack 
examples of typical escape route solutions for different 
of maintenance, damage or other alteration it may 
building layouts. Most residential premises covered 
require additional measures and this guidance should 
by this guide will be considered as ‘normal’ risk. 
be applied.
This is based on the general assumption that the 
occupants are able-bodied and will be capable of 
7.6  In view of the type of properties falling within 
using the means of escape unaided to reach a place of 
the scope of this guide, the fire safety approach 
ultimate safety, and that there are no unusually high 
adopted is to provide early warning of any fire to all 
risk elements. If this is not the case or there are other 
occupiers and to ensure that they can safely evacuate 
factors which present a higher than normal risk then 
the building to a place of permanent safety (total 
additional measures may be required.
evacuation). Blocks of flats which were constructed or 
converted in compliance with the Building Regulations 
9.2  Layout of accommodation units themselves 
1991, approved document B or equivalent may adopt 
must be considered. Poor layout within a unit of 
a different approach such as ‘stay-put’ as the level of 
accommodation can present a fire risk to the occupant 
compartmentation means there will be a low risk of 
before he or she is able to reach the escape route. 
fire spreading beyond its unit of origin. 
Ideally, sleeping areas or rooms should be closer to 
the exit door to the accommodation than living areas 
8.  General fire safety principles 
or kitchen facilities (see also paragraphs 12 and 13 
regarding inner rooms and galleries). 
 
Figure C1 (below) illustrates some general principles 
which underpin fire safety in a residential context.
9.3  Wherever possible, fire risks such as the storage of 
significant quantities of flammable materials and ready 
housing – fire safety
11


sources of ignition should be removed or reduced. If 
9.6  When considering the safety of the existing escape 
it is not possible to do so, the risk should be regarded 
route, in addition to the occupant profile it is 
as ‘higher’ and the property may need a higher level 
necessary to consider:
of fire safety protection than normal. Other examples 
• the layout and complexity of the route; 
of higher risk might include very large premises, 
• the travel distance to a place of safety; 
premises where there are integral commercial uses, 
and those with unusually poor levels of construction 
• the type of construction and state of repair; and
or with complicated layouts. Similarly, the occupancy 
• the presence of other fire safety measures such 
of the building may present a higher than normal 
as automatic fire detection and warning systems, 
risk, thereby warranting a higher level of protection – 
emergency lighting or fire suppression systems.
for example where significant numbers of occupiers 
have limited mobility or are unable to move without 
 
Figure C2 (below): Some risk factors to consider
assistance, or premises catering for people subject to 
alcohol or substance misuse.
9.7  In all buildings a fully protected escape route 
(staircase) offering 30 minutes fire resistance is the 
9.4  Conversely, some premises present a risk which can 
ideal solution and it will usually be appropriate for 
be regarded as ‘low’. Examples may include premises 
all bedsit-type accommodation. However, in lower 
with all of the following characteristics:
risk buildings (i.e. single household occupancy of up 
• a low occupancy level and all the occupants are 
to four storeys and low risk shared houses), due to 
able-bodied and capable of using the means of 
the lower risk and shorter travel distance to the final 
escape without assistance; 
exit, this need not be insisted upon as long as all the 
• very little chance of a fire occurring and few, if any, 
following conditions are met:
highly combustible or flammable materials or other 
• the stairs should lead directly to a final exit without 
fuel for a fire;
passing through a risk room;
• where fire cannot spread quickly throughout the 
• the staircase enclosure should be of sound, 
property and will be quickly detected so people can 
conventional construction throughout the route;
make their escape; and 
• all risk rooms should be fitted with sound, 
• where there is more than one acceptable escape route.
close-fitting doors of conventional construction 
(lightweight doors and doors with very thin panels 
9.5  The guidance on acceptable standards for escape 
should be avoided); and 
routes in this document is based upon ‘normal’ risk. 
• an appropriate system of automatic fire detection 
and warning is in place (see table C4). 
12
housing – fire safety

9.8  An alternative solution is possible in low risk two-
previous standards have suggested maximum safe 
storey shared houses. Where the first floor is no more 
distances. For example, nine metres was considered 
than 4.5 metres above ground level, rooms used for 
the maximum acceptable distance from a room exit 
sleeping could be provided with access to a suitable 
door to a place of relative safety. This is a useful 
escape window from the first floor leading to a place 
reference but need not be applied as a rigid standard, 
of ultimate safety. In this situation consideration of the 
and may be increased or decreased depending upon 
internal escape route is not essential. The option of 
the level of risk once the appropriate fire prevention 
escape windows will only be acceptable if they meet 
measures have been put in place. When assessing 
the requirements of paragraph 14, and, where they do 
travel distances, the distance should be considered 
not, the provisions of paragraph 9.7 should be usually 
from all parts of the premises to the nearest place of 
applied. If it is necessary to pass through the common 
relative safety, which is: 
escape route to reach the escape window, consideration 
• a protected stairway enclosure (storey exit);
should be had to the travel distance involved. Where the 
• a separate fire compartment from which there is a 
common escape route is not a protected route, unusually 
final exit to a place of ultimate safety; or
long travel distances may be unacceptable and other fire 
precautions may be necessary (this will not usually be the 
• the nearest available final exit.
case in conventional houses).
9.12 If there is a suitable second staircase or exit or if there 
9.9   In the worst-case scenario, it may be that the 
are additional fire safety measures (an enhanced 
requirements of paragraphs 9.7 and 9.8 cannot be 
system of fire detection and warning, for example, 
provided and the only exit internally is through a risk 
or a water suppression system), the premises may 
room. Whilst this should always be avoided where 
be considered lower risk and the travel distances 
possible, in some cases it may be impracticable to 
and levels of protection may be adjusted accordingly 
do so. Where this is the case it may exceptionally be 
where this lower risk can be demonstrated.
possible to accept exit via a risk room provided the exit 
from the bottom of the staircase at ground floor level 
9.13 In single room units or other accommodation which 
is possible in more than one direction (i.e. via either 
has an exit door leading directly to a protected 
the front or the rear rooms). 30-minute fire resisting 
stairway enclosure or a separate fire compartment 
construction and FD30S fire doors between each 
from which there is a final exit to a place of ultimate 
of the ground floor rooms and the staircase will be 
safety, it will only be necessary to consider the 
required alongside an enhanced system of automatic 
travel distance from the furthest point within the 
fire detection. Where escape from the bottom of the 
unit to that exit door. It is unlikely that in the types 
staircase is only possible in one direction, a further 
accommodation covered by this guide the distance 
alternative might be the installation of a water 
will be so large as to have any impact on safety, but 
suppression system. These arrangements will generally 
if such cases do arise then additional safety measures 
be unsuitable for bedsit-type occupation.
may be appropriate. In any event, cooking facilities 
within these rooms should, wherever possible, be sited 
9.10 When a fire starts, if there are no fire safety measures 
away from the exit door so as not to prejudice it in the 
in place then the time that people have to escape 
event of fire.
before they become affected or trapped is extremely 
limited. The presence of fire safety measures extends 
9.14  In units with more than one room leading off an 
this time. In practice this means the installation of 
internal lobby or hallway (flats), the travel distance 
some form of fire warning and detection system and 
within that lobby/hallway will need to be considered. 
an escape route which will remain unaffected by the 
If it is unusually large or there are a large number 
fire for sufficient time to allow people to reach a place 
of rooms leading off it (for example a large flat 
of safety. By necessity, the travel distance along the 
in multiple occupation), the travel distances may 
escape route must be limited.
necessitate making the internal lobby/hallway a fire 
protected route; or it may necessitate the provision of 
9.11 Limiting the travel distance from rooms to a place 
an alternative exit or additional fire safety measures 
of safety reduces the risk of people being trapped 
such as an enhanced fire detection and warning 
by a fire on their escape route. This guidance does 
system or an automatic water suppression system. 
not set a maximum travel distance, as this should be 
Doors to sleeping rooms within the unit should, 
considered in the context of overall risk. However, 
wherever possible, be closer to the exit door than 
housing – fire safety
13

doors to higher-risk rooms such as kitchens and 
staircase) to ensure that escaping occupiers do not 
communal living rooms.
have to escape up through a trapped layer of smoke 
and heat.
9.15 In more complex buildings, such as those with more 
than one escape route or with complex layouts, 
10.5 The standard of fire resistance of individual room 
greater attention to travel distances will be required. 
partitions and of doors to rooms should be the same 
Such situations will not usually be encountered in the 
as for the remainder of the house.
type of premises covered by this guide, but if so then 
the guidance contained in HM Government Fire Safety 
10.6 Ideally, a separate exit to an ultimate place of safety 
Risk Assessment Sleeping Accommodation Guide 
should be provided from the basement level. If this is 
should be followed.
not possible then escape windows should be provided 
to all habitable rooms. To be acceptable, escape 
10.  Habitable basements 
windows should comply with paragraph 14, and 
where they do not (security measures may preclude it 
10.1 Consideration needs to be given to the fire risk 
or there may be no escape from the basement well) 
presented to occupiers of any storey below the main 
then a 30-minute protected route should be provided 
entry/exit level of the house and the risk that storey 
within the basement up to the ground floor. However, 
poses to the remainder of the house. Such storeys 
for single household occupancy and in low-risk 
may be true basements or lower ground floors where 
shared houses of no more than two other storeys (not 
the main house entry level is raised above ground and 
counting the basement), it should be possible to relax 
accessed via steps.
the 30-minute standard as in paragraph 10.3 above.
10.2 Ideally, the fire separation between the basement and 
10.7 In all cases the same level of automatic fire detection 
the ground floor (including the staircase soffit and 
and warning system should be installed in the 
spandrel) should be 30 minutes fire resisting, and a 
basement as in the remainder of the house. 
30-minute fire resisting door should be fitted at the 
head of the basement stairs. 
11.  Unoccupied basements/cellars 
10.3 For single household occupancy or low-risk shared 
11.1 Unoccupied basements and cellars are often neglected 
houses of no more than two other storeys (not 
or used for storage. They usually contain electrical 
counting the basement), it should be possible to 
wiring and possibly electric or gas meters, and they 
accept existing construction provided it is of sound, 
often receive little attention. The basement/cellar may 
conventional construction (such as plasterboard or lath 
be one open void without partitioning. Alternatively 
and plaster ceilings) and is in good condition. In this 
there may be rooms but they may not have substantial 
situation it should also be possible to accept existing, 
doors, the doors may be left open or may be in 
well fitted and constructed solid doors within the 
disrepair. In either case, any fire will quickly attack the 
basement, providing they are in sound condition and 
basement/ground floor partition and door. Because 
self closing. Solid timber doors and panelled doors 
of its location the fire will spread rapidly upwards and 
of substantial construction may be adequate in these 
prejudice the escape route from the ground floor. For 
lower risk situations, but flimsy constructions and 
these reasons, generally the fire separation between 
hollow infill-type doors (commonly known as ‘egg-
the basement and the ground floor (including the 
box’) would not be. This can be difficult to assess and 
staircase soffit and spandrel) should be 30 minutes fire 
expert advice may be required.
resisting, and a 30-minute fire resisting door should be 
fitted at the head of the basement stairs. However, for 
10.4 In larger shared houses and other multi-occupied 
two-storey single household occupancies and two-
premises, full 30 minutes fire separation between 
storey, low-risk shared houses, if the basement is well 
the basement and ground floors should be expected, 
maintained and managed it may be possible to apply 
with a self-closing 30-minute fire resisting door with 
the same relaxation in fire separation as in paragraph 
intumescent strips and smoke seals fitted at the head 
10.3 above. In all cases the same level of automatic 
of the stairs to the basement. In some very large 
fire detection and warning system as in the remainder 
occupied basements, it may be appropriate to have 
of the house should be installed in the basement.
two FD30S doors (top and bottom of the basement 
14
housing – fire safety


12.  Inner rooms
outer room while making their escape; and
• ideally the outer room should not be an area of high 
12.1 A room where the only escape route is through 
fire risk, but if this is impracticable and there is no 
another room is termed an ‘inner room’ and poses 
other option it could be accepted in this situation as 
a risk to its occupier if a fire starts unnoticed in the 
exit via an escape window provides an alternative. 
outer room (sometimes termed an ‘access room’). This 
arrangement should be avoided wherever possible. 
 
Figure C3 (below): Inner rooms 
However, where unavoidable it may be accepted where 
the inner room is a kitchen, laundry or utility room, a 
dressing room, bathroom, WC or shower room.
13.  Galleries 
12.2 Where the inner room is any other type of habitable 
13.1 Gallery accommodation has become popular in 
room (for example a living room, sleeping room, 
open plan studios and elsewhere where space is at a 
workroom or study) it should only be accepted if:
premium. To be acceptable a gallery should:
• the inner room has access to a suitable door 
• ideally be provided with an alternative exit leading 
opening onto an alternative safe route of escape, 
to a place of safety; or 
or it is situated on a floor which is not more than 
• where the gallery platform is not more than 4.5m 
4.5m above ground level and has an escape window 
above external ground level it should have an 
leading directly to a place of ultimate safety;
escape window leading to a place of safety. Escape 
• an adequate automatic fire detection and warning 
windows will only be acceptable if they meet the 
system is in place (see paragraphs 22-25); and
requirements of paragraph 14.
• a fire-resisting door of an appropriate standard is 
fitted between the inner and outer rooms (typically 
13.2 Where an alternative exit or suitable escape window is 
FD30S standard for non-high-risk outer rooms).
not possible, the gallery should comply with all of the 
following: 
12.3 Escape windows are only acceptable if they meet the 
• at least 50% of the floor area of the room should be 
requirements of paragraph 14.
unobscured by the gallery;
• the distance from the foot of the egress stair 
from the gallery to the room exit should not be 
12.4 In addition to the precautions outlined in paragraphs 
excessive (approximately three metres is a suggested 
12.1-12.3 above, in all cases the following additional 
reasonable maximum); and
requirements must apply for the arrangement to be 
acceptable:
• any cooking facilities within the room should be 
enclosed within fire-resisting construction or be sited 
• outer rooms should be under the control of the 
remote from the room exit and gallery egress stair.
same person as the inner room;
• nobody should have to pass through more than one 
housing – fire safety
15


13.3 In all cases a suitable automatic fire detection and 
the common escape route is not a protected route, 
warning system should be in place (see paragraphs 
unusually long travel distances may be unacceptable 
22-25).
and other fire precautions may be necessary (this 
will not usually be the case in conventional houses);
 
Figure C4 (below): Gallery where escape window is 
• occupiers are able-bodied individuals with no 
not possible
specific high-risk characteristics and who can 
reasonably be expected to exit via the window 
unaided;
14.  Requirements for escape windows 
• there is no basement well or other encumbrance 
beneath the window such as railings or a 
14.1 Any window provided for emergency escape purposes 
conservatory;
should have an unobstructed openable area that is 
• the escape window is openable from the inside 
at least 0.33m² and have a minimum 450mm height 
without the use of a removable key; and the ground 
and 450mm width. The bottom of the openable area 
below is level and free of obstructions; and
should not be more than 1,100mm above the floor. 
• the window or door should lead to a place of 
ultimate safety, clear of the building. However, if 
14.2 Escape windows can only be considered if satisfied 
there is no practical way of avoiding escape into a 
that it would be safe to use them in an emergency. 
courtyard or back garden from where there is no 
They should meet the following criteria:
exit, it should be at least as deep as the building is 
• they serve rooms whose floor level is no more than 
high.
4.5m from the ground;
• every room served by the escape window has access 
 
Figure C5 (see page 17): Minimum requirements for 
to it without entering another habitable room 
escape windows
with a lockable door (unless of a type that can be 
overridden from outside the room without the use 
of a key, tool or numerical code) and any tenancy 
14.3 If any of the above requirements cannot be met, the 
agreement should ideally prohibit the fitting of 
use of the escape window should not be accepted and 
alternative or additional locks. (This will usually be 
an alternative solution should be adopted.
achievable in single household occupancies and 
most shared houses, but is unlikely in a bedsit-type 
15.  Protected routes/stairs
HMO); 
• If it is necessary to pass through the common escape 
15.1 A protected route is designed to remain free from 
route to reach the escape window, consideration 
smoke and fire for a time adequate to allow occupiers 
should be had to the travel distance involved. Where 
of the building to pass safely along it to a place of 
16
housing – fire safety


safety. The level of fire separation required between 
• basement areas or cellars without automatic fire 
the protected route and rooms presenting a fire risk is 
detection.
determined by risk assessment. 
 
Further guidance on protected routes is given in the 
15.2 Ideally the recommended standard of fire resistance 
remainder of this section, and case study examples of 
enclosing a protected route is 30 minutes for normal 
suitable fire safety solutions are given in Part D.
risk premises. However, subject to risk assessment, 
in lower risk properties (average single household 
15.3 The protected route should be maintained free of any 
occupancy or low risk shared houses) with automatic 
obstructions and/or fire risks. In particular, the stairway 
fire detection this may be relaxed (see paragraph 9.7). 
should not contain:
In such cases it may be sufficient to accept sound, 
conventional construction throughout the route. 
• any portable electric, gas or oil heaters;
Larger properties, however, will require 30 minutes 
• any fixed heaters using a portable heating source 
protection including fire doors. Areas of high fire 
such as liquefied gas;
risk may require 60 minutes protection. Examples of 
• any cooking facilities; and 
60-minute requirement include:
• any furniture or storage.
• walls, ceilings and doors separating commercial uses 
from residential parts;
15.4 Storage cupboards should not be located in protected 
• walls, ceilings and doors separating areas of high 
routes unless they are fire resisting and kept locked 
fire risk, for example commercial kitchens, large 
shut and smoke alarms/detectors are fitted within 
boiler rooms or large stores;
them (as appropriate). The exception is for all single-
• separating walls between buildings; and 
household accommodation and shared houses of not 
housing – fire safety
17

more than two storeys, for which in most situations 
a five-storey bedsit-type HMO which does not have fire 
cupboards can be adequately managed so as not to 
protecting lobbies to the risk rooms).
present an additional risk and can be accepted. 
17.2 For the purposes of this guidance the term ‘secondary 
15.5 Gas or electric meters and/or distribution boards 
means of escape’ refers to a second, alternative means 
should ideally not be sited in escape routes. However, 
of escape from the building other than the usual escape 
it should be possible to relax this providing any gas 
route usually used to enter or exit the premises. 
meter is installed in accordance with the gas safety 
regulations and any electric meter is installed and 
17.3 Typically a secondary means of escape will comprise 
sited in accordance with current IEE regulations. It is 
an external staircase down the rear or side of 
considered best practice to enclose such equipment in 
the building. In some situations this may prove 
fire-resisting construction.
impracticable, and as an alternative a secondary 
means of escape could be achieved by creating a 
15.6 There is usually no requirement to provide protection 
door through a separating wall or across a roof 
to bathrooms and shower rooms which open onto 
walkway into the common parts of another building 
protected routes. Properly installed and maintained 
which itself has a protected route leading to a place 
central heating boilers, electric showers or water 
of safety. Such arrangements are undesirable and 
heaters and room-sealed gas water heaters pose little 
should be ‘designed out’ wherever possible. If no 
additional risk. However, if the room contains open 
other arrangement is possible then this is usually 
flame or electric bar space heaters, storage cupboards 
only acceptable when the two adjoining buildings 
or other risk items then either the storage cupboards 
are under the same ownership/management or 
or the room itself, as appropriate, should be protected 
where the arrangement is reciprocal and a strictly 
to the appropriate standard in the same way as the 
enforced, legally binding agreement is in place. In 
remainder of the route.
an ideal situation, access to the secondary escape 
would be possible from every floor. However, this is 
16.  Exit doors
usually impracticable, and access solely from the top 
floor will be acceptable provided the other fire safety 
precautions recommended in this guide are in place. 
16.1 Ideally, final exit doors from all premises should be 
In five- and six-storey buildings, to protect the upward 
fitted with locks/catches which are openable by 
escape route at fourth and fifth floor levels from any 
the occupiers from the inside without the use of a 
fire on the floors below, there should be 30 minutes 
removable key. This should always be the case in 
fire separation across the staircase between the fourth 
HMOs, including shared houses. Where security locks 
and fifth floors. 
are fitted they should be of the type with a suitable 
internal thumb-turn to facilitate this. To safeguard 
security any glazed panels within the door or adjacent 
17.4 To be acceptable a secondary means of escape should 
to it should replaced with protected glazing of some 
meet the following requirements: 
kind or protected in another way from intruders. 
• have access from the common parts of the building, 
not solely from rooms, bathrooms or WCs (where 
this is impracticable, special arrangements may be 
16.2 It is strongly recommended that the exit door from 
made with the agreement of the LHA); 
each unit of accommodation (bedsit or flat) is also 
openable from the inside without the use of a 
• terminate at ground floor level at a place of ultimate 
removable key. 
safety;
• the entire length of the secondary means of escape 
to be passable without the use of a key or other tool;
16.3 Electrically operated locks must fail to safety (open) or 
have a manual over-ride in the event of power failure.
• access preferably by a standard door, but where 
impracticable via an opening of at least 800mm x 
540mm;
17.  Secondary means of escape 
• fixed walkways will be required across any roofs and the 
roof area beneath should be 60 minutes fire resisting;
17.1 In certain larger buildings and those with certain higher 
• walkways and staircases should have conventional 
risk characteristics, a secondary means of escape will be 
and emergency lighting throughout the route to the 
required (for example in a six-storey bedsit-type HMO or 
standards outlined in paragraphs 23 and 24.
18
housing – fire safety

17.5 Stairs comprising secondary means of escape should 
If that is not possible then a regular maintenance 
comply with the following:
schedule should be in place and non-slip tread 
• clear width (minimum 600mm, preferred 800mm);
surfaces fitted. A cyclical re-painting schedule to 
• pitch 30-42 degrees from horizontal (optimum 35 
prevent weather decay should be in place. Stairways 
degrees);
should have conventional and emergency lighting 
throughout their route to the standards outlined in 
• going (depth of tread from front to back) 225-
paragraphs 23 and 24.
300mm (optimum 250mm);
• rise (vertical distance between treads) 100mm-
220mm (optimum 175mm);
 
Figure C6 (see page 20): Protected zone around an 
external secondary means of escape
• treads to be flat and non-slip;
• handrails required on both sides (840-1000mm 
19.  Fire separation and compartmentation
height);
• minimum headroom clearance 1.5m (2m 
perpendicular height preferable). 
19.1 In addition to providing a protected escape route, it 
 
Further details are contained in BS 5395, parts 1 and 3.
is necessary to restrict the spread of fire and smoke 
from one unit of accommodation to another. This is 
termed compartmentation. Fire-resisting construction 
17.6 Fixed or removable vertical ladders, pull-down ladders 
enclosing each unit of accommodation creates a 
and unconventional devices such as lowering lines and 
compartment that will contain fire and smoke within 
cradles are not suitable as secondary means of escape. 
it for a period of time, leaving adjacent units free from 
the effects of fire during that time.
18.  External stairways (other requirements) 
19.2 The recommended standard of fire separation in 
18.1 To be an acceptable secondary means of escape, any 
the types of premises of normal risk covered by 
external stairway should ideally be protected from the 
this guide is generally 30 minutes. However, in 
effects of fire along its full length. Except for those 
lower risk premises (for example average single 
serving non-risk rooms, doors or windows adjacent 
household occupancy or shared houses of no more 
to the route and vertically below it should, where 
than two storeys) this requirement can be relaxed 
possible, be protected. Doors should be fire resisting 
(see paragraph 19.6). Where the fire risk assessment 
and self closing. Windows should be of fire-resisting 
identifies specific higher risks then a higher standard 
construction and, if possible, fixed shut. However, in 
of fire resistance may be required (usually 60 minutes) 
reality this will be impracticable if the windows serve 
or additional fire safety measures should be installed. 
habitable rooms. In such cases the risk will need to be 
Examples of 60-minute requirement will include:
assessed. If a fire in the room could prejudice both the 
• walls, ceilings and doors separating commercial uses 
internal escape route and the secondary escape route 
from residential parts;
at the same time, the risk will be unacceptable and 
• walls, ceilings and doors separating areas of high 
alternative measures will be required if the room is to 
fire risk such as commercial kitchens, large boiler 
remain in habitable use. Alternatives might include 
rooms or large stores; and
additional fire-resisting lobby protection internally, 
• separating walls between buildings.
re-siting of the risk windows, mechanical ventilation 
to the room or the provision of a water suppression 
system. If acceptable alternatives cannot be provided 
 
Attention should be paid to any ductwork that passes 
then the room may need to be converted to low-risk 
through the separation. This will require protecting to 
use (e.g. bathroom/WC). Research on the effects 
the same standard of fire resistance as the partition 
of fire from openings on external escape routes 
itself.
suggests that the sensitive area is approximately 1.8m 
horizontally (as shown in figure C6 below). These 
19.3 Types of construction which meet the 30 minutes 
dimensions should be treated with some flexibility 
fire resistance standard are those tested to the 
according to the risk presented.
relevant part of BS 476 or BS EN 13501. This will 
usually mean solid walls or timber stud partitions of a 
18.2 The external stairway should be protected from the 
particular construction (with adequately fixed 12.5mm 
weather so that the treads do not become slippery. 
plasterboard and skim coat). However, many other 
housing – fire safety
19


proprietary constructions and products are available 
D of this guidance are in place). It will be difficult 
which have been tested to these standards and have 
to determine the exact construction of an existing 
a valid test certificate demonstrating 30 or 60 minutes 
partition without invasive inspection. A practical 
of fire resistance.
solution to this could be to accept partitions where 
both sides of the partition are constructed of sound 
19.4 In general (but subject to paragraph 9.7 for lower risk 
plasterboard or lath and plaster in good repair. 
properties):
Where there is any doubt as to the sound properties 
or integrity of the partition it may be appropriate to 
• walls and ceilings separating individual units of 
replace it. If these constructions are to be considered 
accommodation should be constructed to provide a 
in premises of higher risk than those described in this 
minimum of 30 minutes fire resistance; and
paragraph, it should only be within the context of the 
• protected routes should be fully enclosed at all 
overall fire risk assessment. This is likely to conclude 
points by construction providing a minimum fire 
that compensatory fire safety measures (such as an 
resistance of 30 minutes.
enhanced system of automatic fire detection and 
warning, a domestic water suppression system or a 
19.5 Existing partitions of standard construction with 
secondary means of escape) are necessary.
adequately fixed 12.5mm plasterboard with skim coat, 
on correctly sized and spaced timbers and in good 
19.7 Particular care must be taken with walls and partitions 
condition, can be expected to achieve a nominal fire 
enclosing protected routes to ensure that they will 
resistance of 30 minutes and should be acceptable.
restrict the passage of smoke and fire. Any openings 
around pipes, services or ducts that pass through 
19.6 In many existing buildings, constructions will be 
fire-resisting construction should be fire stopped 
encountered which are of a lesser standard (for 
with materials of at least the same level of fire 
example 9mm plasterboard partitions or original lath 
resistance as the structure itself. Many proprietary fire 
and plaster construction). It is likely to be impracticable 
stopping products are available, but only those which 
and uneconomic to replace such partitions as a matter 
provide the appropriate fire resistance when tested 
of routine whenever encountered. Where they are 
to the relevant part of BS 476 or BS EN 13501 are 
in sound condition and good repair they may be 
acceptable. Any services (such as cables) constructed 
acceptable in lower risk premises (shared houses 
of combustible materials or materials likely to melt or 
of no more than two storeys with no particularly 
be affected by fire should be enclosed within fire-
vulnerable high-risk occupants, provided the other 
resisting construction and be fire stopped to restrict 
fire safety measures as recommended in Parts C and 
the passage of smoke and fire.
20
housing – fire safety

20.  Floor/ceiling partitions 
• providing additional protection within the floor 
space above the ceiling.
20.1 In most premises covered by this guide, floor/
ceiling partitions between units of accommodation 
20.5 There are a number of acceptable methods and 
should provide a standard of fire resistance of 30 
products available for upgrading ceilings/floors. Only 
minutes. The exception is those above areas of high 
products accompanied by a valid test report should 
fire risk which should provide 60 minutes. Floor/
be accepted. The report will specify the fire resistance 
ceiling partitions between any basement or cellar 
which will be achieved by the upgrading method. This 
and the ground floor escape route should provide 60 
is essential for all upgrading methods, but particularly 
minutes resistance, but this may be reduced to 30 
so where proprietary products are being considered. 
minutes where the basement/cellar has an automatic 
Where in doubt, careful scrutiny of the fire test report 
fire detection and warning system to the standard 
is essential before acceptance. Particular attention 
recommended in paragraphs 27-30.
should be paid to any suspended ceilings. Several 
products are available which provide adequate fire 
20.2 Inspection of the floors/ceilings as part of the fire 
resistance and which are accompanied by acceptable 
risk assessment will determine the suitability of 
test reports, but not all suspended ceilings are 
existing construction. Generally, ceilings constructed 
designed to provide 30 minutes fire resistance. Often 
with 12.5mm plasterboard with skim coat and in 
they are installed for aesthetic reasons and may 
sound condition will be adequate. Other proprietary 
conceal a ceiling beneath which has collapsed or 
constructions will be encountered and it will be 
is damaged. In such cases the overall construction 
necessary to consult the manufacturer’s fire test 
may provide little fire resistance. Where suspended 
report to determine the standard of fire resistance and 
ceilings already exist, ideally a test report should be 
suitability.
required from the installer/manufacturer. Where this 
is not forthcoming a judgment will need to be made 
following detailed inspection, and specialist advice 
20.3 Ceilings such as those constructed from 9mm 
may be required. 
plasterboard or lath and plaster (in sound condition) 
can be expected to provide a lower standard of fire 
resistance. However, this should be acceptable as 
20.6 Suspended ceilings which do meet an acceptable 
part of an overall fire risk assessment in lower risk 
standard should be inspected regularly and well 
premises such as single household occupancy and 
maintained as they can be easily damaged.
shared houses of no more than three storeys with 
no specific higher risk factors present. Acceptability 
21.  Fire doors 
is conditional upon other fire safety measures being 
in place as recommended in this guidance (Parts C 
21.1 Where fire-resisting partitions are required, any 
and D). If these constructions are to be considered 
doorways within them must be fitted with fire-
in premises of higher risk than those described in 
resisting door assemblies providing fire resistance at 
this paragraph, it must only be within the context of 
least to the same standard as the requirement for the 
the overall fire risk assessment, which includes the 
partition itself – so 30-minute partitions will require a 
provision of compensatory fire safety measures such as 
30-minute fire-resisting door, 60-minute partitions a 
an enhanced standard of automatic fire detection and 
60-minute door:
warning system, a domestic water suppression system 
or a secondary means of escape.
• 30-minute doorsets are specified as FD30 (or E 30)
• 60-minute doorsets are specified as FD60 (or E 60)
20.4 Ceilings which are not in sound condition, particularly 
lath and plaster type, should be replaced or upgraded to 
 
The 30 or 60 figures denote the integrity performance 
provide 30 minutes resistance. This can be achieved by:
time of the doorset in minutes. A letter ‘S’ after the 
• removal and replacement of the existing ceiling 
figure (e.g. FD30S) or ‘Sa’ (e.g. E30 Sa) denotes a 
with standard 12.5mm plasterboard and skim 
requirement for smoke seals to be fitted so as to 
construction or alternative product/construction 
restrict the passage of smoke, including cold smoke 
providing 30 minutes resistance and subject to a 
(see paragraph 21.3).
satisfactory fire test report;
• providing additional protection below the ceiling; or
21.2 Most timber fire doors will need intumescent seals 
housing – fire safety
21

fitted. The type and location of the seals varies with 
doorset, which will be available from the manufacturer 
the door design and the manufacturer’s instructions 
or supplier. Variations in any detail from the test 
should be followed.
specification may adversely affect the performance 
of the door. When new fire doors are to be provided, 
21.3 In most situations fire-resisting doors should be fitted 
ideally an entire doorset construction should be fitted 
with smoke seals, as these restrict the passage of 
– thereby overcoming potential problems with fitting 
smoke into the escape route from the room where 
doors to frames of a different specification to that in 
the fire is situated. The exception to this is where fire 
the test construction. However, it is recognised that 
doors are fitted to rooms in premises where the fire 
in some existing buildings of substantial construction 
detection system is restricted to the escape route (see 
this requirement may cause practical difficulties. If this 
paragraph 22.11/table C3). This will often be the case 
is the case it may be possible to fit new fire doors to 
in three-storey shared houses. In these cases smoke 
existing frames. This will, however, only be acceptable 
seals should not be fitted, as their benefit will be 
if the frames are of sound construction, in good 
outweighed by the fact that the smoke detectors in 
condition, and of material and dimensions not less 
the escape route will only activate when the fire is at 
than those of the frame detailed in the test report. 
an advanced stage and beginning to breach the fire 
door. The resulting alarm may be so late sounding 
21.8 The upgrading of non-fire-resisting door assemblies 
that the fire and smoke is already affecting the escape 
should be avoided wherever possible. The practice is 
route. Where smoke detection is sited within rooms 
generally impractical and uneconomic and is reliant 
(LD2 coverage – see paragraph 22.11/table C3) the 
upon strict adherence to an approved specification and 
alarm will sound very early in the development of the 
upon a high standard of workmanship. Replacement 
fire and the smoke seals will be of benefit in keeping 
with suitable, purpose designed and tested doorset 
smoke out of the escape route, enabling occupiers to 
constructions is always preferable. However, it is 
evacuate safely.
accepted that for aesthetic reasons it may be necessary 
 
to undertake upgrading rather than replacement. This 
21.4 Fire doors should be installed and maintained in 
will apply in buildings of special architectural interest 
accordance with BS 8214:1990.
and certainly in listed buildings where it is important 
to maintain the appearance or original features of the 
door. In non-listed buildings where there is no legal 
21.5 In most multi-occupancy situations, fire-resisting doors 
requirement to maintain the features of the door, 
should be fitted with approved self-closing devices. 
property owners may still want to do so for aesthetic 
This may be relaxed for doors within houses or flats 
reasons. Whilst undesirable from a practical and fire 
occupied by a single household and doors within low-
safety viewpoint, upgrading may be acceptable subject 
risk, shared houses. Doors to rooms within larger flats 
to strict conditions. Not all doors are suitable for 
in multiple occupation and larger shared houses may 
upgrading, so before undertaking upgrading the door 
require self-closers within the context of an overall 
must be assessed for suitability by a qualified person. 
fire risk assessment. Entrance doors to flats and bedsit 
Where the door is of a common construction and to 
rooms will always require them.
a specification that has previously been subjected to a 
fire test and been considered suitable for upgrading, 
21.6 In lower risk premises where a full 30-minute 
a standard method of upgrading may be specified. If 
protected route is not required (see paragraph 9.7 and 
the door type is unconventional it will need a specific 
case studies in Part D), it should be possible to accept 
assessment by a suitably qualified person who will issue 
existing, well fitted and constructed solid doors, 
an assessment report. The assessment report will specify 
providing they are in sound condition. Solid timber 
the upgrading measures required. 
doors and panelled doors of substantial construction 
may be adequate in these lower risk situations. Non-
21.9 There are several acceptable methods of upgrading 
fire-resisting glazed doors, doors of flimsy construction 
available. They are restricted to those which have 
or hollow infill-type doors (commonly known as ‘egg-
been successfully subjected to fire tests. Details of 
box’) should not be accepted. This can be difficult to 
these are available from trade organisations such as 
assess and expert advice may be required.
TRADA† and from English Heritage† and in other 
practical and technical guides. Whatever method of 
21.7 The specification for the doorset on site should be 
upgrading is being considered, it must be one which 
identical to that specified in the test report for the 
is accompanied by a valid and complete test report 
22
housing – fire safety

or an assessment report from a suitably qualified 
22.2 The type of system to be provided in a particular 
person. The report will specify the fire resistance which 
premises is dependent upon risk. A small single family 
will be achieved by the upgrading method. This is 
house will only require a relatively simple provision of 
essential for all upgrading methods but particularly 
smoke alarms. Larger properties will require greater 
so where proprietary products are being considered, 
coverage, and large HMOs with a number of detectors 
and careful scrutiny of the report is essential before 
will require a more sophisticated system including an 
acceptance. When considering a report it is imperative 
integrated control panel and alarm sounders. Virtually 
that the door being considered for upgrading is of a 
all residential premises where people are sleeping will 
design and specification corresponding to the door 
require some form of automatic fire detection and 
in the report. When the upgrading is carried out, the 
warning system.
specification on site must correspond in all respects 
to that specified in the test or assessment report – 
22.3 The type of system installed should be in accordance 
including the specifications for intumescent strips, 
with the recommendations of BS 5839: part 6. This 
smoke seals, self-closers and ironmongery. Variations 
details different grades of system and extent of 
may adversely affect the performance of the door. 
coverage and recommends an appropriate system 
based on the risk the premises presents. Relatively 
†  TRADA : Stocking Lane, Hughenden Valley, High
simple systems will be satisfactory for smaller, low-risk 
Wycombe, HP14 4ND
premises, but larger houses and HMOs will require a 
Website ww.trada.co.uk   
more sophisticated automatic system. In bedsit HMOs 
E-mail: xxxxxxxxxxx@xxxxx.xx.xx 
with cooking facilities within the bedsits and in blocks 
Phone: 01494 569600  
of self-contained flats then a mixed system is usually 
recommended, where the escape routes and common 
†  English Heritage, Customer Services Department,
parts are protected by an interlinked system of alarms 
PO Box 569, Swindon, SN2 2YP 
or detectors and the individual units have a separate 
Website www.english-heritage.org.uk
stand-alone system to alert a sleeping occupant of 
Email: xxxxxxxxx@xxxxxxxxxxxxxxxx.xxx.xx 
fire in their own unit of accommodation. This has the 
Phone:  0870 333 1181 
benefit of reducing nuisance/false alarms throughout 
the whole property caused by activities such as 
21.10 Where existing upgraded doors are encountered 
cooking within any one unit. 
and no test reports or records are available, it may be 
impossible to determine the likely performance of the 
22.4 BS 5839: part 6, The design, installation and servicing 
door. In these cases, if, following detailed inspection, 
of fire detection and alarm systems in dwellings, 
a sound comparison cannot be made with a tested 
is not a prescriptive standard but is based on the 
and approved upgrading method (tested on a door of 
principles of fire risk assessment. It should be treated 
similar construction and dimensions), then it may be 
with flexibility. The standards recommended in part 6 
necessary to replace the door.
table 1 are to be regarded as base guidelines. Those 
recommendations will be appropriate for premises of 
22.  Automatic fire detection and alarm systems 
normal risk, but where the risk is assessed to be lower 
or higher than normal then a lower or higher provision 
of detection and warning may be appropriate.
22.1 The presence of a suitable, properly installed and 
maintained automatic fire detection and warning 
system will alert occupiers to the presence of a fire 
22.5. BS 5839: part 6 risk assessment criteria
in its early stages and enable them to evacuate to a 
place of total safety before the escape routes become 
22.6 General principles:
blocked by smoke or directly affected by fire. The 
• system design must be appropriate to the risk;
system should wake people who are sleeping (who 
• in assessing risk, consider each room in the dwelling 
may otherwise be asphyxiated by smoke before being 
separately;
able to escape). It should also alert the presence of 
a developing fire in any hidden areas such as boiler 
• consider statistical data on fire incidence in each 
rooms, storerooms, cellars and other potentially 
type of dwelling/room; and
unoccupied risk areas before that fire affects the 
• occupant characteristics are relevant (for example 
escape route. 
tenants with impaired hearing).
housing – fire safety
23

22.7 There is no risk low enough to negate the need for 
 
Grade D: a system of one or more mains-powered 
some form of detection and warning system in the 
smoke (or heat) alarms each with integral battery 
house.
standby supply. These are designed to operate in 
the event of mains failure and therefore could be 
22.8 Design considerations/grades of system
connected to the local lighting circuit rather than an 
independent circuit at the dwelling’s main distribution 
board. There is no control panel.
22.9 BS 5839: part 6 grades fire detection and alarm 
systems for residential premises according to the 
 
Grade E
complexity of the system. For the purpose of 
: a system of one or more mains-powered 
specifying fire detection and alarm systems and the 
smoke (or heat) alarms with no standby power supply. 
associated engineering design parameters, there are 
This grade of system will not function if mains power 
six grades. In this guidance grade A and grade D are 
is disconnected or interrupted. It must therefore be 
most relevant, but all six grades are described in table 
wired to a dedicated circuit at the dwelling’s main 
C2 for completeness. 
distribution board.
 
Grade F
 
Table C2: Grades of automatic fire detection and 
: a system of one or more battery-powered 
warning systems as specified in BS 5839: part 6 
smoke alarms. These are not recommended in HMOs.
(2004)
 
 

note: in grades D, E, and F, where more than one 
 
Grade A
alarm is installed they must be interlinked.
: a fire detection and alarm system that 
is designed and installed in accordance with the 
recommendations of BS 5839: part 1 (2002), except 
22.10 Mixed grade systems
clauses relating to alarm audibility, alarm warnings for the 
 
Installations where more than one alarm system 
hearing-impaired, standby supplies, manual call points and 
is installed to serve the whole building are termed 
radio-linked systems, which are replaced by part 6. 
‘mixed systems’. These systems are installed to meet 
 
This comprises a system of electrically operated smoke 
differing life safety objectives and may be to differing 
and/or heat detectors which are linked to a control 
grades, having regard for the need to avoid false 
panel. The control panel must conform to current BS 
alarms from one dwelling unit affecting all occupiers.
5839: part 4 (or equivalent). In general the system 
must incorporate manual call points which should be 
 
Table 1 of BS 5839: part 6 recommends a mixed 
located next to final exits, and, in larger multi-storey 
system for HMOs of three storeys and above (grade 
properties, on each landing. The alarm signal must 
A for communal areas and grade D within individual 
achieve sound levels of not less than 65dB (A) in all 
dwelling units). However, for shared house HMOs 
accessible parts of the building and not less than 75dB 
of normal risk on the basis of risk assessment, this 
(A) at all bed-heads when all doors are shut, to arouse 
guidance does not recommend a mixed system 
sleeping persons. 
as detection is not normally recommended within 
bedrooms in this type of accommodation.
 
Grade B: a fire detection and alarm system including 
detectors (other than smoke or heat alarms), alarm 
22.11 Level of protection: types of system
sounders and control and indicating equipment which 
either conforms to BS EN 54-2 (power supply to BS EN 
 
BS 5839: part 6 (2004) recommends various levels of 
54-4) or to a simpler type laid out in annexe C of BS 
coverage for detection within premises, based on risk. 
5839: part 6. 
These are outlined below in table C3.
 
Grade C: a system of fire detectors and sounders 
 
Table C3: Levels of coverage of automatic fire 
detection and warning systems as specified in BS 

(which may be combined in the form of smoke or heat 
5839: part 6 (2004)
alarms) connected to a common power supply with 
both mains and a standby supply, with an element of 
central control – for example a small dedicated fire 
 
LD1 coverage: a system installed throughout the 
control panel.
dwelling incorporating detectors in all circulation 
24
housing – fire safety

spaces that form part of the escape routes from the 
Single household occupancy five or six storeys
dwelling, and in all rooms and areas in which fire 
Grade A: LD3 coverage
might start i.e. risk rooms.
Shared house HMO of up to two storeys (shared 
 
LD2 coverage
cooking facilities)
: a system incorporating detectors in 
all circulation spaces that form part of the escape 
Grade D: LD3 coverage + additional detection to 
routes from the dwelling and in all rooms or areas that 
the kitchen, lounge and any cellar containing a risk 
present a high fire risk to occupants i.e. risk rooms.
(interlinked)
Shared house HMO of three or four storeys 
 
LD3 coverage: a system incorporating detectors in 
(shared cooking facilities) 
circulation spaces that form part of the escape routes 
Grade D: LD3 coverage + additional detection to 
from the dwelling only.
the kitchen, lounge and any cellar containing a risk 
(interlinked)
22.12 Guidance on grade and coverage of fire detection 
and warning systems within various types of existing 
Shared house HMO of five or six storeys (shared 
residential premises
cooking facilities)
Grade A: LD2 coverage (detection in all risk rooms i.e. 
bedrooms, kitchen and lounge) (interlinked)
22.13 As outlined above, when specifying a system 
it is necessary to follow the principles of fire risk 
Bedsit HMO of one or two storeys with individual 
assessment. The design and complexity of the system 
cooking facilities within bedsits
should reflect the risk presented by the subject 
A mixed system:
property and the type of occupier. 
• Grade D: LD2 coverage in the common areas and 
heat detectors in bedsits (interlinked)
22.14 The recommendations for system design outlined in 
• Grade D smoke alarm in each bedsit to protect the 
table C4 below are based on a broad risk assessment 
sleeping occupants (non-interlinked)
using data sourced from BS 5839: part 6 (2004). 
The recommendations constitute an acceptable 
Bedsit HMO of three to six storeys with individual 
benchmark and will, in the majority of cases, provide 
cooking facilities within bedsits
a reasonable level of protection. However, individual 
A mixed system:
characteristics of the subject property must always 
• Grade A: LD2 coverage in the common areas and 
be considered before specifying a particular system. 
heat detectors in bedsits (interlinked)
The recommendations below are based on properties 
• Grade D smoke alarm in each bedsit to protect the 
considered to present a normal risk for their type. 
sleeping occupants (non-interlinked)
They will have a suitable level of protection to the 
escape route and adequate other fire precautions as 
Two-storey house converted to self-contained 
recommended in this guidance. Their occupiers will 
flats (prior to Building Regulations 1991, 
not be from high-risk groups. If this is not the case 
approved document B standard) 
in the property under consideration then the risk 
A mixed system:
can be considered as higher, and it may therefore 
• Grade D: LD2 coverage in the common areas and a 
be considered appropriate to recommend a higher 
heat detector in each flat in the room/lobby opening 
standard of fire detection and warning or provide 
onto the escape route (interlinked)
additional fire safety measures as appropriate to the 
• Grade D: LD3 coverage in each flat (non-interlinked 
case. For clarification of use of the term ‘storey’, see 
smoke alarm in the room/lobby opening onto the 
the glossary.
escape route) to protect the sleeping occupants
Three- to six-storey house converted to self-
Table C4: Recommended grade and coverage of 
contained flats (prior to Building Regulations 
automatic fire detection and warning system 
1991, approved document B standard)
for various categories of existing residential 
• Grade A: LD2 coverage in the common areas and a 
premises (normal risk)
heat detector in each flat in the room/lobby opening 
onto the escape route (interlinked)
Single household occupancy up to four storeys
• Grade D: LD3 coverage in each flat (non-interlinked 
Grade D: LD3 coverage (interlinked)
housing – fire safety
25

smoke alarm in the room/lobby opening onto the 
of three or four storeys, it may be appropriate to 
escape route) to protect the sleeping occupants
provide emergency escape lighting throughout the 
escape route if the route is long or complex or where 
Building converted partly into self-contained flats 
there is no effective borrowed light. For all HMOs of 
and partly into bedsits or non-self-contained lets
five or six storeys then emergency escape lighting is 
A mixed system:
recommended, as the escape route will be long and 
• Apply the appropriate recommendation for each 
may be complex.
unit of accommodation from this table and the 
appropriate whole-house system based on the 
23.5 The recommendations for lighting of escape routes 
storey height
outlined in table C5 below are based on a broad risk 
assessment. The recommendations constitute an 
Flat in multiple occupation (FMO) (any storey 
acceptable benchmark and will, in the majority of 
height and regardless of date of construction/
cases, provide a reasonable level of safety. However, the 
conversion)
recommendations are based on buildings considered 
Grade D: LD3 coverage + additional heat detector in 
to present a normal risk for their type. They will have 
the kitchen (and shared living room depending on risk)
a suitable level of protection to the escape route and 
adequate other fire precautions as recommended in this 
guidance. Some buildings (such as the examples quoted 
23.  Lighting of escape routes 
in paragraph 23.2) will require a higher specification of 
lighting in the escape route. Again, for clarification of 
 23.1 When a fire occurs, people will be escaping in haste 
use of the term ‘storey’, see the glossary.
and in a probable state of distress or even panic. At 
night, when they have been awoken abruptly, they 
 
Table C5: Recommendations for lighting of 
may be disorientated. With this is mind, the staircase 
escape routes for various categories of existing 
and escape route must be adequately lit.
residential premises (normal risk)
23.2 In common escape routes including stairways, 
Single household occupancy up to two storeys  
conventional artificial lighting with a suitable system 
Conventional lighting 
of control should be provided so that people are able 
Single household occupancy three to six storeys 
to move within the escape route from a building 
Conventional lighting. Emergency escape lighting 
during the hours of darkness (and during the day in 
maybe appropriate if route is complex and there is 
areas that do not have the benefit of daylight). Some 
no effective borrowed light
buildings will, in addition, require emergency escape 
lighting in the escape route. These will include: 
Shared house HMO of up to two storeys (shared 
• large buildings with long escape routes;
cooking facilities)
• buildings with a complex layout;
Conventional lighting 
• buildings with no natural or borrowed lighting along 
Shared house HMO of three or four storeys 
the escape route; and 
(shared cooking facilities) 
• buildings with vulnerable occupiers or those posing 
Conventional lighting. Emergency escape lighting 
a specific risk. 
maybe appropriate if route is complex and there is 
no effective borrowed light
23.3 In most single household properties conventional 
lighting arrangements should be adequate, subject  
Shared house HMO of five or six storeys (shared 
to the above conditions. However, in larger single 
cooking facilities)
household properties, emergency escape lighting may 
Conventional lighting and emergency escape 
be required if the escape route is complex and/or there 
lighting
is no effective borrowed light. 
Bedsit HMO of one to four storeys with individual 
cooking facilities within bedsits
23.4 In buildings of up to two storeys conventional lighting 
Conventional lighting (and emergency escape 
arrangements will usually be adequate, subject to the 
lighting if risk requires or there is no effective 
above conditions. In HMOs (including shared houses) 
borrowed light)
26
housing – fire safety

lighting circuit should be installed so that the use of 
Bedsit HMO of five or six storeys with individual 
any one switch/control anywhere along the route 
cooking facilities within bedsits
will illuminate the entire escape route. However, in 
Conventional lighting and emergency escape 
large properties where the escape route is divided 
lighting
into distinct, separated sections, each section may 
have its own control provided it is obvious and 
Two, three or four storey house converted to 
visible under all conditions. In such cases (and where 
self-contained flats (prior to Building Regulations 
there is no borrowed light to the route) the switches 
1991, approved document B standard)
themselves should be illuminated. The rule is that it 
Conventional lighting (and emergency escape 
should never be necessary to search for switches. 
lighting if risk requires)
23.7 If push-button, slow release lighting switches are to 
Five or six storey house converted to self-
be used, careful consideration must be given to their 
contained flats (prior to Building Regulations 
duration setting. This should be assessed according 
1991, approved document B standard)
to risk (i.e. the distance of travel to a safe place or 
Conventional lighting and emergency escape 
final exit, the height of building, the complexity of the 
lighting
escape route and mobility of the occupiers). Where 
occupiers have limited mobility, time release switches 
Two, three or four storey building converted 
should be avoided. In all other cases the duration 
partly into self-contained flats and partly into 
must be adequate to allow a normal, orderly escape 
bedsits or non-self-contained lets
from the building and incorporate some degree of 
Conventional lighting (and emergency escape 
redundancy. The rule here is that people should never 
lighting if risk requires)
be plunged into darkness while using the route.
Five or six storey building converted partly into 
self-contained flats and partly into bedsits or 
23.8 Theft of light bulbs from common areas is a problem 
non-self-contained lets
experienced in some properties. If this is likely to be 
Conventional lighting and emergency escape 
a problem, bulb holders with a different fitting to 
lighting
those within the accommodation units should be used 
(screw holders, for example). This is good practice 
Flat in multiple occupation (FMO) occupying 
and should be standard in bedsit-type HMOs. The use 
a single storey of a building (at any storey 
of long-life, low-energy light bulbs throughout the 
height and regardless of date of construction/
property also reduces the frequency of replacement, 
conversion)
thereby helping to reduce this problem.
Conventional lighting (and emergency escape 
lighting if risk requires – may also be required in the 
24.  Emergency escape route lighting 
common escape route)
Flat in multiple occupation (FMO) occupying 
24.1 Where considered necessary, emergency escape 
more than one storey of a building (any 
lighting must be designed to comply with BS 5266. 
level and regardless of date of construction/
conversion)
24.2 It will automatically illuminate upon the failure of the 
Conventional lighting (and emergency escape 
power supply to the conventional artificial lighting, 
lighting if risk requires – may also be required in the 
when it must: 
common escape route)
• illuminate the escape route to assist the occupants 
to move easily to exits and a place of safety;
23.6 For conventional lighting most existing arrangements 
• highlight any hazards such as stairs and changes in 
will be adequate, with the following conditions:
floor level or direction; and 
• light switches/controls should be obvious, simple 
• enable easy identification of any fire alarm call 
and visible under all conditions;
points and fire fighting equipment throughout the 
• switches should be located on every landing in a 
escape route. 
convenient and conventional position; 
• in HMOs (except smaller shared houses) a dedicated 
24.3  Emergency lighting must operate not only when there is 
housing – fire safety
27

complete failure of the supply to the conventional artificial 
24.9 It is essential that the emergency lighting system 
lighting, but also when there is a localised power failure 
is routinely inspected and tested. Detailed 
within the lighting circuit that could be hazardous. The 
recommendations are contained in BS 5266 and 
source of the power supply to the emergency lighting 
discussed in paragraph 40.8. 
should be from the same local fuse as the conventional 
escape route lighting, so that in the event of that fuse 
25.  Fire fighting equipment (portable) 
failing, causing the normal lighting to fail, the emergency 
lighting will be brought into operation in the same locality.
25.1  The provision of fire blankets and simple fire 
extinguishers can be useful in restricting the 
24.4 In most cases self-contained, non-maintained luminaires 
development and spread of small fires in their early 
providing three-hour duration will be adequate. 
stages. However, unless a fire is very small, the best 
Non-maintained luminaires remain unlit when the 
advice is to evacuate the building to a place of safety 
conventional lighting power supply is healthy. When 
and call the fire and rescue service. This is because for 
it fails, the luminaire provides power to its own lamp 
larger fires people need training to know what type 
from its own battery and illuminates. Restoration of the 
of fire an extinguisher can safely be used on, how 
conventional lighting power supply switches off the 
to tackle a fire safely, and when to give up and get 
emergency luminaire and recharges its battery. 
out. The installation of extinguishers can also lead to 
problems if they are not properly maintained or where 
24.5 Emergency lighting systems are categorised as 
equipment is discharged through malice or horseplay. 
maintained or non-maintained followed by their 
For these reasons extinguishers are not recommended 
duration of illumination. So a non-maintained system 
inside units of accommodation unless there are 
with three-hour duration will be categorised as NM/3.
resident staff who are trained in their use (a caretaker, 
housekeeper, warden or similar). 
24.6 The power supply to the luminaires should be 
designed to prevent unauthorised disconnection, but 
 
In order to provide a facility for extinguishing small 
it must incorporate a suitable means for simulating a 
fires in their early stages, a simple multi-purpose 
mains failure (i.e. a test switch).
extinguisher is recommended on each floor in the 
common parts of HMOs and buildings containing 
flats. It will not usually be practical to train tenants in 
24.7 The mounting height of luminaires will be governed 
the use of these, but basic advice should be offered at 
by the physical characteristics of the building. They 
the start of each new tenancy.
should be mounted close to two metres above 
floor level (when measured to the underside of the 
luminaire) but not lower than two metres.
25.2 Fire blankets are recommended as good practice in 
kitchens of all premises covered by this guide, including 
single household occupation and bedsit rooms.
24.8 Luminaires should be sited in the following positions:
• near any intersection of corridors;
• above each final exit door;
25.3 Fire blankets should:
• near each change of direction (other than on a 
• comply with BS 6575 or equivalent;
stairway);
• be of ‘light duty’ type which are capable of dealing 
• within each stairway so that each flight of stairs 
with small fires such as cooking fires or fires 
receives direct light;
involving clothing; and
• near any change of floor level;
• be mounted on the wall approximately 1.5m high 
and closer to the room exit than the cooking facility. 
• outside any secondary escape exit if the street 
lighting is poor; 
• near each fire alarm call point; and 
25.4 Where provided, fire extinguishers should:
• near fire fighting equipment. 
• comply with BS EN 3-7;
• be maintained in accordance with BS 5306-3 (see 
paragraph 32.7); and 
 
‘Near’ is normally considered to be within two metres 
when measured horizontally. The route should be 
• be appropriate to the risk. 
reasonably uniformly lit.
28
housing – fire safety

25.5 Extinguishers should be located as follows:
suppression system supply pipes are permanently 
• on a dedicated stand or hung on wall brackets with 
charged with water, fed from the domestic water 
the handle approximately 1.5m from floor level; 
main or storage tanks. Fire suppression heads are 
• in a position such that they do not obstruct the 
fitted to the system of supply pipes, and each is an 
escape route;
independent unit and operates only if a fire causes it 
to do so.
• close to the exit position from each floor; 
• not obstructed by opening doors and not in recesses 
out of sight; and 
26.5 Suppression heads are fitted with small thermal 
elements that are activated solely by heat. The thermal 
• away from heaters or areas where they may be 
element is set to operate at a fixed temperature, not 
subject to damage.
less than 30ºC above ambient temperature, which 
makes it highly unlikely to operate other than in a fire 
26.  Automatic water suppression systems 
condition. The exception is malicious operation and 
if the fire risk assessment indicates that this is likely, 
a water suppression system may not be appropriate. 
26.1 Interest in the use of water suppression systems for 
In the majority of fires just one suppression head is 
domestic premises is growing in the UK. The use of 
operated, which is often sufficient to deal with the fire.
these systems in the United States and other parts of 
the world has proved their value in saving lives and 
reducing damage caused to property by fire. A water 
26.6 Potential uses: there is potential for water suppression 
suppression system will detect, give warning, control, 
systems to be fitted in all types of existing residential 
contain and often extinguish a fire. 
accommodation. The decision to do so will be based on:
• a cost/benefit analysis of the overall benefit gained 
26.2 The traditional concerns expressed regarding damage 
from their provision against the cost of installation 
from accidental activation of water suppression 
and maintenance;
systems can largely be discounted. The quantity 
• the practicability of their installation;
of water discharged by a suppression head when 
• the extent of design freedoms available in terms of 
activated in a fire is significantly less than that 
reduced compensatory provision of other fire safety 
disgorged in fire fighting by the fire and rescue 
measures; and 
service. In general, a water suppression system will 
• their potential for fulfilling a need where traditional 
use between 1/100th and 1/1000th of the water 
fire safety measures cannot be provided to the 
used by the fire and rescue service (source: Residential 
full recommended standard, for example where 
Sprinklers Association). Statistics show that accidental 
extended travel distances cannot be reduced to the 
operation occurs in one in 16 million cases (source: 
recommended maximum or where fire protecting 
West Midlands Fire Service guidance document for 
lobbies cannot be installed. 
design freedoms in houses in multiple occupation 
incorporating residential sprinkler systems). 
26.7 When considering a water suppression system, regard 
must be paid to the adequacy of the water supply 
26.3 It is recommended that serious consideration be 
and mains water pressure. If interruptions to supplies 
given to the role water suppression systems can play 
are possible or the water pressure is low or fluctuates, 
in existing residential accommodation. Historically, 
then additional measures such as pumping and water 
the main barrier to their installation has been cost. 
storage may be required – or indeed the installation 
Whilst cost effective in new-build property or when 
may not be feasible.
installed during major refurbishment, the retro-fitting 
of water suppression systems in existing, occupied 
residential accommodation does need a considered 
26.8 Potential design freedoms: water suppression systems 
cost/benefit analysis. However, the wider benefits of 
are not a fire safety solution in themselves. In isolation 
suppression and the cost savings resulting from any 
they cannot provide an acceptable level of fire safety in 
design freedoms offered in respect of other fire safety 
residential accommodation to meet the requirements 
measures may work in their favour.
of current legislation (see Appendix 1). However, as 
part of a comprehensive overall fire risk assessment 
they can be a key component in the overall solution 
26.4 General description: a water suppression system is 
and can contribute to a safe building. In particular the 
designed to cover a predetermined floor area. Fire 
provision of a suitable water suppression system can, 
housing – fire safety
29

in some circumstances, allow for relaxed provision of 
create an ‘institutional’ feel to a building, which is 
certain other fire safety measures (but not all). Some 
undesirable in premises which are people’s homes.
examples of design freedoms which have been applied 
include reduced fire separation/compartmentation, 
27.2 When determining whether fire safety signage should 
an alternative to a secondary means of escape where 
be provided, consideration should be given to the 
impracticable, extended travel distances and relaxed 
following criteria when carrying out the fire risk 
requirements for inner rooms. However, the provision 
assessment: 
of automatic fire detection and warning systems cannot 
be relaxed. These must still be provided as adequate 
• are all occupiers likely to be familiar with the escape 
early warning of a fire is always essential.  
route?
• which route offers the shortest travel distance?
26.9 These trade-offs or ‘design freedoms’ are not 
• are there any changes in direction in corridors, 
prescribed in any statutory guidance and must be 
stairways and open spaces which form part of the 
agreed with the relevant local housing authority, 
escape route?
building control authority and fire and rescue authority 
•  will people ever need to exit the building by a 
for each individual case. Each case will have different 
different route from which they entered?
factors and must be considered on its own merits. A 
• is there a choice of escape routes?
blanket approach to the allowance of design freedoms 
• are there any areas where confusion may occur 
should not be applied.
when exiting the building?
• is there an external secondary means of escape to a 
26.10 Standards for water suppression systems: where a 
place of safety?
water suppression system is agreed upon, its design, 
• are there any facilities or equipment provided for fire 
installation and maintenance should be in accordance 
safety that may need appropriate signage?
with BS 9251:2005 or another equivalent standard 
approved by the enforcing authority. Approval of the 
type of system and its design should be sought from 
27.3 These considerations will determine whether fire 
the enforcing authority prior to installation.
safety signage is necessary. In general this will mean 
that signage will not be necessary in single family 
houses of any type or in smaller shared houses and 
26.11 Installation should be carried out only by experienced 
HMOs with single, simple escape routes. However, 
sprinkler contractors who are suitably qualified and 
if confusion is likely for any reason, the final exit(s) 
registered with an appropriate sprinkler association 
should be provided with a sign. In larger HMOs (of 
or third party accreditation scheme such as LPS 
more than three storeys), those with complex or 
1048 scheme requirements for certificated sprinkler 
unusual layouts and those with multiple exits, signage 
installers, supervising bodies and supervised installers. 
will be required. In particular the following situations 
The installer must provide information to the landlord 
will require directional signage:
as detailed in clause 6.3.2 of BS 9251:2005. 
• the final exit;
• where there is more than one exit;
 
More detailed guidance on water suppression 
• where there is a secondary means of escape (for 
systems can be found in A guide to automatic water 
example an external staircase or roof-level exit);
suppression systems (AWSS) and their practical 
application (Chief Fire Officers Association).
• where there is a change of direction and the onward 
escape route it is not visible; and
• where there is any potential for confusion.
27.  Fire safety signs 
27.4 Any fire fighting equipment which is obscured from 
27.1 In most residential premises of average size and 
view should be indicated with a sign.
normal risk, fire safety signs and notices will not be 
required. However, in larger premises or those with 
complicated layouts or with alternative exits, the 
27.5 Generally in a domestic setting the placing of fire door 
fire risk assessment is likely to indicate some need 
signage on room doors is unpopular and unnecessary. 
for signage. The need for clear information should 
However, fire-resisting doors across escape routes and 
be balanced with the desire to maintain a homely 
doors to communal kitchens and other communal 
environment. The excessive provision of signage can 
rooms in HMOs should be marked ‘Fire door keep 
30
housing – fire safety




shut’ (see figure C9). Doors to cupboards, stores and 
• signs should be fixed above the door in the direction 
boiler rooms opening onto the escape route should be 
of escape and not be fixed to doors, as they will not 
marked ‘Fire door keep locked shut’. These provisions 
be visible if the door is open;
can be relaxed in normal-risk shared houses.
• signs mounted above doors should be at a height of 
between 2m and 2.5m above the floor;
27.6 Where fire safety signs are provided they should be in 
• signs on walls should be mounted between 1.7m 
accordance with BS 5499 and the Health and Safety 
and 2m above the floor;
(Safety Signs and Signals) Regulations 1996.
• mounting heights greater than 2.5m may be used 
for hanging signs (for example in large open spaces 
27.7 To comply, directional signs must be pictographic 
or for operational reasons) but care should be taken 
(see examples C7 and C8 below). The pictogram 
to ensure that such signs are both conspicuous and 
can be supplemented by text to make the sign 
legible. In such cases larger signs may be necessary;
easily understood, but it cannot contain only text. 
• signs within the same premises should follow a 
‘Pictogram only’ and ‘pictogram with text’ sign types 
consistent design pattern or scheme throughout; and 
should not be mixed in the same premises. Whilst 
• signs should be sited at the same height throughout 
either type of sign is acceptable, the pictogram with 
the escape route, as far as is reasonably practicable.
text style (figure C7) is thought to be more readily 
understood.
28.  Surface finishes 
 
Figure C7: Directional escape sign (pictogram with text)
28.1 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. This is of particular 
 
Figure C8: Directional escape sign (pictogram only)
concern in escape routes, especially in single staircase 
 
buildings. Arson is a particular problem in this respect: 
fires started deliberately can be particularly dangerous 
because they generally develop much faster. In multi-
 
occupancy buildings they are often started in escape 
routes, as access is more easily gained to these areas.
 
 
Figure C9: Notice for fire resisting doors 
28.2 In single household occupancy and some shared 
houses where the occupiers have exclusive control 
 
of the escape route, the risk may be low. No specific 
measures will therefore be required in respect of 
surface finishes. However, good practice would be 
to reduce the risk further by avoiding combustible 
surface finishes within the escape route. 
27.8 Where the risk is such that directional signs indicating 
the escape route are considered necessary, they should 
28.3 In multiple-occupancy buildings the risk is usually 
meet the following criteria:
higher. Combustible surface finishes should not be 
permitted within the escape route and should, as far 
• they should provide clear, unambiguous information 
as is practicable, also be avoided in other locations. 
to enable people to safely leave a building in an 
However, in some HMOs the risk may be lowered by 
emergency;
other fire precautions, such as in:
• every escape route sign should, where necessary, 
• two-storey buildings with suitable escape windows 
either incorporate or be accompanied by a directional 
from all risk rooms (see paragraph 14); 
arrow (arrows should not be used on their own);
• buildings where there is a second staircase or 
• in long or complex escape routes, signs should be 
secondary means of escape which meets certain 
positioned so that a person escaping will always 
standards (see paragraphs 17-18); and 
have the next escape route sign in sight;
housing – fire safety
31

• buildings with additional fire safety measures such 
locations for materials and products commonly 
as a water suppression system.  
encountered.
 
In such cases the premises may be considered lower 
28.7 Multiple layers of gloss paint: surfaces may be found 
risk and the precautions outlined below in respect of 
where multiple layers of gloss paint have been applied. 
surface finishes and floor coverings could be varied 
These surfaces may present a risk of fire spread. 
accordingly.
Therefore it is recommended that the paint is removed 
from locations requiring a class 1 (or C s3, d2) or class 
28.4 Materials are classified for combustibility and surface 
0 (C s3, d2) classification. Proprietary products may be 
spread of flame by BS 476: parts 6 and 7 or under the 
available which can cover the paint, thereby providing 
European system by BS EN 13501-1.
an acceptable classification for the surface. These 
should only be used subject to a satisfactory fire test 
report but may not be suitable for areas subject to 
28.5 Fire spread across surface finishes is classified as set 
heavy wear and tear.
out in table C6 below, with class 0 being the most 
resistant and class 3 the least. Classes 0-3 (or A-D) are 
29.  Floor coverings 
suitable in multi-occupied residential accommodation, 
but should be restricted in some locations. Table C6 
outlines their suitability for different locations within a 
29.1 Floor coverings throughout the protected route 
multi-occupied property.
(i.e. stairways, hallways, landings and lobbies) of all 
categories of HMO should conform to low radius of 
 
Table C6: Suitable classes of surface finish in 
fire spread (up to 35mm) when tested in accordance 
certain locations in multi-occupied residential 
with BS 4790 or the European equivalent. It is good 
buildings
practice to adhere to this in all categories of HMO, 
although in lower risk shared houses this requirement 
may be relaxed. 
Class 0, B s3, d2
These are non-combustible materials and materials 
of limited combustibility such as brickwork, concrete, 
29.2 BS 5287 Specification for assessment and labelling of 
plasterboard and plastered finishes.
textile floor coverings tested to BS 4790 specifies how 
Acceptable in all locations including protected 
these tested floor coverings should be labelled.
routes, circulation routes, escape routes and 
stairways. 
29.3 It is, of course, difficult to assess existing floor 
coverings in HMOs unless the supplier/manufacturer 
Class 1, C s3, d2
can be traced. As a general guide for existing carpets, 
These include timber, particleboard, hardboard and 
those comprising a mix of 80% wool and 20% 
surfaces covered with heavy flock wallpaper, provided 
synthetic fibre (commonly referred to as 80/20 carpets) 
they have been treated with flame retardant materials.
will comply. Many vinyl, linoleum and laminate floor 
Acceptable in rooms.  
coverings may not be suitable and will need replacing. 
Class 3, D s3, d2
These include those specified in class 1 with the 
29.4 When considering the suitability of new floor 
addition of thermosetting plastics and surfaces 
coverings for protected routes it is sufficient to 
covered with polystyrene wall and ceiling tiles. 
ensure they are labelled to BS 5287 or the European 
Not acceptable on escape routes and stairways. 
equivalent as low radius of fire spread (up to 35mm). 
Acceptable in small rooms and parts of other rooms 
Suppliers/manufacturers will be able to verify this (or 
if the total area does not exceed more than one half 
otherwise).
of the floor area up to a maximum of 20m².
 
30.  Special provisions relating to ‘back-to-back’ 
Not acceptable on escape routes and stairways.
houses 
28.6 It is very difficult to identify the classification of 
30.1  In certain areas of the country there remain a 
existing coverings on-site unless the trade name of the 
significant number of ‘back-to-back’ houses. These 
product can be traced. Table C6 illustrates acceptable 
typically back directly onto one another at the party 
32
housing – fire safety

wall and have other houses either side. This means 
be adopted and may include the construction of a 
there is only one exit from the house and the escape 
30-minute protected escape route inside the house, 
route inevitably passes through a risk room. This 
60-minute separation between the ground and first 
arrangement should be avoided wherever possible, 
floors, the installation of a water suppression system 
but it is recognised that significant numbers of 
(see paragraph 26) and the setting of conditions 
these houses do still exist and they make a valuable 
relating to facilities for calling the fire and rescue 
contribution to affordable housing supply. Any risk 
service in an emergency (for example linking the fire 
assessment carried out on a back-to-back house will 
alarm system to a monitoring centre or the FRA). 
identify higher than normal risk and will recommend 
special fire precautions accordingly. Back-to-back 
 
A sample case study is given in Part D at paragraph 39 
houses are restricted to certain areas of the country 
(D15). 
and LHAs and FRAs have developed local fire safety 
solutions for the types of houses in their areas, taking 
account of local building design and local need. 
30.4 This type of housing presents a particular risk, and 
Because of their specialist nature it is not appropriate 
some LHAs and FRAs may require alternative solutions 
to offer complete solutions to apply nationally in this 
including higher standards where appropriate.  
guidance, as layouts and situations vary and the risk 
assessment must take account of this and recommend 
31.  Mixed commercial and residential use 
solutions as appropriate. While some basic solutions 
are outlined here for the sake of completeness, local 
guidance may be more comprehensive. 
31.1 Residential accommodation is often situated above 
or within commercial premises. Any fire in the 
commercial premises will affect the residential parts, 
30.2 Solutions for back-to-back houses will inevitably rely 
and at night may not be noticed until well developed. 
heavily on the following main principles:
The risk assessment will assess how high the risk from 
the commercial premises is, but it may be significantly 
• the provision of a suitable escape window at first 
higher than the risk from the residential parts (for 
floor level accessible to all occupiers of the upper 
example where the accommodation is above a pub, 
floors (see paragraph 14). Because of the design of 
restaurant or dry cleaners).
this type of house it may not be possible to provide 
more than one escape window from the first floor. 
31.2 Generally there should be 60-minute imperforate 
Where this is the case and the escape window is 
separation between the two uses. In lower risk 
from a habitable room, the door to that room must 
commercial premises it may be possible to reduce 
not be fitted with locks and any tenancy agreement 
this to 30 minutes where there is an automatic 
should ideally prohibit the fitting of locks (unless of 
fire detection system in the commercial parts 
a type that can be overridden from outside the room 
which is linked to the residential system. In higher 
without the need for a key, tool or code);
risk premises, even where 60-minute separation 
• a suitable automatic fire detection and warning 
is achieved it may still be appropriate to provide 
system. The grade and coverage of the system 
an automatic fire detection system linked to the 
will depend on the risk the house presents (see 
residential system.
paragraph 22.12 and table C4); 
• an appropriate degree of fire separation between 
31.3 In some cases imperforate separation proves 
the ground floor and the upper floors. Full 
impracticable to achieve, for example with some 
30-minute separation will usually be appropriate 
accommodation above pubs. In these cases 
with a FD30S fire door at the foot of the stairs 
compensatory measures should be considered such 
leading from the ground floor to the first floor; and 
as fire protecting lobbies between the two uses, a 
• where a basement or cellar exists then the guidance 
secondary means of escape, or in high-risk situations a 
in paragraphs 10 and 11 should be applied, with 
water suppression system in the commercial premises.
higher standards of separation as appropriate in the 
higher risk back-to-back properties. 
32.  Management and maintenance of fire safety 
30.3 Where the conditions for escape windows cannot be 
32.1 Whatever physical fire safety measures are provided 
met (see paragraph 14), other solutions will need to 
in residential accommodation, their effectiveness 
housing – fire safety
33

will only be as good as their management and 
• all doors should be close fitting as designed. Fire 
maintenance. While single household dwellings will 
doors should never be propped or wedged open. 
generally be self-managing, HMO accommodation 
Any damage to fire doors should be noted and 
will require ongoing attention to ensure fire safety 
repaired. Any damaged or missing smoke seals must 
measures remain effective. This section outlines 
be replaced like-for-like.
management and maintenance measures applicable 
to HMOs. The responsible person (the licensee, 
32.5 Automatic fire detection (AFD) and warning systems: 
landlord or managing agent) has a duty to ensure 
BS 5839: part 1, section 6 contains recommendations 
that the day-to-day management of fire safety in the 
for regular, routine testing of AFD systems as follows: 
premises is properly undertaken and that essential 
routine maintenance and emergency repairs are 
properly carried out. This is not only common sense 
Grade A systems  
and good practice, but also an obligation in law for 
• Routine testing – at least one detector or call point 
those premises to which The Management of Houses 
in each zone should be tested weekly to ensure 
in Multiple Occupation Regulations 2006 and the FSO 
correct operation of the system. Any defect should 
apply (see Appendix 1, paragraphs A.45 and A.51).
be recorded in the log book and action taken to 
correct it.
32.2 The level of management attention required will 
• Routine maintenance – a six-monthly service should 
be determined as part of the fire risk assessment. 
be carried out by a competent person, usually a 
Detailed recommendations are to be found in the 
specialist alarm engineer, under a maintenance 
HM Government Fire Safety Risk Assessment Sleeping 
contract. It entails a full test to ensure compliance 
Accommodation Guide. These recommendations may 
as specified in with BS 5839: part 1, section 6. It 
be appropriate in very large and complex buildings, 
should be recorded in the log book and a periodic 
but not all will apply fully for the average residential 
inspection and test certificate issued.
accommodation of normal risk covered by this guide. 
Grade D and E systems
32.3 Guidance on best practice in fire safety management 
• Routine testing – these systems should be tested 
can be found in BS 5588, part 12: 2004 Fire 
every month by use of the test button on the smoke 
precautions in the design, construction and use 
alarm. 
of buildings – managing fire safety, but the points 
• Routine maintenance – all alarms should be cleaned 
outlined below should be expected in any acceptable 
periodically in accordance with the manufacturer’s 
fire risk assessment as a minimum. 
recommendations.
 
32.4 Escape routes: 
All systems
• must be free from obstruction at all times, and 
• It is recommended that all detectors should be 
regular checks should be made to guarantee this; 
tested at least once a year to ensure that they 
• there should be no free storage on the escape 
respond to smoke. Tests should not involve the use 
routes; 
of open flame or any form of smoke or non-specific 
• there should be no trip hazards such as trailing 
aerosol that could contaminate the detection 
electrical leads or worn carpets;
chamber or the electronics of the detector. Suitable 
•  in most cases fire-resisting doors should be 
specific test aerosols are available. The test is usually 
effectively self-closing to engage their latches with 
carried out by a specialist alarm engineer under a 
no obstructions or hindrances such as catching 
maintenance contract and should be recorded in 
carpets. This will always be the case in bedsit-type 
the log book, with a periodic inspection and test 
HMOs. However, the requirement for self-closers is 
certificate issued.
considered unnecessary in some situations, such as 
individual room doors within flats (the flat entrance 
32.6 It is recognised that the above arrangements represent 
door will still require one), within single household 
the ideal. While they may be possible in buildings 
occupancies, and in smaller low-risk shared houses. 
with a resident landlord or a dedicated caretaker 
The use of self-closers in these situations has proved 
or housekeeper, in most situations for premises 
impracticable and has often rendered the doors 
covered by this guide such arrangements may be 
ineffective; 
impracticable. Where this proves to be the case 
34
housing – fire safety

tenants should be given clear instructions on how 
maintain the system in accordance with clause 7 
to test grade D or E alarms within their dwelling 
(maintenance) of BS 9251;
using the test button, along with clear recording and 
• the responsible person must ensure that the system 
reporting instructions for any faults or false alarms on 
is fully functional at all times and that any defects 
the system. Grade A systems are more specialist and 
are rectified as soon as possible;
resident testing will be inappropriate unless there is a 
• the responsible person should check the pressure 
trained individual in the property. Clear fault and false 
gauge readings monthly and record these readings 
alarm reporting arrangements should be put in place, 
in the systems log book. Any significant fluctuations 
and the responsible person or his/her agent should 
or pressure readings below the agreed system 
respond to reports at the earliest opportunity.
design must be rectified immediately; and 
• the system log book must be used to record all 
32.7 Fire blankets and extinguishers: 
actuations, testing, maintenance, system faults and 
• where provided, these should be checked 
any remedial action.
periodically to make sure they are in place and 
available for use. Extinguishers must be tested and 
32.10 Gas installations (see Appendix 1, paragraph A.67): 
maintained on an annual basis in accordance with 
BS 5306-3 and with the manufacturer’s instructions.
• The Gas Safety (Installation and use) Regulations 
1998 require that gas installations and appliances 
are maintained in safe condition and good working 
32.8 Artificial lighting: 
order and receive a gas safety check annually. 
• conventional staircase lighting must be working 
The gas safety check and any other work to the 
properly at all times. Any blown bulbs should be 
installation may only be carried out by a competent 
replaced and all switches should be working. If timer 
and registered engineer. The findings must be 
switches are fitted then the duration should be 
recorded and the records kept for at least two years.
checked and adjusted if necessary; and 
• any emergency escape lighting should be serviced 
32.11 Electrical installations (see Appendix 1, paragraph 
and maintained in accordance with BS 5266-8: 2004 
A.73): 
(BS EN 50172: 2004) Emergency escape lighting 
• the electrical installation should be installed 
systems. This contains detailed recommendations 
and maintained by a competent person and 
which include inspections and tests to be carried 
should be inspected periodically by a competent 
out, down to a daily basis. For large, complex 
electrical engineer. An inspection every five years 
HMOs (such as those with five or six storeys) or 
is recommended for all types of premises and is a 
premises with a specific high-risk factor (persistent 
legal requirement in HMOs under the Management 
vandalism problems, for example, or complex escape 
of Houses in Multiple Occupation (England) 
routes and no effective borrowed light), the full 
Regulations 2006 (see Appendix 1, paragraph A.45).
recommendations may be appropriate. However, in 
most average sized premises with normal risk, the 
following regime with a procedure for responding to 
32.12 Electrical appliances: 
reports of defects should be adequate:
• letting agents and landlords should check all 
• an annual discharge test in accordance with the 
electrical appliances at the start of each new 
requirements of BS 5266: part 8. This must be 
tenancy for defects (for example frayed wiring or 
carried out by a competent person, usually a lighting 
badly fitted plugs) and remove any unsafe items;
engineer under a maintenance contract. It entails a 
• it is good practice to have the equipment checked 
full test to ensure compliance with the standard and 
at regular intervals thereafter, but there is no legal 
should be recorded in the log book, with a periodic 
requirement to do so unless appliances are used by 
inspection and test certificate issued.
employees;
• records should be kept of the checks carried out;
32.9 Water suppression systems: 
• instruction booklets should be available at the 
• where provided, the responsible person must 
property for all appliances and any necessary safety 
ensure that any water suppression system is 
warnings should be given to tenants; and  
fully maintained and ready for use at all times. 
• second-hand electrical appliances should not 
The landlord should enter into a maintenance 
be supplied, but if they are then they should be 
contract with a competent person or company to 
checked by a competent electrical engineer.
housing – fire safety
35

32.13 Furniture and furnishings regulations (see Appendix 
32.15 Record keeping: 
1, paragraph A.61): 
• it is recommended that a property log book is kept 
• all furniture within lettings commencing after 
and all routine maintenance and servicing activity 
1 January 1997 must meet fire resistance 
(as recommended in this guide) is recorded in it, 
requirements. However, the regulations do not apply 
along with all reported defects and remedial action 
to furniture made before 1950 and re-upholstered 
taken – including false alarms. Model log books may 
furniture made before that date;  
be available from landlords associations or through 
• all new furniture (except mattresses and bed bases) 
landlord accreditation schemes.
must carry a permanent label stating that it complies 
 
with the fire resistance standards. However, absence 
of such a label does not mean that the furniture does 
Part D: some risk-based case studies of fire 
not comply, as the label may have been removed 
safety solutions in certain catagories of 
after the furniture was supplied. Some furniture 
manufactured before the regulations were applied 
residential accomodation
may comply with the requirements anyway; and
• landlords and managing agents must ensure that 
33.  Introduction 
the furniture supplied meets the fire resistance 
requirements, and the only practical way of doing 
so is to ensure that the furniture is labelled by 
33.1 This chapter considers some commonly encountered 
the manufacturer in this way. If this cannot be 
types of residential premises and provides suggested 
ascertained then the furniture should be replaced.
fire safety solutions which could be applied to achieve 
a reasonable and acceptable standard of fire safety in 
each. In each case the solutions are based on a fire risk 
32.14 Information and training: 
assessment. If the fire safety measures recommended 
• each occupier should be given specific advice on 
are applied to buildings of similar risk, those buildings 
fire prevention and fire safety in the home. This 
should meet the requirements of the legislation 
should be provided at the start of each new tenancy 
applying to them as outlined in Appendix 1. If the 
and reviewed periodically. Suitable advice can be 
recommendations and risk methodology of this guide 
found in annexe one of BS 5588: part 12, Advice 
are applied, no additional works should be necessary 
to occupiers of domestic residential buildings, and 
to meet any of the requirements.
advice is also available from local fire and rescue 
authorities. Information should include: 
 
The recommendations in this chapter must be read in 
• an explanation of the escape routes, particularly 
conjunction with Part C, which gives more details on 
where secondary means of escape is provided;
individual provisions and applies some conditions to 
• how the fire detection and alarm system operates 
these recommendations. 
and what to do if it activates;
• how and when to re-set the fire alarm system;
33.2 The solutions recommended here are considered 
• if extinguishers or fire blankets are provided, 
to be the most conventional and practical for most 
training in their application and safe use;
situations. There is no obligation to adopt these 
• avoidance of false alarms;
exact solutions, and it is possible that the relevant 
• how and when to call the fire brigade;
requirement can be met in some other way. However, 
any alternative arrangement will need to achieve 
• how to report defects;
at least an equivalent level of fire safety, and the 
• the importance of maintaining clear escape 
responsible person will need to demonstrate that this 
routes, free of storage; 
is the case. The interaction between the individual 
• the importance of keeping fire doors closed, not 
fire safety measures is key. Where a higher standard 
propped or wedged open;
of protection is provided than is recommended here, 
• smoking and cooking safety;
it may be possible to provide a compensating lower 
• gas safety advice;
standard in some other respect (and vice versa). For 
example, in lower risk premises a reduced level of fire 
• safe storage and disposal of refuse; and 
separation may be acceptable if a higher standard of 
• the safe use of escape windows where 
fire detection and warning system is provided. Equally, 
appropriate.
the installation of a fixed water suppression system 
36
housing – fire safety

(sprinkler system) may allow a reduced standard of fire 
but the escape route should have  sound, conventional 
separation. Variations on such themes will need to be 
construction and should not pass through risk rooms
considered on their merits, and agreement will need 
to be sought from the relevant enforcing authority.
No requirement for fire doors note 5, but sound, well 
constructed and close-fitting conventional doors are 

33.3 The examples in this section assume a normal level of 
required
risk. They assume that:
Alternatively, provide suitable escape windows from 
• occupiers are able-bodied and capable of evacuating 
bedrooms and living rooms (see paragraph 14)
the building unaided;
• occupiers are not from any particular vulnerable 
Fire separation (see paragraph 19)
group (for example people with impaired sight or 
No requirement for additional fire resistance, but 
hearing, the elderly or frail, or people with alcohol 
walls and floors should be of sound, conventional 
or drug dependency); and
construction
• there are no particular high-risk factors present in 
the building such as commercial uses, large storage 
If a basement/cellar is present, 30-minute separation 
areas or the use of open fires. 
between the cellar and the ground floor escape route 
is the ideal (but see paragraph 19.6 regarding existing 
construction)

 
Where this is not the case and higher risk factors are 
 
present, higher levels of fire safety precautions may be 
Fire detection and alarm system (see paragraph 22) 
required.
Grade D, LD3 system
• interlinked mains wired smoke alarms with integral

33.4 The descriptions of the various categories of residential 
battery back-up located in the escape route at 
premises covered in this chapter will not necessarily 
ground and first floor levels; and
match every situation, and professional judgment will be 
• additional interlinked smoke alarms with integral
needed where variations occur. For clarification of use of 
battery back-up located in any cellar
the term ‘storey’, see the glossary. This chapter contains 
case studies for the following categories of premises:
Lighting of escape routes (paragraphs 23-24) 
• single occupancy accommodation;
No requirement for emergency escape lighting, but 
• shared houses;
conventional artificial lighting is required
• bedsit-type HMOs;
Fire fighting equipment (see paragraph 25) 
• buildings converted to self-contained flats; and
It is recommended good practice to provide a fire 
• flats in multiple occupation.  
blanket in the kitchen
34.  Single household occupancy 
Fire safety signs (see paragraph 27) 
No requirement

 
Houses, flats and maisonettes occupied by persons 
living as a single household. The term ‘household’ 
Surface finishes & floor coverings (paragraphs 28-29) 
means either a single person or members of the same 
No requirement
family who are living together. This includes people 
who are married or living together as married (including 
Management and maintenance of fire safety
those in same-sex relationships). ‘Family’ means specific 
It is recommended that all doors are kept closed at 
relatives: parents, grandparents, children and step-
night (see paragraph 32)
children, grandchildren, brothers, sisters, uncles, aunts, 
nephews, nieces or cousins. Foster children are also 
 
note 5: where construction standards are poor, 
treated as part of their parents’ household.
travel distances are long or other higher risk factors 
are present, a 30-minute protected route may be 

 
Case study D1: Single household occupancy of no 
required. 
more than two storeys (see figure D1)
  
 
Escape routes (see paragraph 9)
 
No requirement for full 30-minute protected route note 5, 
housing – fire safety
37


 
Case study D2: Single household occupancy of 
Fire safety signs (paragraph 27) 
three or four storeys (see figure D2)
No requirement
 
Escape routes (see paragraph 9) 
Surface finishes & floor coverings (paragraphs 
No requirement for full 30-minute protected route 
28-29)
note 6, 
but the escape route should have sound conventional 
No requirement
construction and the travel distance should not be 
Management and maintenance of fire safety
excessive 
It is recommended that all doors are kept closed at 
No requirement for fire doors 
night (see paragraph 32)
note 6, but sound, well 
constructed and close-fitting conventional doors are 
required

 
note 6: where construction standards are poor, travel 
distances are long or other higher risk factors are 

Fire separation (see paragraph 19) 
present, a 30-minute protected route may be required. 
No requirement for additional fire resistance, but 
 
walls and floors should be of sound, conventional 
 
Case study D3: Single household occupancy of 
construction
five or six storeys (see figure D3)
If a basement/cellar is present, 30-minute separation 
Escape routes (see paragraph 9)
between the cellar and the ground floor escape route 
30-minute protected route is required, including 
is required
30-minute fire-resisting construction and FD30 doors to 
all risk rooms (without smoke seals – see paragraph 21.3). 

Fire detection and alarm system (see paragraph 22)
Secondary means of escape is required from top floor
Grade D, LD3 system
• interlinked mains wired smoke alarms with integral

Fire separation (see paragraph 19)
battery back-up located in the escape route at all 
No requirement for additional fire resistance generally, 
floor levels; and 
but walls and floors should be of sound, traditional 
• additional interlinked smoke alarms with integral
construction. Lateral fire-resisting separation of the top 
battery back-up located in any cellar
two floors from the remainder of the house is required. 
 
If a cellar is present, provide 30-minute separation 
Lighting of escape routes (paragraphs 23-24) 
between the cellar and the ground floor escape route
No requirement for emergency escape lighting, but 
conventional artificial lighting is required

Fire detection and alarm system (see paragraph 22)
Grade A, LD3 system

Fire fighting equipment (see paragraph 25) 
• detection throughout common parts, in the kitchen
It is recommended good practice to provide a fire 
(heat detection) and any cellar
blanket in the kitchen
38
housing – fire safety


Lighting of escape routes (paragraphs 23-24)
has been rented out by an identifiable group of 
No requirement for emergency escape lighting, but 
sharers such as students, work colleagues or friends 
conventional artificial lighting is required
as joint tenants. Each occupant normally has their 
own bedroom but they share the kitchen, dining 
Fire fighting equipment (see paragraph 25)
facilities, bathroom, WC, living room and all other 
It is recommended good practice to provide a fire 
parts of the house. All the tenants will have exclusive 
blanket in the kitchen
legal possession and control of all parts of the house, 
including all the bedrooms. There is normally a 
Fire safety signs (see paragraph 27)
significant degree of social interaction between the 
Directional fire exit signs indicating way to secondary 
occupants and they will, in the main, have rented out 
means of escape
the house as one group. There is a single joint tenancy 
agreement. In summary, the group will possess many 
Surface finishes & floor coverings (paragraphs 28- 29)
of the characteristics of a single family household, 
No requirement
although the property is still technically an HMO as 
the occupants are not all related.
Management and maintenance of fire safety
 
(see paragraph 32)
35.3 The exact arrangements will vary from house to house 
and this may result in ‘grey areas’ in determining 
whether a house is a true shared house which 
35.  Shared houses
therefore presents a lower fire safety risk due to 
 
the mode of occupation. Each case will need to be 
35.1 There is no legal definition of a ‘shared house’ and so 
considered on its merits.
this term can sometimes cause confusion. Whilst shared 
houses fall within the legal definition of an HMO (see 
35.4 Even if a property is occupied as a shared house, the 
Appendix 1, paragraph A.32) and will be licensable 
fire risk may still increase if the property is of a non-
where licensing criteria are met, it is recognised that 
standard layout or if the occupants present a higher 
they can often present a lower fire risk than traditional 
risk due to factors such as limited mobility or drug/
bedsit-type HMOs due to their characteristics. 
alcohol dependency (see paragraph 9.3).  
35.2 For the purposes of this guidance, shared houses 
are described as HMOs where the whole property 
housing – fire safety
39


35.5 Whilst all HMOs are still subject to the Housing Act 
the first floor). In September he lets the first floor 
2004, the FSO does not apply to shared houses that 
to tenants C and D, with a right to use the kitchen 
meet the criteria set out above. This is because the 
and living room (but not full possession of the whole 
occupants have exclusive use of the whole house. 
house). Then the ground floor will be treated as being 
used as a private dwelling because it includes the 
35.6 However, the following two examples are intended to 
kitchen and living room but the first floor will not, 
expand on this description and assist in making that 
because, although C and D have the right to use 
judgment:
the kitchen and living room, it is not comprised in 
their tenancy agreement. They do not have exclusive 
possession of a dwelling and therefore the FSO will 
 
example 1
apply. 
 
A two-storey house with kitchen and living room on 
the ground floor and bathroom on the first floor. The 
 
The following examples set out an approach to fire 
whole house is let to four tenants, A, B, C and D, who 
safety that may be appropriate in shared houses that 
have exclusive possession of the whole house. The 
present no additional risk factors (as explained above). 
house will therefore be used as a private dwelling by 
Where additional risk factors are present then a higher 
A, B, C and D jointly, as domestic premises and the 
standard of fire precautions may be necessary, having 
FSO will not apply.
regard to the fire risk assessment.
 
The position will be different if there is not exclusive 
 
possession of the whole house, as follows:
 
example 2
 
In July, the landlord lets the ground floor of the house 
(including the kitchen and living room) to tenants 
A and B, giving them a right to use a bathroom on 
40
housing – fire safety


 
Case study D4: Shared house of no more than 
Lighting of escape routes(paragraphs 23-24)
two storeys
No requirement for emergency escape lighting, but 
conventional artificial lighting is required

Escape routes(see paragraph 9)
No requirement for full 30-minute protected route 

Fire fighting equipment(see paragraph 25)
note 
Fire blanket to be provided in the kitchen
7, but the escape route should have sound, traditional 
construction and should not pass through risk rooms.

  Simple multi-purpose fire extinguisher in the hallway 
No requirement for fire doors 
recommended
note 7, but sound, well 
constructed and close-fitting conventional doors 
are required. Alternatively, provide suitable escape 

Fire safety signs (see paragraph 27)
windows from bedrooms and living rooms (see 
No requirement
paragraph 14)
Surface finishes & floor coverings(paragraphs 28-29)
Fire separation(see paragraph 19)
No requirement
No requirement for additional fire resistance, but 
walls and floors should be of sound, traditional 

Management and maintenance of fire safety
construction. If a basement/cellar is present, 
It is recommended that all doors are kept closed at 
30-minute separation between the cellar and the 
night (see paragraph 32)
ground floor escape route is the ideal, but see 
paragraph 19.6 regarding existing construction

 
note 7: where construction standards are poor, 
travel distances are long or other higher risk factors 

Fire detection and alarm system(see paragraph 22)
are present, a 30-minute protected route may be 
Grade D, LD3 system:
required. 
• interlinked mains wired smoke alarms with integral
 
battery back-up located in the escape route at all 
 
Case study D5: Shared house of three or four 
floor levels;
storeys (see figure D5)
• additional interlinked heat alarm with integral
battery back-up located in the kitchen;
Escape routes (see paragraph 9)
• additional interlinked smoke alarm with integral
30-minute protected route note 8, is required, including 
battery back-up located in the lounge; and
30-minute fire-resisting construction and FD30 doors 
• additional interlinked smoke alarms with integral
to all risk rooms (without smoke seals – see paragraph 
battery back-up located in any cellar.
21.3). Travel distance must not be excessive
housing – fire safety
41


Fire separation (see paragraph 19)
Surface finishes & floor coverings (paragraphs 28-29)
No requirement for additional fire resistance, but walls 
No requirement
and floors should be of sound, traditional construction.
If a cellar is present, 30-minute separation is required 

Management and maintenance of fire safety
between the cellar and the ground floor escape route
(see paragraph 32)
 
Fire detection and alarm system (see paragraph 22)
 
note 8: three-storey properties only: the ideal 
Grade D, LD3 system:
situation is for the escape route to be enclosed in 
• interlinked mains wired smoke alarms with integral
30-minutes fire resisting construction and FD30 
battery back-up located in the escape route at each 
fire doors. However, in existing three-storey shared 
floor level;
houses of low risk it may be possible to accept existing 
• additional interlinked heat alarm with integral
walls and partitions if 20-minutes fire resistance 
battery back-up located in the kitchen;
can be achieved. This is likely to be met if walls and 
• additional interlinked smoke alarm with integral
partitions are of sound, conventional construction. 
battery back-up located in the lounge; and
Sound lath and plaster construction should meet this 
• additional interlinked smoke alarms with integral
requirement. Doors onto the escape route may be 
battery back-up located in any cellar.
acceptable if they are of sound, solid construction, are 
close fitting and self-closing.   

Lighting of escape routes (paragraphs 23-24)
 
Emergency escape lighting required only if the route 
is long or complex or where there is no effective 

 
Case study D6: Shared house of five or six 
borrowed light
storeys (see figure D6)
Conventional artificial lighting required
Escape routes (see paragraph 9)
Fire fighting equipment (see paragraph 25)
30-minute protected route is required, including 
Fire blanket to be provided in the kitchen
30-minute fire-resisting construction and FD30S doors 
Simple multi-purpose fire extinguisher on each landing  
to all risk rooms (with smoke seals). Travel distance 
recommended
must not be excessive
Fire safety signs (see paragraph 27)
Five storeys 
Signage only required if the escape route is complex
Lobby protection to all floors except the top floor or 
secondary means of escape from top floor 

42
housing – fire safety


Six storeys
Lobby protection to all floors except the top floor and 

Surface finishes & floor coverings (paragraphs 28-29)
secondary means of escape from top two floors
No requirement
Fire separation (see paragraph 19)
Management and maintenance of fire safety
No requirement for additional fire resistance generally, 
(see paragraph 32)
but walls and floors should be of sound, traditional 
 
construction. Lateral fire-resisting separation of the 
top floor (in five storey) or top two floors (in six storey) 

36.  Bedsit-type HMOs
from the remainder of the house is required. If a cellar 
is present, provide 30-minute separation between the 

 
These are HMOs which have been converted into a 
cellar and the ground floor escape route.
number of separate non-self-contained bedsit lettings 
or floor-by-floor lets. Typically there will be individual 
Fire detection and alarm system (see paragraph 22)
cooking facilities within each bedsit, but alternatively 
Grade A, LD2 system
there may be shared cooking facilities or a mixture 
• detection throughout escape route and all risk
of the two. Toilets and bathing/washing facilities will 
rooms including living rooms, kitchen (heat 
mostly be shared. There is unlikely to be a communal 
detection) and any cellar
living or dining room. Each bedsit or letting will be let 
to separate individuals who will live independently, 
Lighting of escape routes (paragraphs 23-24)
with little or no communal living between tenants. 
Emergency escape lighting required 
Each letting will have its own individual tenancy 
Conventional artificial lighting required
agreement and there will usually be a lock on each 
individual letting door.
Fire fighting equipment (see paragraph 25)
Fire blanket to be provided in the kitchen

 
Case study D7: Bedsit-type HMO of no more than 
Simple multi-purpose fire extinguisher on each landing 
two storeys (see figure D7)
recommended
Escape routes (see paragraph 9)
Fire safety signs (see paragraph 27)
30-minute protected route note 9 is required, including 
Signage only required if the escape route is complex 
30-minute fire-resisting construction and FD30S doors 
or where there is a secondary means of escape
to all risk rooms. Travel distance must not be excessive
housing – fire safety
43


Fire separation (see paragraph 19)
Fire safety signs (see paragraph 27)
No requirement for additional fire-resisting separation 
Signage along escape route if the escape route is 
between units, but walls and floors should be of 
complex
sound, traditional construction
Surface finishes & floor coverings
Fire detection and alarm system (see paragraph 22)
(see paragraphs 28-29)
Mixed system
Grade D, LD2 system

Management and maintenance of fire safety
• interlinked mains wired smoke alarms with integral
(see paragraph 32)
battery back-up located throughout the escape route
 
note 9: a full 30-minute protected route is the 
Where cooking facilities are sited within the bedsits:
preferred (ideal) option. However, in two-storey, 
• interlinked heat alarms with integral battery back-up
normal risk HMOs the provision of suitable escape 
located in each bedsit; and
windows from all bedsit rooms may be acceptable in 
• additional non-interlinked smoke alarm with integral
lieu of a fully protected route.
battery back-up located in each bedsit.
 
 
Case study D8: Bedsit-type HMO of three or four 
Where cooking facilities are sited in shared kitchen, 
storeys (see figure D8)
not within bedsits:
• interlinked smoke alarms with integral battery back-

up located in each bedsit;
Escape routes (see paragraph 9)
• interlinked heat alarms with integral battery back-up
30-minute protected route is required, including 
located in each communal kitchen; and
30-minute fire-resisting construction and FD30S doors 
• additional interlinked smoke alarms with integral
to all risk rooms. Travel distance must not be excessive
battery back-up located in any cellar.
Fire separation (see paragraph 19)
Lighting of escape routes (paragraphs 23-24)
No requirement for additional fire-resisting separation 
Emergency escape lighting required only if the route 
between units, but walls and floors should be of 
is long or complex or where there is no effective 
sound, traditional construction
borrowed light
Conventional artificial lighting required

Fire detection and alarm system (see paragraph 22)
Mixed system

Fire fighting equipment (see paragraph 25)
Grade A, LD2 system
Fire blanket to be provided in each bedsit with 
• smoke detectors located throughout the escape route
cooking facilities and in shared kitchens. Simple multi-
purpose extinguisher on each floor in the common 
parts recommended

44
housing – fire safety


Where cooking facilities are sited within the bedsits:
 
Case study D9: Bedsit-type HMO of five or six 
• interlinked heat detectors located in each bedsit; and
storeys (see figure D9)
• additional Grade D, non-interlinked smoke alarm
with integral battery back-up located in each bedsit.
Escape routes (see paragraph 9)
30-minute protected route is required, including 

Where cooking facilities are sited in shared kitchen, 
30-minute fire-resisting construction, and FD30S doors 
not within bedsits:
to all risk rooms. Travel distance must not be excessive
• interlinked smoke detectors located in each bedsit;
• heat detectors located in each kitchen; and

Five storeys 
• additional interlinked smoke detectors located in
Lobby protection to all floors except the top floor or 
any cellar.
secondary means of escape from top floor 
Lighting of escape routes (paragraphs 23-24)
Six storeys
Conventional lighting is required.
Lobby protection to all floors except the top floor and 
Emergency escape lighting maybe appropriate if route 
secondary means of escape from top two floors 
complex or there is no effective borrowed light
Fire separation (see paragraph 19)
Fire fighting equipment (see paragraph 25)
30-minute fire separation between units of 
Fire blanket to be provided in each bedsit with 
accommodation throughout
cooking facilities and in shared kitchens
30-minute fire separation across the stairway between 
Simple multi-purpose extinguisher on each floor in the 
second and third floors and between fourth and fifth 
common parts recommended
floors
Fire safety signs (see paragraph 27)
Fire detection and alarm system (see paragraph 22)
Final exit sign and signage along the escape route if 
Mixed system
the escape route is complex
Grade A, LD2 system
• smoke detectors located throughout the escape

Surface finishes & floor coverings
route
(see paragraphs 28-29)
Where cooking facilities are sited within the bedsits:
Management and maintenance of fire safety
• heat detectors located in each bedsit;
(see paragraph 32)
• additional Grade D, non-interlinked smoke alarm;
housing – fire safety
45


with integral battery back-up located in each bedsit.
37.  Houses/buildings converted to self-contained flats 
 
Houses or buildings converted into self-contained flats 
Where cooking facilities are sited in shared kitchen, 
where the conversion did not (and does not) meet 
not within bedsits:
the building standards under the Building Regulations 
• smoke detectors located in each bedsit;
1991. Buildings that were converted to a standard 
• heat detectors located in each kitchen; and
meeting those regulations and which still meet them 
• additional interlinked smoke detectors located in
are not included here, as they will not require additional 
any cellar.
fire safety measures unless occupied in a manner other 
than intended under the original conversion scheme – 
Lighting of escape routes (paragraphs 23-24)
for example, occupation of a flat as a flat in multiple 
Emergency escape lighting required
occupation (see section E) – or where an additional risk 
Conventional artificial lighting required
has been introduced post-conversion.
Fire fighting equipmeny (see paragraph 25)
Fire blanket to be provided in each bedsit with 

 
Case study D10: Two-storey building converted 
cooking facilities and in shared kitchens
into self-contained flats (see figure 10)
Simple multi-purpose extinguisher on each floor in the 
common parts recommended

Escape routes (see paragraph 9)
30-minute protected route is required, including 

Fire safety signs (see paragraph 27)
30-minute fire-resisting construction and FD30S doors 
Final exit sign and directional signage along escape 
to rooms opening onto escape route. No requirement 
route
for fire doors within flats, but sound, well constructed 
and close-fitting conventional doors are required. 

Surface finishes & floor coverings
Travel distance must not be excessive
(see paragraphs 28-29)
It may be possible to accept an existing lower standard 
Management and maintenance of fire safety
of protection in the protected route if there are 
(see paragraph 32)
suitable escape windows from bedrooms and living 
rooms (see paragraph 14) 

Fire separation (see paragraph 19)
30 minutes fire resistance between flats throughout 

46
housing – fire safety


is the ideal, but on risk assessment there may be no 
 
note 10: where the fire risk assessment identifies  
requirement for additional fire-resisting separation 
higher than normal risk, the BS 5839: part 6, LD2 
between units providing walls and floors are of sound, 
interpretation of “rooms or areas that present a high 
traditional construction and additional compensatory 
fire risk to occupants” may include living rooms, 
detection is fitted.
bedrooms and kitchens within the flats, thereby 
providing automatic detection in these rooms in 

Fire detection and alarm system (see paragraph 22)
addition to the common parts and internal entrance 
A mixed system note 10
hall/lobby within flats. Where this is the case, this 
• Grade D: LD2 coverage in the common areas and a
additional detection would be an additional grade D 
heat detector in each flat in the room/lobby opening 
system within the flat (i.e. a mixed system overall) so 
onto the escape route (interlinked); and
as to avoid whole-house false alarms.
• Grade D: LD3 coverage in each flat (non-interlinked
  
smoke alarm in the room/lobby opening onto the 
 
Case study D11: Three- or four-storey building 
escape route) to protect the sleeping occupants of 
converted into self-contained flats (see figure D11)
the flat
Subject to fire separation (above)
Escape routes (see paragraph 9)
Lighting of escape routes (paragraphs 23-24)
30-minute protected route is required, including 
Conventional artificial lighting is required 
30-minute fire-resisting construction and FD30S doors 
Emergency escape lighting required if the route is long 
to rooms opening onto escape route. No requirement 
or complex or where there is no effective borrowed 
for fire doors within flats, but sound, well constructed 
light 
and close-fitting conventional doors are required.
Travel distance must not be excessive

Fire fighting equipment (see paragraph 25)
Fire blanket to be provided in each kitchen 

Fire separation (see paragraph 19)
(recommended good practice)
30 minutes fire resistance between flats throughout 
Simple multi-purpose extinguisher on each floor in the 
is the ideal, but on risk assessment there may be no 
common parts (ground floor hallway only if no first 
requirement for additional fire-resisting separation 
floor common parts) recommended
between units providing walls and floors are of sound, 
traditional construction and additional compensatory 

Fire safety signs (see paragraph 27)
detection is fitted
No requirement
Fire detection and alarm system (see paragraph 22)
Surface finishes & floor coverings
A mixed system note 11
(see paragraphs 28-29)
• Grade A: LD2 coverage in the common areas and a
heat alarm in each flat in the room/lobby opening 
Management and maintenance of fire safety
onto the escape route (interlinked); and
(see paragraph 32)
housing – fire safety
47


• Grade D: LD3 coverage in each flat (non-interlinked
additional detection would be an additional grade D 
smoke alarm in the room/lobby opening onto the 
system within the flat (i.e. a mixed system overall) so 
escape route) to protect the sleeping occupants of 
as to avoid whole-house false alarms.
the flat
 
Subject to fire separation (above)
Case study D12: Five- or six-storey building 
converted into self-contained flats (see figure D12)

Lighting of escape routes (paragraphs 23- 24)
Conventional artificial lighting required 

Escape routes (see paragraph 9)
Emergency escape lighting required if the route is long 
30-minute protected route is required, including 
or complex or where there is no effective borrowed 
30-minute fire resisting construction, FD30S doors to 
light
rooms opening onto escape route, and FD30 doors 
(self-closers not required) to risk rooms within flats. 

Fire fighting equipment (see paragraph 25)
Travel distance must not be excessive
Simple multi-purpose extinguisher on each floor in the 
common parts

Fire separation (see paragraph 19)
Fire blanket to be provided in each kitchen 
30-minute fire separation between units of 
(recommended good practice) 
accommodation throughout
30-minute fire separation is required across the 

Fire safety signs (see paragraph 27)
stairway between second and third floors and 
Final exit sign and signage along escape route if the 
between fourth and fifth floors
escape route is complex
Fire detection and alarm system (see paragraph 22)
Surface finishes & floor coverings
A mixed system note 12:
(see paragraphs 28-29)
• Grade A: LD2 coverage in the common areas and a
heat detector in each flat in the room/lobby opening 
Management and maintenance of fire safety
onto the escape route (interlinked); and
(see paragraph 32)
• Grade D: LD3 coverage in each flat (non-interlinked
smoke alarm in the room/lobby opening onto the 
note 11: where the fire risk assessment identifies 
escape route) to protect the sleeping occupants of 
higher than normal risk, the BS 5839: part 6, LD2 
the flat.
interpretation of “rooms or areas that present a high 
fire risk to occupants” may include living rooms, 

Lighting of escape routes (paragraphs 23-24)
bedrooms and kitchens within the flats, thereby 
Emergency escape lighting required
providing automatic detection in these rooms in 
Conventional artificial lighting required
addition to the common parts and internal entrance 
hall/lobby within flats. Where this is the case, this 

48
housing – fire safety


Fire fighting equipment (see paragraph 25)
38.  Flats in multiple occupation 
Simple multi-purpose extinguisher on each floor in the 
 
Any self-contained flat which is occupied by three or 
common parts
more persons who do not form a single household. 
Fire blanket to be provided in each kitchen 
Fire safety standards will be enforceable under the 
(recommended good practice)
housing health and safety rating system and some 
transitional and additional HMO licensing schemes.
Fire safety signs (see paragraph 27)
Final exit sign
Directional signage along escape route

 
Case study D13: Flat in multiple occupation 
occupying a single storey

Surface finishes & floor coverings
(see paragraphs 28-29)

Escape routes (see paragraph 9)
No requirement for full 30-minute protected route within 

Management and maintenance of fire safety
flat note 13, but the escape route should have sound, 
(see paragraph 32)
traditional construction and should not pass through risk 
rooms. Travel distance must not be excessive

note 12: where the fire risk assessment identifies 
higher than normal risk, the BS 5839: part 6, LD2 

No requirement for fire doors within flat, but sound, 
interpretation of “rooms or areas that present a high 
well constructed and close-fitting conventional doors are 
fire risk to occupants” may include living rooms, 
required. 
bedrooms and kitchens within the flats, thereby 
FD30S door to flat entrance door
providing automatic detection in these rooms in 
(note: in converted or purpose-built flats, 30-minute 
addition to the common parts and internal entrance 
construction and fire doors are likely to be in place)
hall/lobby within flats. Where this is the case, this 
additional detection would be an additional grade D 

Fire detection and alarm system (see paragraph 22)
system within the flat (i.e. a mixed system overall) so 
Grade D, LD3 system:
as to avoid whole-house false alarms.
• interlinked mains wired smoke alarms with integral
 
battery back-up located in the flat internal hallway; 
and

• additional interlinked heat alarm with integral
battery back-up located in the kitchen
housing – fire safety
49

Lighting of escape routes (paragraphs 23-24)
No requirement for emergency lightening, but 

Fire safety signs (see paragraph 27)
conventional artificial lighting is required
No requirement
Fire fighting equipment (see paragraph 25)
Surface finishes & floor coverings
Fire blanket to be provided in the shared kitchen
(see paragraphs 28-29)
Fire safety signs (paragraph 27)
Management and maintenance of fire safety
No requirement 
(see paragraph 32)
Surface finishes & floor coverings
 
note 14: where construction standards are poor, travel 
(see paragraphs 28-29)
distances are long or other higher risk factors are 
present, a 30-minute protected route may be required 

Management and maintenance of fire safety
and/or LD2 fire detection may be appropriate
(see paragraph 32 )
note 13: where construction standards are poor, travel 
distances are long or other higher risk factors are 

39.  Back-to-back houses 
present, a 30-minute protected route may be required 
 
These houses typically back directly onto one another 
and/or LD2 fire detection may be appropriate.  
at the party wall and have other houses either side. This 
 
means that there is only one exit from the house, and 
 
Case study D14: Flat in multiple occupation 
the escape route inevitably passes through a risk room.
occupying two storeys
 
Case study D15: Three-storey back-to-back 
Escape routes (see paragraph 9)
shared house with up to four occupiers (the 
No requirement for full 30-minute protected route 
stairs exit via the living room and the kitchen is 
within flat 
off the living room (see figure 15)
note 14, but the escape route should have 
sound, traditional construction and should not 
pass through risk rooms. Travel distances must not 

Escape routes (see paragraph 9)
be excessive. No requirement for fire doors within 
30-minute protected route at first and second floor 
flat, but sound, well constructed and close-fitting 
level:
conventional doors are required. FD30S door to flat 
• 30-minute fire-resisting construction;
entrance door. (note: in converted or purpose-built 
• FD30 doors (without smoke seals – see paragraph
flats 30-minute construction and fire doors are likely 
21.3), self-closers not required, to risk rooms on first 
to be in place)
and second floors and to kitchen note 15 ;
• escape window from first floor (see paragraph 14);
Fire detection and alarm system (see paragraph 22)
and
Grade D, LD3 system:
• travel distances must not be excessive.
• interlinked mains wired smoke alarms with integral
battery back-up located in the escape route at each 
Fire separation (see paragraph 19)
floor level;
30-minute fire separation between ground and first 
• additional interlinked heat alarm with integral
floors
battery back-up located in the kitchen; and
FD30S fire door across staircase between ground and 
• additional interlinked smoke alarm with integral
first floor 
battery back-up located in any communal lounge.
Fire detection and alarm system (see paragraph 22)
Lighting of escape routes (paragraphs 23-24)
Grade D, LD3 system:
Conventional artificial lighting required
• interlinked mains wired smoke alarms with integral
Emergency escape lighting may be required if there is 
battery back-up located in the escape route at all 
no effective borrowed light
floor levels;
• additional interlinked heat alarm with integral
Fire fighting equipment (see paragraph 25)
battery back-up located in the kitchen; 
Fire blanket to be provided in the shared kitchen
• additional interlinked smoke alarm with integral
50
housing – fire safety


battery back-up located in the lounge; and
Where the requirements for an escape window (see 
• additional interlinked smoke alarms with integral
paragraph 14) cannot be met, alternative precautions 
battery back-up located in any cellar.
may include construction of a 30-minute protected 
route through the house to the final exit, 60 minutes 
Lighting of escape routes (paragraphs 23-24)
fire separation between ground and first floors, and 
Conventional artificial lighting required
conditions relating to arrangements for calling the fire 
Emergency escape lighting may be required if there is 
and rescue service (such as a fire alarm linked to the 
no effective borrowed light
fire brigade or to a monitoring agency). The installation 
of a domestic water suppression system may also be 
Fire fighting equipment (see paragraph 25)
considered in such high-risk cases.
Fire blanket to be provided in the kitchen
  
Fire safety signs (see paragraph 27)
No requirement

Surface finishes and floor coverings
(see paragraphs 28-29)

Management and maintenance of fire safety
(see paragraph 32)

 
note 15: where the house is occupied by a single 
household or as a low-risk shared house by a small 
number of occupiers, it may be possible to relax 
the requirement for full 30-minute fire resisting 
construction throughout the escape route and FD30 
doors at first and second floor level. This is dependent 
on sound, traditional construction and sound, well 
constructed and close-fitting conventional doors. 
Solid timber doors and panelled doors of substantial 
construction may be acceptable but flimsy constructions 
and hollow infill-type doors (commonly known as ‘egg-
box’) would not be. This can be difficult to assess and 
expert advice may be required. The door to the kitchen 
and the door separating ground and first floors should 
be at least FD30S in all cases.

housing – fire safety
51

 
APPENDIX 1:  LEGISLATION AND 
A.5  So, in respect of houses in multiple occupation 
STATUTORY GUIDANCE
(see paragraph 35 regarding shared houses) and in 
maisonettes and sheltered accommodation, the new 
regulatory framework provides for dual enforcement 
A.1  Introduction: This appendix provides a general 
between local housing authorities under the Housing 
overview of fire safety legislation for existing residential 
Act 2004 and fire and rescue authorities under the 
accommodation. It aims to provide a general working 
Regulatory Reform (Fire Safety) Order 2005. 
knowledge for the reader and set the context for 
this fire safety guidance. It does not provide an in-
depth, detailed knowledge of the legislation or cover 
A.6  In view of the dual enforcement regime, there is a 
all details. References to further, detailed reading are 
clear need for consistent and coherent joint working 
provided, and those seeking detailed legal guidance are 
arrangements between local housing authorities 
recommended to refer to those signposted references 
and fire and rescue authorities when applying the 
and seek specialist legal advice.
two sets of legislation. Uncoordinated regulation 
places a burden on housing providers and leads to 
confusion, duplication and unnecessary expense. 
A.2  The repeal of the Fire Precautions Act 1971 and the 
With this in mind, in May 2007 the fire safety housing 
Housing Act 1985 altered dramatically the way that 
working group published a Protocol between local 
fire safety in existing residential accommodation is 
housing authorities and fire and rescue authorities to 
regulated. These old acts have been replaced by new 
improve fire safety. This received Ministerial support 
legislation which, for the purposes of this guidance, is 
from Baroness Andrews and Angela Smith MP and 
the Housing Act 2004 and the Regulatory Reform (Fire 
established a framework for joint working between 
Safety) Order 2005 (FSO). 
the two sets of authorities. The protocol is being 
adopted by authorities around the country and has 
A.3   The Housing Act 2004 introduced the housing health 
improved working arrangements and brought about a 
and safety rating system (HHSRS), along with licensing 
more coordinated approach. The protocol is included 
provisions for certain larger houses in multiple 
in this guidance at Appendix 2.
occupation (HMOs) and management regulations for 
all HMOs. The HHSRS is the principal tool for assessing 
A.7.  The Housing Act 2004: part 1 – the housing 
fire safety risk and regulating standards in all types 
health and safety rating system (HHSRS) 
and tenures of residential accommodation. HMO 
licensing conditions provide specific regulation of fire 
safety standards for HMOs in the private rented sector. 
A.8  Part 1 of the Act introduced the housing health and 
Guidance under this legislation for housing providers 
safety rating system (HHSRS). This is the Government’s 
and local housing authorities is contained in both the 
new approach to evaluation of the potential risks to 
Housing Health and Safety Rating System Operating 
health and safety from any deficiencies identified in 
Guidance and in secondary legislation.
dwellings. Twenty-nine categories of potential hazard 
are considered, one of which (hazard 24) is fire. The 
HHSRS, although not in itself a standard, has been 
A.4  The Regulatory Reform (Fire Safety) Order 2005 places 
introduced as a replacement for the previous housing 
duties on housing providers to risk-assess fire safety 
fitness standards which were contained in sections 
in their properties, to take adequate precautions 
604 and 352 of the Housing Act 1985 (both now 
to reduce that risk and to manage that risk which 
repealed). Detailed guidance on the principles and 
remains. The duties apply throughout a range of 
application of the HHSRS are contained in Housing 
property types, but in HMOs, flats and maisonettes 
Health and Safety Rating System Operating Guidance 
and sheltered accommodation in which personal care 
and Housing Health and Safety Rating System 
is not provided they apply only within the common 
Enforcement Guidance from Communities and Local 
areas (although housing providers need to consider 
Government.
the risk created within the private areas too). These 
duties are enforced by fire and rescue authorities. 
Guidance for housing providers and fire and rescue 
A.9  The underlying principle of the HHSRS is that any 
authorities is contained in HM Government Fire Safety 
residential premises should provide a safe and healthy 
Risk Assessment Sleeping Accommodation Guide, 
environment for any potential occupier or visitor.
although the recommendations contained in this 
 
guide should produce an equivalent level of safety.
 
  To satisfy this principle, a dwelling should be 
52
housing – fire safety

designed, constructed and maintained with non-
can have a high level of confidence in the statistical 
hazardous materials and should be free from both 
averages. This statistical evidence is summarised in the 
unnecessary and avoidable hazards. This holds true 
fire hazard profile (24) section of the HHSRS Operating 
for the hazard of fire. The HHSRS provides a means 
Guidance and is intended to inform professional 
of assessing dwellings which reflects the risk from 
judgment.
any hazard and allows a judgment to be made as to 
whether that risk, in those particular circumstances, 
A.13 The recommendations in Parts C and D of this 
is acceptable or not. For the purposes of the HHSRS 
guidance have regard to the evidence and advice 
the assessment is solely about the risks to health 
contained in fire hazard profile (24) of the HHSRS 
and safety. The feasibility, cost or extent of any 
Operating Guidance.
remedial action is irrelevant to the assessment. 
Some deficiencies may be quickly, easily and cheaply 
remedied, but while such deficiencies are present the 
A.14   Assessing fire hazard under the housing health and 
threat to health or safety can be considerable.
safety rating system
A.10 The principle of the HHSRS is the assessment of risk 
 
The HHSRS Operating Guidance details how to make 
presented by a dwelling, based on:
an assessment of the fire hazard presented by a 
• the likelihood of an occurrence that could cause 
particular dwelling. The guidance offers the following 
harm (in this case uncontrolled fire and associated 
information:
smoke); and 
• the probable severity of the outcomes of such an 
 
Potential for harm from fire: this sets out how the 
occurrence. 
hazard of uncontrolled fire and associated smoke 
can affect health, outlining typical illnesses or injuries 
which may result from exposure to it. The prevalence 
 
The system uses a formula to generate a numerical 
of the hazard, and typical numbers of people affected 
score, which allows comparison of different hazards – 
nationally each year, are identified. The national 
the higher the score, the greater the risk.
statistical averages for the likelihood and spread of 
harms are given in a table, together with the average 
A.11 Under the HHSRS, the fire hazard covers threats from 
hazard scores. The averages are given for eight 
exposure to uncontrolled fire and associated smoke in 
different ages and types of dwellings, and for all 
a dwelling. It includes injuries from clothing catching 
dwellings.
alight on exposure to an uncontrolled fire, but does 
not include injuries caused by clothing catching alight 
 
Causes: this section discusses potential sources of 
from a controlled fire or flame, which may be caused 
hazard from fire based on statistical evidence. It 
by reaching across a gas flame or an open fire used for 
also discusses the contribution to a hazard which 
space heating.
could be attributed to dwelling features and to 
human behaviour. This helps to assess whether any 
A.12 The HHSRS is evidence-based. It is supported by 
deficiencies identified in the dwelling could mean that 
extensive reviews of available literature and by 
the likelihood or spread of harms deviates from the 
detailed analyses of statistical data on the impact of 
average for the particular age and type of dwelling. 
housing conditions on health. The data used to make 
a fire hazard assessment is based on averages relating 
 
Preventive measures and the ideal: this gives an 
to persons aged 60 years or over who died or were 
indication of measures and the optimum standard 
injured in a house or flat fire in England and Wales 
intended to avoid or minimise the hazard – that 
in the years 1997, 1998 and 1999. The statistics are 
is, the optimum current at the time of preparation 
based on the number of such persons dying in fires 
of the operating guidance (January 2004). This is 
as reported by coroners; the number of casualties and 
informed by relevant British Standards (BS 5588, 5839 
persons rescued at all fires attended by the fire and 
and 5446) and UK building regulations approved 
rescue services; and the number of additional persons 
document B. 
injured from uncontrolled fire or flames reported 
by the Home Accident Surveillance System. There 
is a strong evidence base for the production of fire 
 
Relevant matters affecting likelihood and harm 
accident statistics, and due to large sample sizes we 
outcome: to assist enforcement officers, a check-list of 
housing – fire safety
53

dwelling features which may affect the likelihood and 
A.19 Using the two judgments, the HHSRS formula detailed 
the severity of the outcome is provided. 
in the operating guidance is used to generate a 
numerical hazard score for the fire hazard at the 
A.15 For multi-occupied buildings the assessment is made 
subject premises. The numerical hazard score is a 
for each individual dwelling, including its associated 
representation of the inspector’s judgment rather than 
shared rooms/areas and its access and escape route, 
a precise statement of the risk. The scores potentially 
not the building as a whole. This means that different 
range from 0.2 to one million. In order to make this 
hazard ratings can be expected for dwellings within 
wide range manageable and to avoid too strong a 
the same building, depending, amongst other 
focus on precise numerical scores, hazard bands have 
things, on the location of the dwelling unit within 
been devised which group ranges of scores, which 
the building and any deficiencies to the individual 
can then be used for comparison. There are 10 hazard 
dwelling. For example, a bedsit on the ground floor 
bands (A to J) with band J being the safest and band 
close to the final exit from the building would not be 
A the most dangerous.
assessed the same as a bedsit on the third floor where 
the means of escape is the internal staircase (even if 
A.20 The band into which a dwelling falls in respect of the 
both bedsitting rooms are identical apart from their 
fire hazard can then be used:
location). If a fire occurred, the harm caused to a 
• to inform a landlord’s decision as to whether action 
victim in the third storey bedsit would be more severe 
should be taken to reduce the hazard and to 
than the person in the ground floor bedsit because 
prioritise actions across a property portfolio; and  
there would be a greater distance of travel to safety. 
• to inform the enforcing authority’s decision as to 
what, if any, enforcement action should be taken in 
A.16 The HHSRS uses judgments made by the inspector, 
respect of the property.
based on an inspection of the dwelling, to generate a 
numerical score.
A.21 Worked examples of HHSRS assessments of fire hazard 
can be found on the LACORS website at www.lacors.
A.17 The procedure requires two judgments from the 
gov.uk
inspector. These are an assessment of:
• the likelihood, over the next 12 months, of an 
A.22 Action following hazard assessment
occurrence that could result in harm to a person 
 
The enforcing authority for the Housing Act 2004 is 
aged 60 years or over (the vulnerable group); and 
the local housing authority (LHA) (the local council). 
• the range of potential outcomes from such an 
The Act gives LHAs powers to intervene where they 
occurrence.
consider housing conditions to be unacceptable on 
the basis of the impact of hazards on the health or 
 
Note: ‘vulnerable group’ is defined in the HHSRS 
safety of the most vulnerable potential occupant. 
operating guidance as “a range of people for whom 
Having carried out an assessment for the hazard of 
the risk arising from a hazard is greater than for any 
fire under HHSRS and where a significant hazard 
other group in the population”. It is restricted to 
exists, the LHA must decide what (if any) action is 
age groups, no other vulnerability is considered. The 
appropriate. 
assessment of likelihood of an occurrence resulting in 
harm is based on a member of this group living in the 
A.23 Where a category one hazard is identified (i.e. a band 
property. For the hazard of fire the vulnerable group 
A, B or C hazard – one that scores 1,000 or more 
is persons over the age of 60. The vulnerable group 
under the HHSRS assessment outlined above), the 
is only used to assess the hazard; when it comes to 
LHA must take action to reduce the risk – it is under a 
enforcement decisions the actual person living there is 
statutory duty to do so under section 5 of the Act. 
considered.
A.24 Where a category two hazard exists (i.e. a band D-J 
A.18 The judgment of the likelihood made by the inspector 
hazard – one which scores less than 1,000 under the 
involves taking account of the conditions (deficiencies) 
HHSRS assessment outlined above) then the LHA has 
identified during the inspection, in particular whether 
a power to act but is not under a duty to do so (under 
those conditions will increase or reduce the average 
section 7 of the Act). 
likelihood of an occurrence. 
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housing – fire safety

A.25 In many cases, notification of the existence of a 
 
If the LHA considers that the action it has taken under 
hazard to the landlord by the LHA will be all that is 
the above provisions has not proved satisfactory, it 
required, as the landlord will take the appropriate 
may subsequently take the same action again or take 
action to reduce the hazard to an acceptable level. 
an alternative action.
Guidance on how to do so can be found in Parts C 
and D of this guide. However, where self-regulation 
A.28 Statement of reasons
does not happen the LHA must consider what action 
is appropriate.
 
Whichever type of action the LHA considers 
appropriate, it must prepare a statement of reasons 
explaining why it decided on that particular type of 
A.26 For both categories of hazard the enforcement 
action rather than any other type.
options available are as follows (the first two can be 
suspended if appropriate):
A.29 Right of appeal
 
Except for hazard awareness notices, the recipient of 
 
Serve an improvement notice (section 11 or 12)  
any of the above enforcement actions has a right of 
this requires the responsible person (usually the 
appeal to the residential property tribunal (RPT). The 
landlord or HMO licence holder) to carry out works 
LHA must include details of the right of appeal, how 
which will at least remove the category one hazard. 
to appeal and the timescale for doing so with the 
notice when it is served. Further details on appeals can 
 
Make a prohibition order (section 20 or 21)
be found on the RPT website at www.rpts.gov.uk
 
this prohibits the use of part or all of the premises for 
various specified purposes.
A.30 Consultation with fire and rescue authorities
 
Before talking any of the actions outlined above in 
 
Serve a hazard awareness notice (section 28 or 29)
respect of a fire hazard in an HMO or in the common 
 
this is purely advisory action where the LHA notifies 
parts of flats, the LHA must consult with the FRA. For 
the person responsible of the need for improvements.
emergency remedial action or emergency prohibition 
this requirement applies only so far as it is practical 
to do so before taking those measures (section 10, 
 
Note: demolition orders and clearance areas are not 
Housing Act 2004). 
discussed here.
A.31. The Housing Act 2004: part 2 – licensing of 
A.27 In addition to the above, the following discretionary 
houses in multiple occupation  
enforcement options are also available for category 
one hazards only where they present an imminent risk 
of serious harm to occupiers:
A.32 Introduction: the definition of house in multiple 
occupation (HMO) is contained in section 254 of the 
Housing Act 2004. The definition is complex, and for 
 
Emergency remedial action (section 40) 
detailed understanding then the Act itself should be 
 
LHAs can themselves take remedial action to remove a 
studied. For general purposes the definition can be 
hazard and recover reasonable expenses.
summarised as follows.
 
Emergency prohibition order (section 43)
A.33 A building or part of a building is an HMO if it meets 
 
LHAs can prohibit the use of all or part of a property.
every condition specified in one or more of four tests, 
or is subject to an HMO declaration: 
 
In both cases the owner of the property will be able 
 
to appeal, but any appeal will not prevent the action 
 
The standard test 
from being taken or the prohibition being put into 
a) it consists of one or more units of living 
effect. These provisions may only be used where 
accommodation which are not self-contained flats; 
there is a category one hazard, the hazard involves an 
b) the living accommodation is occupied by persons 
imminent risk of harm to any of the occupiers of these 
who do not form a single household; 
or other residential premises, and no management 
order is in force under part four of the Act. 
c)  the living accommodation is occupied by persons as 
their only or main residence; 
housing – fire safety
55

d)  their occupation of the living accommodation  
household does not constitute the only use of the 
constitutes the only use of that accommodation; 
accommodation but does constitute a significant 
e)  rents are payable or other consideration is 
use of that accommodation, the local authority may 
provided in respect of at least one of those person’s 
serve an HMO declaration notice. The LHA must 
occupation; and  
serve the notice on the landlord or manager of the 
property within seven days of the decision to make 
f) two or more of the households who occupy the 
the declaration. This action nullifies the requirement in 
living accommodation share one or more basic 
the section 254 HMO definition that the occupation 
amenity or the living accommodation is lacking in 
constitutes the only use of the accommodation. The 
one or more basic amenity. 
recipient of an HMO declaration notice has a right 
of appeal to the residential property tribunal (RPT). 
 
The self-contained flat test 
Details on appeals are available at www.rpts.gov.uk
  
A self-contained flat which meets all of (b) to (f) 
above. 
A.34   In summary
 
 
A building is an HMO if it:
 
The converted building test 
• is occupied by more than one household and 
 
A converted building consisting of one or more units 
where more than one household shares (or lacks) 
which are not self-contained flats and:
an amenity such as a bathroom, toilet or cooking 
 
facilities;
a) the living accommodation (the building) is occupied 
• is occupied by more than one household and is a 
by persons who do not form a single household; 
converted building, but not entirely self-contained 
b) the living accommodation is occupied by persons as 
flats (whether or not some amenities are shared or 
their only or main residence;
lacking);
c) their occupation of the living accommodation 
• is converted self-contained flats but does not meet 
constitutes the only use of that accommodation; 
as a minimum standard the requirements of the 
and 
1991 Building Regulations, and more than one third 
of the flats are privately rented; or
d) rents are payable or other consideration is 
provided in respect of at least one of those person’s 
• an HMO declaration has been made by the LHA 
occupation. 
under section 255 of the Housing Act 2004.
 
Converted blocks 
A.35 The term ‘household’ means either a single person 
or members of the same family who are living 
 
A converted block of self-contained flats converted 
together. This includes people who are married or 
to construction standards that did not comply with 
living together as married (including those in same-
the requirements of the Building Regulations 1991 (SI 
sex relationships). ‘Family’ means specific relatives: 
1991/2768) and:
parents, grandparents, children and step-children, 
grandchildren, brothers, sisters, uncles, aunts, 
a)  less than two thirds of the flats are owner-occupied; 
nephews, nieces or cousins. Foster children are also 
b)  the living accommodation is occupied by persons 
treated as part of their foster parents’ household.
who do not form a single household; 
c) the living accommodation is occupied by persons as 
A.36 The term ‘occupied’ includes occupation by asylum 
their only or main residence;
seekers and migrant and seasonal workers, as a refuge 
d) their occupation of the living accommodation 
by persons escaping domestic violence, or by students 
constitutes the only use of that accommodation; and 
in higher or further education.
e) rents are payable or other consideration is 
provided in respect of at least one of those person’s 
A.37 Schedule 14 of the Act exempts the following 
occupation. 
categories from the HMO definition:
 
HMO declarations 
• buildings controlled or managed by public sector 
 
Where the occupation of a building or part of 
bodies:  
a building by persons who do not form a single 
• local housing authorities
56
housing – fire safety

• registered social landlords
district under part 3 of the Act. The parts of the 
• police authorities
local authority district covered will be determined 
by the particular scheme, and it will be necessary 
• fire and rescue authorities
to contact the relevant local authority to ascertain 
• health service bodies;
these details. 
• buildings occupied principally by students in full-
time education and which are managed by the 
 
Note: certain converted blocks of flats fall within the 
relevant educational establishment in conformity 
HMO definition. These are described in section 257 
with any code approved under section 233 of the 
and are essentially those converted to a standard 
Act;
that does not comply with the building standards 
• buildings occupied by religious communities which 
of the Building Regulations 1991 (and still do not 
are occupied principally for the purposes of a 
comply) and of which less than two-thirds of the flats 
religious community whose principal occupation 
are owner-occupied. These flats fall within the HMO 
is prayer, contemplation, education or the relief of 
definition but are not subject to mandatory licensing. 
suffering (this category excludes converted block of 
However, they may fall within an additional licensing 
flats to which section 257 applies); 
scheme if the local authority has one. If in doubt, the 
• owner-occupied buildings; 
local authority should be contacted for advice.
• buildings occupied by only two persons; and 
• buildings regulated by other legislation as specified 
A.39   Suitability for licensing in respect of fire safety
in schedule 1 to The Licensing and Management of 
 
The LHA cannot approve an application for an HMO 
Houses in Multiple Occupation and Other Houses 
licence until it is satisfied that the HMO is reasonably 
(Miscellaneous Provisions) (England) Regulations 
suitable for occupation or can be made so by the 
2006 (SI 2006/373). 
imposition of licensing conditions (section 64). It 
cannot be satisfied of this unless the HMO meets 
A.38 Licensable HMOs
(or can meet) prescribed standards under section 
 
If the above definition determines that a property 
65. The prescribed standards are contained in 
is a HMO it is then necessary to consider whether it 
Statutory Instrument 2006 no. 373: The Licensing and 
requires licensing. There are three ways in which part 
Management of Houses in Multiple Occupation and 
2 or 3 licensing may apply to an HMO:  
Other Houses (Miscellaneous Provisions) (England) 
Regulations 2006. The standards require that 
  1) 
HMOs that fall within a mandatory licensing 
“appropriate fire precaution facilities and equipment 
scheme. These are schemes which LHAs must 
must be provided of such type, number and location 
operate under the duty contained in section 55 of 
as is considered necessary”. No further guidance is 
the Act. The categories of HMO which fall within 
given. If an HMO meets the relevant standards in this 
mandatory licensing are prescribed in The Licensing 
guidance, the LHA should be satisfied that appropriate 
of Houses in Multiple Occupation (Prescribed 
fire precaution facilities and equipment are provided 
Descriptions) (England) Order 2006. These are 
and the HMO is reasonably suitable for occupation in 
all HMOs comprising three storeys or more and 
terms of fire safety, and that there is no impediment 
occupied by five or more persons living in two or 
to granting the licence in fire safety terms. 
more separate households, unless the HMO has 
been temporarily exempted by the LHA or is being 
managed by it under a management order. 
A.40 Licence conditions relating to fire safety
  2) 
HMOs in areas that are designated by the 
 
Mandatory licence conditions
LHA as subject to additional licensing schemes 
 
When granting a licence the LHA must attach 
(under section 56 of the Act). In these cases the 
certain mandatory conditions. These are laid down in 
categories of HMO covered and the parts of the LHA 
schedule four to the Act as follows:
district covered will be determined by the particular 
scheme. It will be necessary to contact the relevant 
LHA to ascertain whether there is an additional 
 
“A licence under part 2 or 3 must include the 
licensing scheme in place.
following conditions … conditions requiring the 
licence holder –
(a) to ensure that smoke alarms are installed in the    
  3) 
Finally, some local authorities may operate 
house and to keep them in proper working order;
‘selective licensing’ schemes within parts of their 
housing – fire safety
57

(b) to supply the authority on demand, with a 
(b) this does not, however, prevent the authority 
declaration by him as to the condition and 
from imposing licence conditions relating to the 
positioning of such alarms.”
installation or maintenance of facilities or equipment 
within subsection (2)(c) (section 65 prescribed 
standards for appropriate fire precaution facilities 
 
This is the only fire safety related mandatory condition. 
and equipment), even if the same result could be 
It must be applied to all licences alongside any 
achieved by the exercise of part 1 functions.”  
relevant discretionary conditions, as explained in the 
next section.
A.42 In practice, as a rule, where a LHA encounters a 
significant fire hazard (category one or two) in a 
 
Discretionary licence conditions
licensable HMO it should seek to remove or reduce 
 
Section 67 of the Act gives LHAs the discretion to 
it using part 1 of the act (HHSRS). However, when 
attach such other conditions to an HMO licence as 
granting a licence for an HMO it must satisfy itself 
it considers appropriate in relation to a number of 
that there are appropriate fire precaution facilities 
specified matters. These include:
and equipment in the house. Where that is not the 
 
“conditions requiring facilities and equipment to 
case, it may attach a condition to the licence requiring 
be made available in the house for the purpose of 
that works to ensure the facilities and equipment 
meeting standards prescribed under section 65” (see 
are installed within a specified time period. This 
paragraph A.39); and   
practice will benefit landlords as well as the authority, 
 
“conditions requiring, in the case of any works 
because relying solely on the mandatory licence 
needed in order for any such facilities or equipment 
condition described in paragraph A.41 above may 
to be made available or to meet any such standards, 
not provide adequate fire safety to meet the section 
that the works are carried out within such period or 
65 requirement. Such an approach may also leave 
periods as may be specified in, or determined under, 
a category one hazard in place, which will require 
the licence.”
further remedial works in the near future when the 
 
So LHAs may grant a licence with a condition attached 
LHA discharges its duty to remove it under the Act. 
that certain fire safety works are carried out within 
Achieving a comprehensive and reasonable standard 
a specified period of time to satisfy them that the 
of fire safety via the licensing condition will avoid 
HMO is reasonably suitable for occupation in terms 
works being carried out which will subsequently have 
of fire safety under section 64 (“ensuring appropriate 
to be upgraded or reversed.
fire precaution facilities and equipment are provided 
of such type, number and location as is considered 
A.43 A note of caution must be exercised in relation to 
necessary”).
licence conditions requiring works within the common 
parts of premises. Article 43 of the Regulatory 
A.41 Two other considerations are important in terms of 
Reform (Fire Safety) Order 2005 has the effect that 
HMO fire safety licence conditions.
any licence condition applied in the common parts 
of premises to which the order applies shall have no 
 
Where a category one or two hazard is identified in a 
effect. Therefore, any licence condition may have no 
licensable HMO, the Act is clear that the appropriate 
effect where a properly conducted risk assessment 
enforcement route to remove it is via part 1 (HHSRS). 
has indicated that a higher level of provision is 
However, this rule does not preclude LHAs from 
necessary. In view of this, the terms of the Protocol 
attaching fire safety conditions (as described above) to 
between local housing authorities and fire and rescue 
the licence, even if this brings about the same result. 
authorities to improve fire safety should be followed in 
This is dealt with in section 67:
all cases when establishing licence conditions requiring 
 
“67 (4) As regards the relationship between the 
works within the common parts of premises to which 
authority’s power to impose conditions under this 
the order applies. 
section and functions exercisable by them under or for 
the purposes of part 1 (‘part 1 functions’) — 
A.44 For properties falling within the HMO definition but 
  (a) the authority must proceed on the basis that, 
outside the scope of licensing, enforcement of fire 
in general, they should seek to identify, remove or 
safety standards will fall under part 1 of the Housing 
reduce category one or category two hazards in the 
Act 2004 and the Regulatory Reform (Fire Safety) 
house by the exercise of part 1 functions and not by 
Order 2005, and again the terms of the protocol 
means of licence conditions; 
should be followed.
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housing – fire safety

A.45  HMO management regulations 
A.49 Regulation 6 places specific duties on managers of 
HMOs in respect of gas and electrical safety. These 
closely affect fire safety. The manager must:
A.46   The Management of Houses in Multiple Occupation 
(England) Regulations 2006 apply to all HMOs, 
• supply to the LHA, within seven days of receiving 
whether licensable or not. Identical regulations apply 
a request in writing from them, the latest gas 
in Wales. The exception is converted blocks of flats, 
appliance test certificate in relation to the testing 
to which section 257 of the Housing Act 2004 applies 
of any gas appliances in the HMO by a recognised 
(i.e. houses or buildings converted into self-contained 
engineer;
flats where the conversion did not (and still does not) 
• ensure that every fixed electrical installation is 
comply with the building standards under the Building 
inspected and tested at intervals not exceeding 
Regulations 1991 and less than two-thirds of the flats 
five years by a person qualified to undertake such 
are owner-occupied). The purpose of the management 
inspection and testing;
regulations is not to require additional fire safety 
• obtain a certificate from the person conducting that 
precautions but to ensure that existing precautions are 
test, specifying the results of the test; and
properly maintained.
• within seven days of receiving a request in writing 
for it from that authority.
A.47 Regulation 4 places specific duties on managers of 
HMOs in respect of fire safety. The manager must 
A.50 There is no provision for service of notice requiring 
ensure that:
works to remedy management failings under 
• all means of escape from fire in the HMO are kept 
these regulations, but failure to comply with the 
free from obstruction and maintained in good order 
regulations is a criminal offence under section 234(3) 
and repair;
of the Housing Act 2004. Offences carry a level 5 
• any fire fighting equipment and fire alarms are 
fine on conviction (maximum £5,000 per offence). 
maintained in good working order; and 
Both landlords and tenants may be prosecuted for 
• all notices indicating the location of means of 
contravening the regulations.
escape from fire are displayed in positions within 
the HMO that enable them to be clearly visible to 
A.51.  The Regulatory Reform (Fire Safety) Order 2005 
the occupiers (unless the HMO has four or fewer 
occupiers).
A.52 Article 6 of the FSO specifically states that it does not 
apply to domestic premises except where the sharing 
A.48   Regulation 10 places specific duties on occupiers of 
of living accommodation e.g. a kitchen, means that 
HMOs in respect of fire safety. Every occupier of the 
the residential unit cannot properly be described as a 
HMO must:
dwelling. The exception is the prohibition order power, 
• conduct themselves in a way that will not hinder or 
which is available for domestic premises except for 
frustrate the manager in the performance of their 
those occupied as a single private dwelling. Domestic 
duties;
premises are defined in the order as premises occupied 
• allow the manager, for any purpose connected 
as a private dwelling. 
with the carrying out of any duty imposed on them 
by these regulations and at all reasonable times, 
 
So the FSO does apply to:
to enter any living accommodation or other place 
• the common parts of HMOs (but not ‘shared 
occupied by that person;
houses’) (see paragraph 35);
• provide the manager, at their request, with any such 
• the common parts of buildings containing flats and 
information as they may reasonably require for the 
maisonettes; and  
purpose of carrying out their duties;
• the common parts of sheltered accommodation.
• take reasonable care to avoid causing damage to 
anything that the manager is under a duty to supply, 
maintain or repair under these regulations; and
 
However, it does not apply to the individual flats, 
• comply with the reasonable instructions of the 
maisonettes, bedsits or residential units themselves. 
manager in respect of any means of escape from 
The FSO is enforced by the local fire and rescue 
fire, the prevention of fire and the use of fire 
authority (FRA) but it must consult the LHA before 
equipment.
taking enforcement action.
housing – fire safety
59

A.53 The FSO places a duty on the responsible person to 
give all tenants and other relevant persons information 
take such general fire precautions as will ensure, as far 
on risks identified in the risk assessment and 
as is reasonably practicable, the safety of all relevant 
information on fire safety measures and procedures 
persons. Relevant persons include anyone lawfully on 
for the premises. All fire safety measures at the 
the premises and those in the vicinity of the premises 
premises must then be subject to a proper system of 
who would be affected by any fire at the premises. 
maintenance by a competent person so as to be kept 
All persons within an HMO are likely to be considered 
in efficient working order and in good repair. The risk 
relevant persons. The responsible person is the person 
assessment must be regularly reviewed to ensure that 
having control of the premises, so will usually be 
it is kept up to date. 
the landlord or manager of the premises. Any other 
person who has a degree of control over the premises 
A.56 “In practice, it is very unlikely that a properly 
will share the responsible person’s duties to the extent 
conducted fire risk assessment, which takes into 
of that control. This includes a contractor maintaining 
account all the matters relevant for the safety of 
or repairing the premises, in relation to the works he 
persons in case of fire, will conclude that no fire 
or she is obliged to carry out.
precautions (including maintenance) are necessary” 
source: Regulatory Reform (Fire Safety) Order, 
A.54 General fire precautions include, where necessary:
guidance note no. 1: enforcement (Communities and 
• measures to reduce the risk of fire occurring;
Local Government). 
• measures to reduce the spread of any fire through 
the premises;
A.57 The relevant enforcement agencies are defined in 
• measures in relation to the means of escape;
article 25 of the FSO, but in the types of premises 
• measures to ensure the means of escape can be 
covered by this guide this will usually be the fire 
safely used at all times;
and rescue authority (FRA). Inspectors enforce the 
provisions of the FSO and have certain powers 
• fire fighting measures;
to require information and to enter premises. 
• means of fire detection and warning;
Enforcement actions which may be taken under the 
• action to be taken in the event of fire; and 
order are as follows:
• mitigating the effects of fire. 
 
Serve an alterations notice (article 29)
A.55 In order to comply with the duties imposed by the 
 
this is used where the FRA consider premises to be 
FSO, the responsible person must carry out a fire risk 
high risk or to have the potential of becoming high 
assessment to identify what fire hazards exist at the 
risk should alterations be made or change of use 
premises and what measures have been taken (or will 
occur. It requires the responsible person to notify the 
be taken) to minimise the risk. The risk assessment 
LHA before making any such changes. 
must pay particular attention to those at special risk, 
such as disabled persons, elderly persons, children, 
 
Serve an enforcement notice (article 30)
or those with special needs. Any other specific 
risks should be noted, for example the presence of 
 
where the FRA is of the opinion that the responsible 
dangerous substances at the premises. These details 
person has failed to comply with any provision of the 
should be recorded and are known as ‘significant 
FSO or is dissatisfied with the risk assessment or action 
findings’. They must be recorded if the premises are 
taken under it, it may serve an enforcement notice on 
a licensed HMO or if there are five or more people 
that person, specifying the steps required to remedy 
employed by the business as a whole (not necessarily 
the failure. 
at the premises being assessed). A fire risk assessment 
must be carried out irrespective of the requirement 
 
Serve a prohibition notice (article 31)
to record the significant findings. The responsible 
 
where the FRA is of the opinion that the use of a 
person must ensure that a competent person(s) 
premises involves or will involve a risk to relevant 
carries out any necessary fire prevention or protection 
persons so serious that use of the premises ought to be 
works identified by the risk assessment (someone 
prohibited or restricted, it may serve a prohibition notice. 
with enough training and experience, knowledge and 
other qualities to be able to implement the measures 
properly). This could, in many cases, be the responsible 
 
Note: the article 31 prohibition notice power is 
person themselves. The responsible person must also 
unique in that it can be applied to any or all parts 
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housing – fire safety

of the premises covered by this guide, including the 
label does not mean that the furniture does not comply, 
individual units of accommodation, whereas all other 
as the label may have been removed after the furniture 
powers under the FSO apply only to the common 
was supplied; some furniture manufactured before 
parts.
1988 may comply with the requirements anyway.
A.58 Failure to comply with any duty imposed by the FSO or 
A.65 Landlords and managing agents must ensure that 
the requirements of an alterations notice, enforcement 
the furniture supplied meets the fire resistance 
notice or prohibition notice is a criminal offence under 
requirements, and the only practical way of doing 
article 32 of the FSO and carries a level 3-5 fine on 
so is to ensure that the furniture is labelled by the 
conviction (£1,000 and £5,000 maximum respectively). 
manufacturer in this way. If this cannot be ascertained, 
There is a right of appeal to a magistrates’ court 
the furniture should be replaced.
against any notice. 
A.66 The regulations are enforced by local authority trading 
A.59 Parts C and D of this guide give guidance on how to 
standards departments, which can give further 
comply with the general fire safety duties required 
advice to landlords/managing agents regarding these 
under the FSO as well as meeting other regulatory 
requirements.
requirements. 
A.67 The Gas Safety (Installation and Use) Regulations 
A.60 More detailed guidance on compliance with the 
1998 
Regulatory Reform (Fire Safety) Order 2005 can be 
found in HM Government Fire Safety Risk Assessment 
A.68 The Gas Safety (Installation and Use) Regulations 1998 
Sleeping Accommodation Guide. Download it 
deal with the installation, maintenance and use of gas 
from www.communities.gov.uk/publications/fire/
appliances, fittings and flues in domestic and certain 
firesafetyrisk4 
commercial premises. They place duties on certain 
landlords to ensure that gas appliances, fittings and 
A.61 The Furniture and Furnishings (Fire) (Safety) 
flues provided for tenants’ use are safe. Essentially any 
Regulations 1988 
lease under seven years is covered.
A.62 The Furniture and Furnishings (Fire) (Safety) 
A.69 Landlords must ensure that gas fittings and flues are 
Regulations 1988 (as amended) set levels of fire 
maintained in a safe condition. Gas appliances should 
resistance for domestic upholstered furniture, 
be serviced in accordance with the manufacturer’s 
furnishings and other products containing upholstery. 
instructions. If these are not available, then it is 
The regulations cover most items of furniture found 
recommended that they are serviced annually. 
in rented accommodation including beds, mattresses, 
pillows and cushions. They do not apply to carpets, 
A.70   Only a competent and registered engineer may carry 
curtains or duvets. The regulations apply to all persons 
out servicing or gas safety checks. This term means 
who supply furniture and furnishings in connection 
an engineer recognised by the Council of Registered 
with accommodation in the course of a business. In 
Gas Installers as being competent to undertake such 
general, this includes landlords, letting agents and 
testing. This means British Gas engineers or (until 1 
managing agents. 
April 2009) engineers registered with CORGI. After 
that date, CORGI registrations will be replaced by 
A.63 All furniture within lettings commencing after 1 January 
CAPITA registrations.
1997 must meet the fire resistance requirements of 
the regulations. However, the regulations do not apply 
A.71 Landlords must ensure that a gas safety check is 
to furniture made before 1950 or to re-upholstered 
carried out annually on each gas appliance/flue. 
furniture made before that date. 
Before any new tenancy starts they must make sure 
that such a check has been carried out within one year 
A.64 Since 1988 all new furniture (except mattresses and 
before the start of the tenancy (unless the appliances 
bed bases) have had to carry a permanent label stating 
in the property have been installed for less than one 
that it complies with the fire resistance standards 
year, in which case they should be checked within one 
specified in the regulations. However, absence of such a 
year of their installation date). A record of each gas 
housing – fire safety
61

safety check must be kept for at least two years and a 
copy must be given to existing tenants within 28 days 
of the check being completed, or to any new tenant 
before they move in (in certain cases there is an option 
to display the record in the property instead). 
A.72 These requirements do not apply to any appliances 
owned by the tenant. The regulations are enforced by 
the Health and Safety Executive. Further advice can 
be obtained free from their gas safety advice line on 
0800 300 363 or at www.hse.gov.uk
A.73 Electrical Equipment (Safety) Regulations 1994 
A.74 The regulations require that all electrical equipment 
supplied by landlords is safe. In measuring safety, 
the landlord or managing/letting agent needs to 
ensure that the equipment complies with current 
UK requirements for safety of domestic electrical 
products. There is no mandatory requirement for 
the equipment to undergo any safety testing, but 
regulations require that any equipment supplied after 
9 January 1995 shall be marked with the appropriate 
CE symbol. Where the safe use of the equipment 
relies upon the user being aware of any particular 
characteristic, suitable information or instruction 
booklets should be provided.
A.75 The regulations are enforced by local authority trading 
standards departments, which can provide further 
advice to landlords/managing agents regarding these 
requirements.
 
62
housing – fire safety

Appendix 2: 
Protocol between local housing authorities and fire and 
rescue authorities to improve fire safety

Foreword by Communities and Local Government Ministers
It is always a priority to ensure safety from the risk of fire in the home, especially in mixed use premises, or where the 
occupiers share vital parts of the building with persons who are not members of the same family.
I welcome this protocol which clearly sets out the interrelationship between the two most important pieces of legislation 
relating to fire safety in homes, the Housing Act 2004 and the Regulatory Reform (Fire Safety) Order 2005. The collaborative 
working arrangements it promotes between Local Housing Authorities and Fire and Rescue Authorities will ensure proper 
partnerships at the local level. This will be of great benefit to the community, in ensuring that risk of fire in homes is reduced 
and helps protect against injury or loss.
When it comes to fire safety both the Local Housing Authority and the Fire and Rescue Authority have a range of 
responsibilities and it is important these are exercised with a common purpose and in a consistent way. There are a range 
of activities that statutory authorities can take to achieve this goal, from promoting awareness and good practice to 
enforcement action.
 
I would encourage you to adopt the principles set out in this protocol and ensure clear local arrangements are agreed and 
operational.  
Baroness Andrews OBE, Under Secretary of State with responsibility for Housing
Angela Smith MP, Under Secretary of State with responsibility for Fire Safety
Introduction
by Local Housing Authorities under the Housing Act 2004 
This protocol establishes the principles and describes 
will, in other than exceptional cases, achieve a similar level 
the joint working arrangements between Local Housing 
of fire safety for relevant persons as required under the Fire 
Authorities and Fire and Rescue Authorities to deliver the 
Safety Order.
objective of improved fire safety. It is a framework which 
provides the basis for detailed local arrangements whilst 
Conversely, Local Housing Authorities are responsible 
encouraging collaboration at a regional level.
for implementing the various licensing requirements of 
the Housing Act 2004 and utilising the Housing Health 
The introduction of the Housing Act 2004 and the 
and Safety Rating System to identify and if necessary act 
Regulatory Reform (Fire Safety) Order 2005 (Fire Safety 
upon, significant hazards found within all housing. They 
Order) has imposed an analogous duty on two statutory 
acknowledge that Fire and Rescue Authorities will monitor 
authorities to enforce certain fire safety provisions within 
and enforce fire safety standards, in areas where they have 
such housing.1
legislative control, to a similar standard, in premises identified 
in Section 3 of this protocol. Fire and Rescue Authorities 
To promote the efficient use of resources, this protocol 
undertake to inform Local Housing Authorities of any serious 
will identify discrete areas of inspection and enforcement, 
non-fire matters that they encounter and identify.
appropriate review and monitoring arrangements and 
provide for urgent or complex requests for assistance 
Both authorities utilise a risk based enforcement approach 
from either party.  It seeks to provide all parties, as far as is 
and it is recognised that some housing providers, such 
reasonable practicable, with a measure of confidence that 
as owners, landlords or managing agents, may not have 
they are discharging their respective duties under legislation.
sufficient competencies to undertake such risk assessments. 
In general, Local Housing Authorities undertake a risk 
Fire and Rescue Authorities have a legal duty to enforce 
assessment utilising the Housing Health and Safety 
the Fire Safety Order in the common areas of all residential 
Rating System whilst Fire and Rescue Authorities expect 
accommodation not forming a single private dwelling.2 
the responsible person, usually the housing provider, to 
They acknowledge that the fire safety standards required 
undertake a risk assessment. 
1 A summary of the respective legislation is available as Appendix A
2 The Fire Safety Order applies to all parts of an HMO when prohibition action under Article 31 is taken
housing – fire safety
63

These collaborative working arrangements, which support 
3 All self contained flats, whether purpose built or
the Government’s broader agenda for partnership 
  converted 
 
 
LHA
working, will enable both Authorities to promote fire and 
certain other safety provisions within a broader range of 
premises than would have been possible if they had acted 
4 Premises with mixed commercial and associated 
independently or undertaken joint inspections.
residential accommodation and sheltered housing
 
FRA
Nothing in this agreement shall be considered as creating 
a contractual relationship, a contract of employment or a 
5 Hostels3/B&B/Hotels   
FRA
relationship of principal and agent between the parties and 
shall not add to in any way the existing statutory duties 
of the parties. No party to this agreement shall hold itself 
6 All multiple-occupied accommodation that is
out as being authorised to enter any contract on behalf 
  owned or managed by the LHA 
FRA
of any other party or in any way bind any other party to 
the performance, variation, release or discharge of any 
 
This table provides a general guide – it cannot cover 
obligation otherwise than in circumstances expressly or 
every possible situation and certain premises will fall 
implicitly permitted by this agreement.
under more than one category. Negotiations to take 
account of local residential stock may be necessary.
The signatories to this protocol are shown in Appendix B. 
 
Enforcing authorities may wish to consider the 
1.  The underlying principles of this protocol are as 
opportunities afforded by The Local Government Act 
follows:
1972 Section 101 in appropriate cases.
• To ensure appropriate standards of fire and other 
safety provisions are provided and maintained in 
 
Nevertheless, Fire and Rescue Authorities are under an 
residential premises
obligation to reduce fire deaths in line with their risk based 
• To develop data sharing arrangements, through 
enforcement polices and will undertake planned proactive 
established paths and in accordance with Section 8 
inspections in any identified type of premises or in a 
of this protocol
particular locality as they deem necessary. Prior to starting 
• To assist landlords and other providers to understand 
any such series of inspection programmes, consultation 
the legal framework which they operate under
should take place to ensure that duplication of inspection 
• To encourage opportunities for offering joint 
and enforcement does not occur. Any such programmes 
training and awareness sessions 
may, subject to local agreement take place individually, 
• To recognise the needs and limitations of Fire and 
collaboratively or jointly and should complement the 
Rescue Authorities and Local Housing Authorities 
inspection programme of the Local Housing Authority.
and to acknowledge that both authorities will 
 
always seek to act in good faith
 
Where necessary emergency action will be taken by 
either authority to reduce any immediate risk but further 
2.  Which authority should take the lead enforcing 
remedial enforcement will only be undertaken following 
role for fire safety?
consultation with the designated lead authority. Nothing 
in this protocol will prevent either authority undertaking 
 
The table below lists the Authority that will normally 
specific individual monitoring or enforcement action if 
take the lead in inspection and enforcement action in 
appropriate.
different types of property.
 
The legislative position and the provision and 
1 Single dwellings, including shared housing, (Fire
management of supported housing is complex and 
  risk assessment  not required)    
LHA
outside the scope of this protocol.
2 All House in Multiple Occupation (HMO) whether 
3.  What will Local Housing Authorities do?
or not subject to mandatory, selective or additional
 
Local Housing Authorities will undertake, in line with 
  licensing  
 
LHA
their statutory requirements, monitoring and inspection 
of premises identified in Section 2 of this protocol.
3 Hostels generally have a requirement for the residents to have a particular need or dependency and do not provide permanent accomodation
64
housing – fire safety

They will enforce fire safety standards in accordance with 
4.  What will Fire and Rescue Authorities do?
the provisions of the Housing Act 2004, having regard 
Fire and Rescue Authorities will undertake, in line with 
to relevant documents published by the Government 
their risk-based policies, monitoring and inspection of 
including the statutory operating and enforcement 
premises identified in Section 2 of this protocol which 
guidance on the Housing Health and Safety Rating 
fall under the scope of the Fire Safety Order.
System and in accordance with any guidance jointly 
agreed with the Fire and Rescue Authority.
They will enforce fire safety standards in accordance 
with the Fire Safety Order, having regard to relevant 
Local Housing Authorities will, when taking 
documents published by the Government including, Fire 
enforcement action under the Housing Act 2004, have 
Safety Risk Assessment: Sleeping Accommodation (ISBN 
regard to the principles and requirements of the Fire 
1851128174) and in accordance with any guidance 
Safety Order.
jointly agreed with the Local Housing Authority.
Although Local Housing Authorities may offer 
They will undertake consultation with Local Housing 
a suitable means of complying with fire safety 
Authorities in line with the criteria detailed in Section 
requirements, they will also;
5 of this protocol.
• Ensure that guidance for landlords of relevant multi 
They will provide Local Housing Authorities with 
occupied properties on undertaking their own risk 
relevant, timely and comprehensive data to enable 
assessments in accordance with the Fire Safety Order 
those authorities to maintain adequate property and 
accompanies all statutory notices
risk-based data sets.
• Ensure that the owner/landlord is afforded in writing 
the opportunity to bring forward alternative means 
They will provide Local Housing Authorities with 
of complying with the fire safety requirements in 
information, within their scope of competency, of 
accordance with their own fire risk assessment. In 
serious matters that may need to be addressed by 
most cases it is expected that this will be discussed 
those authorities. (This may include such information 
with the owner/landlord prior to the service of any 
as apparent overcrowding, poor management or 
statutory notice 
unsafe practises by tenants).
• Where such alternatives are brought forward by the 
owner/landlord, the Local Housing Authority will 
Fire and Rescue Authorities will undertake to inform 
consult with the Fire and Rescue Authority
Local Housing Authorities of any significant fire incident 
within premises covered by this protocol.
Fire and Rescue Authorities are emergency 
They will undertake consultation with Fire and Rescue 
organisations which provide twenty-four hour cover. 
Authorities in line with the criteria detailed in Section 
Information about dangerous fire safety conditions 
5 of this protocol.
may come via complaints or post incident and may 
occur outside normal working hours.  Fire and Rescue 
They will provide Fire and Rescue Authorities with 
Authorities are under an obligation to take action in 
relevant, timely and comprehensive data in an agreed 
such situations. Where possible, and especially outside 
format to enable those authorities to maintain 
of normal office hours, efforts will be made to mitigate 
adequate property and risk based data sets.
the dangerous conditions and Local Housing Authorities 
will be informed as soon as practicably possible.
Local Housing Authorities will consider the use of 
the full range of powers under the Housing Act 
Fire and Rescue Services would, in principle, be willing 
2004, including Emergency Prohibition Orders, where 
to support Local Housing Authorities at Residential 
appropriate.
Property Tribunal hearings by offering professional 
Local Housing Authorities will provide Fire and Rescue 
opinion on fire safety matters.
Authorities with suitable out of hours contact details 
for their homelessness unit so that where appropriate 
5.  Consultation
consideration is given to ensure vulnerable persons 
are not left homeless as a result of emergency 
Formal consultation between authorities should take 
enforcement action.
place in accordance with the requirements of the 
Housing Act 2004 Section 10 and the Regulatory 
Reform (Fire Safety) Order 2005 Article 46.
housing – fire safety
65

Arrangements should be put in place to facilitate the 
Authority will establish local communication channels 
following:
to exchange data.
Strategic level consultation
Local Housing Authorities will provide data in an 
agreed format to Fire and Rescue Authorities about 
  Formal meetings at strategic management level 
residential premises. This will enable Fire and Rescue 
to review procedural and policy issues. This group 
Authorities to populate their premises databases.
should also monitor the outcomes of the protocol 
Subsequently, Local Housing Authorities and Fire and 
and should meet at least every 6 months.
Rescue Authorities will provide six monthly updates of 
Tactical level consultation
this data.
  Emergency situations – Consultation between 
Local Housing Officer and Local Fire Officer. (Where 
Both authorities will ensure that the information is 
possible this should be between an identified and 
marked as confidential and will not disclose it to 
named link officer from each authority).
other organisations without consent. Authorities will 
  Non-emergency (such as proposals for inspection 
not use or disclose information supplied pursuant 
programs) – Discussions between named link 
to this protocol without consulting the originating 
officers, and where appropriate referred to strategic 
authority. All information whether held on manual 
meetings.
files or computer/digital media will be disposed of as 
Individual consultation
confidential waste. 
  If a scheme of works for an individual property is 
Suggestions as to the scope and detail of this data are 
in compliance with legislative requirements and 
given in Appendix C. 
any jointly agreed guidance then consultation 
can be deemed to have taken place. Depending 
9.  Approval
on circumstances and the complexity of the 
requirements, written consultation may not always 
The protocol will be approved and endorsed at a 
be necessary. Where alternatives to schemes are 
suitable strategic management level by both the Local 
offered or problematic/non-standard premises are 
Housing Authority and the relevant Fire and Rescue 
involved, full consultation should take place. 
Authority.
  Where necessary, in complex premises, joint 
Consultation should take place on a sub-regional basis 
inspections may be undertaken to agree a suitable 
with appropriate Private Sector Housing Groups.
standard prior to the taking of enforcement action 
 
by the most appropriate authority.
6.  Communication
Local communication channels will be established 
between each Fire and Rescue Authority and the 
respective Local Housing Authority.
Each authority undertakes, so far as they are able, 
to provide the other with assistance and information 
about their respective legislation to promote mutual 
understanding and efficient working.
7.  Monitoring and evaluation
Any changes to this protocol, other than minor 
administrative changes, will be subject to approval at 
strategic level and the signatories to the protocol.
An annual report will be produced jointly by parties to 
the protocol.
8.  Data Exchange
Each Local Housing Authority and Fire and Rescue 
66
housing – fire safety

Appendix A
Regulatory Reform (Fire Safety) Order 2005
The rating and category of hazard are used to inform 
The Regulatory Reform (Fire Safety) Order 2005 (Fire Safety 
decisions about what type of enforcement action a local 
Order) requires responsible persons to undertake a fire risk 
authority may need to take in relation to the hazard. The 
assessment to identify the general fire precautions they 
types of enforcement action which are available to local 
need to take to ensure, as far as is reasonably practicable, 
authorities are outlined in the Act and include improvement 
the safety of relevant persons from fire.
notices, prohibition orders, hazard awareness notices, 
emergency remedial action, emergency prohibition orders, 
Having identified the general fire precautions necessary, 
demolition orders, and slum clearance declarations.
the responsible person must implement them. Where 
five or more persons are employed or any form of licence 
‘Fire’ is one of the categories of hazard which is assessed 
or certification applies to the use of the premises, the 
under the system. It includes threats from exposure to 
significant findings of the fire risk assessment must be 
uncontrolled fire and associated smoke at a dwelling.
recorded.
Where a local authority has identified a prescribed fire 
hazard in a House in Multiple Occupation or in any 
The responsible person is identified as, the employer, the 
common parts of a building containing one or more flats 
occupier or the owner as far as their control extends. 
and intend to take enforcement action, the Act requires 
In premises covered by this protocol which are not 
the local authority to consult the Fire and Rescue Authority 
workplaces, the landlord or managing agent is likely to be 
for the area in which the House in Multiple Occupation or 
the responsible person. Tenants must cooperate with the 
building is situated.
responsible person.
In the event of the authority proposing to carry out 
In most cases the local fire and rescue authority are charged 
emergency measures the duty to consult the Fire and 
with a duty to enforce the Fire Safety Order and have a 
Rescue Authority is a duty so far as it is practicable before 
range of enforcement options, from education and advice, 
carrying out those emergency measures.
through agreed action plans to formal enforcement notices 
and prohibition notices. Failure to comply with the Fire 
Safety Order may constitute a criminal offence.
Part 2 of the Housing Act 2004 introduces a licensing 
scheme for Houses in Multiple Occupation (HMO). The 
In general, the Fire Safety Order applies to all areas of 
Act introduces three types of licensing scheme which local 
premises except those areas occupied as private domestic 
authorities can use. These are mandatory HMO licensing, 
dwellings. Where there are areas used in common by the 
additional HMO licensing of properties not covered by 
occupants of more than one such dwelling, the Fire Safety 
the mandatory scheme and, under certain circumstances, 
Order applies.
selective licensing of all private rented property within a 
 
neighbourhood.
The Housing Act 2004
The Act outlines the conditions for the granting or refusal 
The Housing Act 2004 includes the requirement for local 
of licences by a local authority and this includes the 
authorities to review housing conditions within their area 
suitability of a property for multiple occupation.
with a view to identifying any action that may need to 
With regard to fire safety, this is further elaborated in 
be taken about those conditions under the provisions 
the Licensing and Management of Houses in Multiple 
contained within the Act.
Occupation and other Houses (Miscellaneous Provisions) 
(England) Regulations 2006, schedule 3 of which states 
In relation to this, Part 1 of the Housing Act 2004 replaces 
that ‘appropriate fire precaution facilities and equipment 
the existing housing fitness standard with an evidence 
must be provided of such type number and location as is 
based risk assessment procedure called the Housing Health 
considered necessary’. 
and Safety Rating System. 
 
The Housing Health and Safety Rating System is used 
to assess twenty nine categories of housing hazard and 
to provide a rating for each hazard. A hazard rating is 
indicated by a numerical score which is placed within one 
of ten bands from A to J. A numerical score within bands A 
to C are Category 1 hazards and scores in Bands D to J are 
Category 2 hazards. 
housing – fire safety
67

Appendix B 
Signatories to protocol
Authority 
 
 
Name   
 
 
 
 
Signature and date 
 
 
68
housing – fire safety

Appendix C
Data exchange details
Database details will vary considerably but 
the following data fields are likely to be 
necessary.
LA URN (unique identifier if available)
Eastings
Northings
Property number
Property name
Address Line 1
Address Line 2
Locality
Town
Postcode
Number of floors
Risk Level
Compliance level
Number of units
Licensed
Category/Type
Landlord/responsible person/Contact
Property number
Address Line 1
Address Line 2
Locality
Town
Postcode
Telephone number 
 
housing – fire safety
69


Appendix 3: Example form for recording 
significant findings from the fire 
asessment (alternative formats are 
acceptable)

Notes: 
(1)   this risk assessment record of significant findings 
should refer to other plans, records or other 
documents as necessary.
(2)   the information in this record should assist you to 
develop an emergency plan, coordinate measures with 
any other ‘responsible persons’ in the building, train 
any staff and inform residents.
70
housing – fire safety

GLOSSARY
recognised by the Council of Registered Gas Installers as 
Some useful fire safety terms 
being competent to undertake such testing, but this is 
changing (see Appendix 1, paragraph A.70).  
AFD 
FD30 / FD30S 
Automatic fire detection and warning system. A system 
of interlinked smoke and heat detectors with integral or 
Purpose designed and built fire-resisting door assemblies 
linked alarm sounders. The AFD system is designed to 
with a minimum fire resistance of 30 minutes. The 30 figure 
provide a reliable and constant means of detecting smoke 
indicates the door’s performance time in minutes. A letter 
or fire at the earliest possible stage and to sound an audible 
‘S’ after the figure denotes a requirement for smoke seals 
warning to occupiers, enabling them to escape before the 
to be fitted so as to restrict the passage of smoke, including 
fire develops to a dangerous stage. The sophistication and 
cold smoke. Tested to either British or European standards. 
coverage of the system varies depending on risk. Design, 
installation and maintenance of AFD systems for premises 
Fire risk assessment 
covered in this guide are laid down in BS 5839: part 6, 
An organised and methodical look at a premises, the 
1995.
activities carried on there and the likelihood that a fire could 
start and cause harm to those in and around the premises. 
Area of high fire risk 
A requirement in premises to which the Regulatory Reform 
Room or other area which, because of its function, use 
(Fire Safety) Order 2005 (FSO) applies.
or contents, presents a greater risk of fire occurring and 
developing than a standard risk room or elsewhere – for 
FRA   
example large kitchens, boiler rooms and large storerooms.
Fire and rescue authority. 
 
Back-up supply 
FSO 
See stand-by supply
The Regulatory Reform (Fire Safety) Order 2005. See 
 
Appendix 1, paragraph A.51.
Bedsit HMO 
A building which has been divided into individual non-
Final exit 
self-contained lettings, let to unconnected individuals. 
The termination of an escape route from a building 
Each bedsit letting will usually comprise only one room 
giving direct access to a place of safety such as a street, 
(sometimes more) which may contain cooking/food 
passageway, walkway or open space, and sited to ensure 
preparation facilities, washing facilities and living/sleeping 
that persons can disperse safely from the vicinity of the 
space. Usually bathrooms and WCs are shared between a 
effects of fire.
number of bedsits. The actual facilities contained within 
 
each bedsit letting will vary from property to property.
Fire-resisting door 
Complete construction of door, frame, all door hardware 
Circulation spaces 
(and assemblies intumescent products and smoke seals where 
Passages, corridors, landings, hallways, lobbies and 
appropriate) which has been tested to prove its fire resistance 
stairways.
performance to a particular standard. See FD30 above.
 
 
Competent person 
Fire test report 
A person suitably trained and experienced so as to be able 
The documentation received from a testing house detailing 
to properly examine, test and undertake any remedial 
a test carried out on a particular product or construction 
action and to present the information in a report.
and the fire resistance performance achieved by the 
product/construction in that test. 
Competent and registered engineer    
 
A term used in the HMO management regulations (see 
Flat in Multiple Occupation
Appendix 1, paragraph A.46) to describe a person who is 
A self-contained flat occupied by persons who do not form 
competent to inspect gas installations and provide a gas 
a occupation (FMO) single household.
appliance test certificate. The term means an engineer 
housing – fire safety
71

High fire risk 
through another person as agent or trustee, that other person.
See ‘area of high fire risk’ above. 
Pictogram 
HMO 
A diagram conveying a message without the use of words.
House in multiple occupation, as defined in section 254 
 
of the Housing Act 2004 (see Appendix 1, paragraphs 
Place of ultimate safety 
A.33-A.38). 
A place outside of the building and away from it, where 
people will be safe and unaffected by the fire or its effects.
Intumescent strip 
A strip of special material fitted around the edges of a fire door 
Plasterboard 
which swells to several times its original volume when subjected 
A board of gypsum plaster enclosed between and bonded 
to heat. During a fire it will expand to fill the gap between the 
to two paper sheets. 
door and the frame providing a fire, heat and smoke resistant 
seal, thereby improving the door’s fire resistance. 
 
Protected route 
LHA 
An escape route out of a building offering a degree of 
protection from fire and smoke emanating from rooms 
Local housing authority.
opening onto it. In premises covered by this guide it will 
typically be the usual staircase, landings and hallway of 
NICEIC 
the house leading to a final exit. A protected route will 
National Inspection Council for Electrical Installation Contracting. 
provide varying degrees of protection from fire and smoke 
in accordance with risk (a 30-minute protected route, for 
 
example, will be enclosed with construction giving 30 minutes 
Nuisance alarms 
of fire resistance and containing 30-minute fire-resisting doors 
Alarms sounding in a system not caused by a genuine fire – 
with smoke seals (FD30S)). Lower risk premises will have 
may result from poor system design, occupier behaviour or 
protected routes offering a lower standard. 
a fault in the system. 
 
Relevant persons 
Person having control 
Relevant persons include anyone lawfully on the premises 
The person who receives the rack rent of the premises 
and those in the vicinity of the premises who would be 
(whether on his own account or as an agent or trustee of 
affected by any fire at the premises.
another person) or would so receive it if the premises were 
let at a rack rent (Housing Act 2004, section 263).
Residential property tribunal (RPT) 
The formal name given to a tribunal of two or three people 
Person managing 
set up by law under the provisions of the Rent Act 1977 and 
The person who, being an owner or lessee of the premises:
the Housing Act 2004. It is an independent decision-making 
(a) receives (whether directly or through an agent or 
body which is completely unconnected to the parties or any 
trustee) rents or other payments from— 
other public agency. The RPT is the tribunal which determines 
(i) in the case of a house in multiple occupation, 
appeals against any enforcement actions taken under the 
persons who are in occupation as tenants or 
Housing Act 2005. Weblink: www.rpts.gov.uk
licensees of parts of the premises; and 
(ii) in the case of a house to which part 3 applies (see 
Responsible person 
section 79(2)), persons who are in occupation as 
The responsible person for the purposes of fire safety 
tenants or licensees of parts of the premises, or of 
provision and maintenance at residential accommodation 
the whole of the premises; or 
is the person having control, i.e. the landlord or person 
(b) would so receive those rents or other payments but for 
managing.
having entered into an arrangement (whether in pursuance 
 
of a court order or otherwise) with another person who is 
Risk analysis 
not an owner or lessee of the premises by virtue of which 
An exercise to determine the level of risk of suffering harm 
that other person receives the rents or other payments; and 
from an activity based upon a range of criteria – see Part B. 
includes, where those rents or other payments are received 
72
housing – fire safety

Risk room 
Storey 
A room with a function, use or contents presenting a risk 
In this guidance, for the purposes of fire safety, when 
of fire occurring and developing; typically kitchens, shared 
counting the number of storeys the reader should count 
living rooms, bedsit rooms. On risk assessment may include 
all floors from the level of the final exit to the topmost 
bedrooms in some cases. Excludes bathrooms and WCs 
floor (include mezzanines as storeys). Where the final exit 
containing no fire risk. See also ‘area of high fire risk’.
is located on the ground floor (or raised ground floor) any 
lower ground floor/basement/cellar should not be counted. 
Therefore, a house with a basement, ground and two 
Room sealed appliance 
upper floors with its entrance/final exit at ground floor level 
A gas appliance whose combustion system is sealed from 
should be counted as a three-storey house. Note: this is a 
the room in which the appliance is located and which 
different convention to that in the HMO licensing definition 
obtains combustion air from outside the premises, and 
(which counts cellars/basements) as this guidance is 
which also vents the products of combustion to open air 
considering the distance of travel to the final exit as a factor 
outside the premises. Most modern gas boilers are room 
in determining fire risk.
sealed appliances.
 
 
Suitably qualified Person 
Self-contained flats 
See ‘competent person’. 
The meaning within this guide relates to conversion flats in 
single occupation with all amenities behind the front door. 
Test report 
 
See ‘fire test report’.  
Shared house 
 
See paragraph 35. 
Voids 
Significant findings 
Unused empty spaces within a building.
The actions to be taken as a result of a fire risk assessment 
and details of anyone especially at risk. Must be recorded in 
Vulnerable group  
some cases (see paragraph 10.1). 
The HHSRS Operating Guidance defines a vulnerable 
group as “a range of people for whom the risk arising 
Smoke seal/strip 
from a hazard is greater than for any other group in 
the population.” It is restricted to age groups, no other 
A rubber or synthetic strip fitted around the edge of a fire 
vulnerability is considered. The assessment of likelihood 
door to restrict the passage of smoke between the door 
of an occurrence resulting in harm is assessed based on a 
and the frame. Doors requiring a smoke seal have the 
member of this group living in the property. For the hazard 
letter ‘S’ after their performance time in minutes in their 
of fire, the vulnerable group is persons over the age of 60. 
designation (for example FD30S). The smoke resistance of 
The vulnerable group is only used to assess the hazard – 
the door when fitted with the strip will have been tested to 
when it comes to enforcement decisions then the actual 
standards in BS476: part 31.1, 1983.
person living there is considered.
Soffit 
Where necessary  
Underside of staircase, balcony, architrave or arch.
The Regulatory Reform (Fire Safety) Order 2005 requires 
 
that fire precautions should be provided (and maintained) 
Spandrel 
“where necessary”. This means those which are needed 
A vertical partition enclosing a staircase (usually found on 
to reasonably protect relevant persons from risks in case 
the ground floor enclosing a staircase to the basement, or 
of fire. This will be determined by the findings of the 
in the basement enclosing a staircase to the ground floor).
risk assessment, including the preventative measures 
being taken. In practice, it is very unlikely that a properly 
Stand-by supply 
conducted fire risk assessment, which takes into account 
all the matters relevant for the safety of persons in case 
Battery power to fire alarm or lighting systems which cuts in 
of fire, will conclude that no fire precautions (including 
if mains power fails.
maintenance) are necessary.
housing – fire safety
73

 Bibliography
The Furniture and Furnishings (Fire) (Safety) Regulations 
1988 : Statutory Instrument 1988 No. 1324 
The following references are included as a source of further 
detailed reading for specialists. It is not anticipated that 
Health and Safety (Safety Signs and Signals) Regulations 
landlords of property covered by this guide will need an 
1996, Statutory Instrument I 1996/341. 1996. ISBN 0 11 
in-depth knowledge of these publications and parts B, C 
054093 X.
and Appendix 1 to this guide should provide an adequate 
summary for most purposes. 
Safety Signs and Signals. The Health and Safety (Safety 
Signs and Signals) Regulations 1996.
Acts of Parliament and Statutory Instruments are available 
Guidance on regulations, L64. HSE Books, 1996. ISBN 0 
from The Office of Public Sector Information (OPSI) and via 
7176 0870 0.
their website at www.opsi.gov.uk
BS 5499-4: Safety signs, including fire safety signs. Code of 
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British Standards Institution.
0242 and via their website at www.standardsuk.com
BS 5306-8: Fire extinguishing installations and equipment 
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HSE books via their website at www.hsebooks.com
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ISBN 0 580 33203 9.
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BS 5306-3: Fire extinguishing installations and equipment 
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maintenance of portable fire extinguishers. British Standards 
543404 3.
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BS EN 12845: Fixed firefighting systems. Automatic 
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BS 5839-6: 1995 Fire detection and alarm systems for 
(England) Regulations 2006: Statutory Instrument 2006 no. 
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373  
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The Regulatory Reform (Fire Safety) Order 2005: Statutory 
ISBN 0 580 25104 7.
Instrument 2005 No. 1541 
ISBN 0 11 072945 5
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The Gas Safety (Installation and Use) Regulations 1998: 
Institution. ISBN 0 580 14706 1.
Statutory Instrument 1998 No. 2451
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BS 5266-8: Emergency lighting. Code of practice for 
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Sheet 1-32. Timber Research and
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BS 5266-1: Emergency lighting. Code of practice for the 
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electrical low mounted way guidance
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systems for emergency use. Photoluminescent systems. 
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BS 7974: Application of fire safety engineering principles to 
the design of buildings. Code of practice. 
LPS 1048-1 : Requirements for the approval of Sprinkler 
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System Contractors in the UK and Eire. SD 1048-1 : BRE 
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BS 476-7: Fire tests on building materials and structures. 
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LPC rules for automatic sprinkler installations, incorporating 
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BS EN 13501-1: Fire classification of construction products 
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BS EN 1634-1: Fire resistance tests for door and shutter 
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Methods for determination of the fire resistance of non-
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housing – fire safety
75

Further acknowledgements 
 
Gratitude is also owed to the following people who made 
Greater Manchester Fire and Rescue Service
up the project steering group and provided invaluable 
Greater Manchester Local Authorities
support for the project:
Harlow Council
Andrew Chadney, London Fire and Rescue Authority
Hart Borough Council
Andy Kippax, Stockport Metropolitan Borough Council
Hastings Borough Council
Brian Martin, Communities and Local Government
Herefordshire Council
Elizabeth Brogan, National Landlords Association
Herts & Beds Housing Group
Neil Coles, London Borough of Newham
Homestamp
Paul Dryden, Greater Manchester Fire and Rescue Service
Kent Local Authorities
Richard Drew, Westminster City Council
Lancashire Fire and Rescue Authority
Richard Tacagni, LACORS
Lincoln City Council
Rhian Blackman, Communities and Local Government
London HMO Regulatory Group
Tony Agar, London Fire and Rescue Authority
Merseyside Local Authorities and Fire and Rescue Authority
Newcastle City Council
National Federation of Residential Landlords
Lastly, LACORS thanks the following who contributed  
North Yorkshire Local Authorities
via the consultation process:
Oxfordshire  Fire and Rescue Authority
Andrew Jones 
Oxfordshire  Local Authorities
Association Of Residential Managing Agents
Peter Freeman Properties, Sheffield
Avon Fire and Rescue Service
Peterborough City Council
Barrow Borough Council
PJ Properties, Sheffield
Bedford Borough Council
Plymouth City Council
Berkshire Housing Group
Residential Landlords Association
Brighton & Hove City Council
Rex Caplan, Landlord
Bristol City Council
Richard Clark 
British Property Federation
Richard Jones of Bury & Walkers Solicitors
Broxtowe Borough Council
Rushmoor Borough Council
Camden Borough Council
Salisbury District Council
Carlisle City Council
Sheffield & District Landlord Association
Cornwall Housing Sub Group
Sheffield City Council
Cumbria Local Authorities
Sheffield Student Landlord Association
Devon and Somerset Fire and Rescue Authority
South Yorkshire Local Authorities
Devon Chief Officers Housing Group
Southampton City Council
Dover District Council
Staffordshire Housing Technical Group
East London sub-regional Housing Group
Tyne & Wear Fire and Rescue Authority
East Staffordshire Borough Council
UNIPOL
Eastbourne Borough Council 
University Of Essex
Electrical Contractors Association
Watford Borough Council
Elmbridge Borough Council
West Midlands Fire and Rescue Authority
Epping Forest Borough Council
West of England Local Authorities
Essex Fire and Rescue Authority
Westminster City Council
Fire and Security Association 
Wiltshire Fire and Rescue Authority
Fire Industry Association Ltd
76
housing – fire safety





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