An insider's guide to recent fire safety management legislation changes

I have been involved in public housing for over 50 years, 35 of them as a senior manager. Following the Lakanal House fire, I became increasingly interested in fire safety and after many years of advocating sensible solutions to fire safety issues I recently became an associate of the Institute of Fire Safety Managers.

The number of recent changes in the law affecting social housing is unprecedented. To fully understand the fire safety implications myself, I created a simple summary of those affecting housing managers between now and 23 January 2023. The summary, detailed below, is an alternative blog providing a useful summary for housing professionals on the legislation changes to be aware of and what these mean in practice. 

Secure information boxes are required in all buildings over 18 metres or 7 storeys (high-rise buildings), they must contain:

• Name and contact details of the responsible person(s) and anyone else connected with the building
• Floor plans showing key fire-fighting equipment
• Single page block plan showing key fire-fighting equipment

Design and materials of external walls:

• Responsible person(s) must share information about external wall systems on all high-rise buildings and their associated level of risk
• The government will provide supporting guidance in due course
• For buildings of any height, fire risk assessments must now consider the external wall and any balconies as part of the assessment

Floor plans and building plans for all high-rise buildings:

• Responsible person(s) must include hard copies in secure information boxes and share them electronically with the fire and rescue service
• Floor plans must show key fire-fighting equipment
• Single page block plan must show fire-fighting equipment

Lifts and essential fire-fighting equipment. In all high-rise buildings, monthly checks will be required for:

• Lifts for use by fire fighters
• Evacuation lifts
• Inlets and outlets for dry-rising mains and wet-rising mains
• Smoke control systems
• Suppression systems
• Fire detection and fire alarm systems including any detectors linked to ancillary equipment such as smoke control systems (in the common parts),
• Evacuation alert systems
• Automatic door release mechanisms linked to fire alarm systems

Guidance will be issued to specify which pieces of equipment are subject to a visual inspection or other checks. It is not intended that specialists will be needed for the checks. The fire and rescue service must be told (as soon as practicable) if a fault cannot be resolved within 24 hours.

Wayfinding signage: all high-rise buildings (new and existing) must have signage and flat and floor numbers visible in low light. This will also be required for all new buildings over 11 metres tall.

Information for residents: Responsible person(s) in all multi-occupied residential buildings will need to provide residents with key fire safety information, which must include:

• Details of any fire safety risks in the building
• Instructions on how to report a fire
• A reminder of what the evacuation strategy is for that building, and;
• Any other instruction that tells residents what they must do once a fire has occurred, based on the building’s evacuation strategy.

Visibility of information for residents: the responsible person(s) must ensure the above information for residents is:  

• Displayed clearly in their building’s communal areas (such as the building’s lobby or any conspicuous part of the building)
• Shared directly with residents when they move into the building
• Re-provided in both the communal areas and to residents when a document is updated
• Re-provided to residents on an annual basis.

Fire doors in properties over 11 metres tall the responsible person(s) must:

• Undertake quarterly checks of all fire doors (including self-closing devices) in the common parts; and,
• Undertake – on a best endeavour basis – annual checks of all flat entrance doors (including self-closing devices) that lead onto a building’s common parts.

The regulations will also require the responsible person(s) to provide information to residents on the importance of fire doors to a building’s fire safety. This will be required in all multi-occupied residential buildings which have two or more sets of domestic premises and common parts. The minimum requirement is for the responsible person(s) to undertake an inspection of the doors to identify any obvious damage or issues.

When conducting fire door checks, the responsible person(s) should assess:

• If there have been any alterations or damage to a door’s glazing apertures or air transfer grille
• If there are any gaps around the door frame and whether seals and hinges are fitted correctly
• That the door closer shuts the door and that the door closes correctly around the whole frame
• That there is no visible damage (either deliberate or from wear and tear) to the door or door closer

If any issues are identified from these checks, it might be appropriate to undertake more detailed checks of doors (or the self-closing device) if any damage is identified from the initial inspection. This could include engaging a specialist.

Other requirements and recommendations

Personal Emergency Evaluation Plans (PEEP) and Emergency Evacuation Information Sharing (EEIS)
Whilst we await details of the responses to the consultation, it would be sensible to ensure Person Centred Fire Risk Assessments (PCFRAs) are already being completed in sheltered blocks, as well as those blocks with a waking watch. Having a process in place to reduce the risks for mobility impaired residents and a plan for an assisted escape ought to be in place for all properties (including properties on the ground floor) should it becomes necessary.

Maintenance issues New regulations coming into force from 1 October 2022 require:

• Smoke alarms on every storey in each property and a carbon monoxide alarm in any room used as living accommodation which contains a fixed combustion appliance (excluding gas cookers).
• A review of existing arrangements for dealing with faults to individual alarms to ensure there is a prompt response, and that it is properly recorded.

There is a consultation underway on electrical testing which proposes a requirement for electrical safety tests every five years. If this is not already in place, it would be sensible to review how void electric checks are recorded and begin to plan to introduce these checks across all properties.