Fire Risk Assessment Report: Legal requirements vs Non-legal

[MGA2001]

We have a large Almshouse with approximately 40 dwellings, it is a mixture of bedsits, flats, and houses. The property is Grade II listed and made of stone.

We recently had a FRA carried out, and almost every dwelling failed due to various things such as the lay outs of the dwellings, the escape routes being in the wrong place (through the kitchens), not enough smoke detectors, the need for fire proof plaster boarding, communal smoke detectors in enclosed passageways where 4-5 doors are to access the residents properties.

My query is this – are any of these suggestions legally required?

It would be incredibly challenging and very very expensive to start changing the entrance ways, layouts, and escape routes on some of the properties as we would need to relocate the front door. We also have the hurdle of the buildings being listed and planning permission would be sought.

Does anybody have a list of the legal requirements that Almshouses MUST comply with, or any experience in dealing with these sorts of issues post FRA?

Challenges such as the emergency lighting being installed on the outside of the building again would require planning permission, as well as drilling holes for better internet connectivity which we advise against.

Any tips, advice, checklists, would be greatly appreciated.

[Clare Heyes]

There is very strict legislation with regard to smoke detectors:

https://www.gov.uk/government/publications/smoke-and-carbon-monoxide-alarms-explanatory-booklet-for-landlords/the-smoke-and-carbon-monoxide-alarm-england-regulations-2015-qa-booklet-for-the-private-rented-sector-landlords-and-tenants

I suggest you start with provision of smoke detectors bearing in mind that it is likely that linked smoke/heat detector legislation will be coming in to England in the next year or so. These work on radio waves and don’t need internet.

Please be aware that the Fire Service can impose improvements on you if they are so minded and carry out a spot inspection. This happened at an Almshouse Charity in Chelmsford and cost them about £80K!

Part of the FRA should have been a traffic light set of recommendations. You should seriously consider all “red” actions. I suggest a conversation with your insurers as you may find you are not covered in the event of fire if you fail to act on explicit advice.

Good luck.
Clare Heyes

[MGA2001]

Hi Clare,

Thank you for your reply.

We currently have 1-2 smoke detectors in each flat, however some are being moved or more added as suggested. This will be an area we will review and change.

An issue we face is that some residents break their detectors or remove batteries so that they can smoke in their bedsits/flats. We have issued a no smoking policy and many warnings against the dangers but cant do any more.

We are working towards a plan to make the changes, we have been informed by a couple of different people that so long as we show progress and plans to make the changes the trustees will be likely covered against liability in the event of a fire. We will check this, but of course we will strive to make any and all of the amendments they have suggested. We have already installed 18 fire doors which cost around £20k.

We will consider all of the “red” actions and indeed the orange and green too. It has been very time consuming to read through 38 individual fire reports which are all around 60 pages long that make different recommendations for each flat, however, we are working towards achieving as much as possible.

Our other issue is disruption to the residents. I do not think some of them will be willing to swap their kitchen and bedroom around, not will they want to be temporarily housed in a vacant property whilst works are carried out.

Do you know if there are any grants available for carrying out the suggestions from the FRAs?

I will look to speak to the local planning office and also the insurance company in due course.

Many thanks

[Tim Richardson]

Difficult to comment without seeing the detail but I have seen a lot of FRA’s which treat Listed Buildings the same as new builds – they are often not particularly Fire Risk Assessments but audits of everything which doesn’t comply with the current regs (which is usually mostly everything). Internals of individual flats ARE NOT covered by the requirements of the Fire Safety Order so I am puzzled as to why these have been included, they should be assessed under the Housing Act and the Housing Health and Safety Rating System HHSRS but some Fire Risk Assessors don’t seem to appreciate this. So the concept of an individual dwelling “failing” the FRA does seem to be a bit odd.

Conversely front doors of individual flats are covered as are all common areas and externals and if there were compartmentation issues then that would be relevant although most FRA’s seem to omit any reference to compartmentation.

I am a Chartered Building Surveyor, Registered Fire Risk Assessor for Heritage Buildings and CIAT-Conservation Accredited so do know a bit about this subject. Feel free to drop me an email if you want any further advice. tim@timothyrichardson.co.uk

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