Fire safety principles for residential accommodation

This document has been produced by Leeds City Council, in consultation with the West Yorkshire Fire and Rescue Service, other West Yorkshire local authorities and representatives from landlord groups. 

  • Foreword
  • Introduction
  • The principles of risk assessment for fire safety
  • Design principles for fire safety schemes
  • Category A HMOs (occupied as bedsits and non-self contained flats
  • Category B HMOs (shared houses)
  • Single household properties
  • Back-to-back houses (singly and multiply occupied)
  • Basements and Cellars
  • Glossary

Foreword

This document has been produced by Leeds City Council, in consultation with the West Yorkshire Fire and Rescue Service, other West Yorkshire local authorities and representatives from landlord groups. 

It is based on the national guidance document produced by LACORS, Housing – Fire Safety, Guidance on fire safety provisions for certain types of existing housing published in July 2008 and aims to provide guidance for the design of fire safety schemes for residential accommodation in all tenure groups, including owner-occupied, social housing providers as well as those in the private rented sector. This guidance replaces previous Fire Safety Principles issued by Leeds City Council (“LCC”)

This guide offers practical advice on undertaking fire risk assessments and contains case studies of fire safety solutions in a range of property types. 

It aims to provide recommendations and guidance when assessing the adequacy of fire precautions and does not set prescriptive standards. Where there is doubt on the suitability of a fire safety scheme, then further advice can be sought from LCC’s Housing Regulation Team or alternatively, West Yorkshire Fire & Rescue Authority (“WYFRA”).

Telephone

  • Private Rented Sector Housing Team, Leeds City Council, for queries relating to single household properties and non-licensable HMOs 0113 378 4699
  • HMO Team, Leeds City Council, for queries relating to licensed and licensable HMOs – 0113 378 4698
  • Fire Safety Office Leeds, West Yorkshire Fire and Rescue Service 0845 155 0595
  • Development Enquiry Centre, Leeds City Council, for all queries relating to planning and building control matters 0113 222 4409

It is important to note that some fire safety works may be classed as building works for the purpose of building regulations and therefore approval maybe required from the local authority’s Building Control Services. Similarly new-build residential accommodation or conversions where there is a change of use of an existing building to a house in multiple occupation or self-contained flats may also require planning permission.

Introduction

This fire safety guide applies to all buildings constructed or converted for use as domestic dwellings and includes single and shared households, bedsit HMOs, purpose built flats and buildings converted into self-contained flats to a standard that does not comply with the Building Regulations 1991, sheltered accommodation where no personal care is provided and small hostels where the HM Government Sleeping Accommodation Guide (HM Government Fire Risk Assessment: Sleeping Accommodation Guide published by Communities and Local Government in May 2006) does not apply. 

Where self-contained flats did meet the 1991 Building Regulations standards but they are now in a poor condition due to a lack of maintenance, damage or alteration, or where they are occupied in a manner other than intended (ie in multiple occupation) then appropriate additional measures from this guide can be applied.

The guide does not apply to a range of other residential uses, including guest houses and hotels used by visitors, large hostels, refuges, residential training and conference centres and health and beauty spa centres, student halls of residence, boarding schools, residential care homes and workplaces where employees sleep on the premises as a business requirement e.g. a hotel, but not including tied accommodation and accommodation above pubs. For these premises the Regulatory Reform (Fire Safety) Order 2005 (“FSO”) applies and guidance is contained in the HM Government Sleeping Accommodation Guide.

The FSO introduced duties on the responsible person, (ie the person in control of premises) in relation to fire safety in the common parts of HMOs, flats, maisonettes, bedsits and sheltered accommodation where no personal care is provided. The duty is to carry out a fire risk assessment and to take specific action to minimise the risk of fire in common parts. Whilst the assessment is of common parts only, in practice it will take into account the whole of the premises including all units of accommodation. 

It is important to note that the FSO does not apply to HMOs that are occupied as shared houses. The FSO is enforced by the fire and rescue authorities. There is a small section in this guide that covers the key aspects of undertaking a fire risk assessment in smaller residential premises. Specialist advice should be sought for larger, complex premises or premises with mixed use.

In addition to the FSO, fire safety in residential accommodation is also covered by the Housing Act 2004, by way of the housing, health and safety rating system (“HHSRS”), the licensing provisions for HMOs and the management regulations for HMOs. This legislation is enforced by local authorities.

As there is a dual enforcement role for fire safety, the general protocol in Leeds is that the council will lead on single households, shared houses (Category B HMOs), bedsits (Category A HMOs) and self-contained flats, whilst WYFRA will lead on mixed use premises, sheltered housing, large hostels, hotels and bed and breakfast accommodation and all multiply occupied property managed and owned by the local authority. In dual enforcement situations Leeds City Council may take action in consultation with WYFRA.

1.0 The principles of risk assessment for fire safety

A fire risk assessment is a methodical inspection of premises, examining the activities undertaken there, the likelihood of a fire starting and the risk of harm occurring to occupiers and people around the premises. 

The aim of the assessment is to identify fire hazards, reduce the risks of hazards causing harm to as low as reasonably practicable, and to decide what physical fire precautions and management arrangements are necessary to ensure the safety of people within the building if a fire does occur.

1.1 Identifying fire hazards in premises

A hazard is anything that has the potential to cause harm. In terms of a fire safety risk assessment the following hazards should be considered -

The vulnerability of occupiers 

People at risk must be considered. This may include the elderly and the young; people with personal challenges such as drug abuse or alcohol dependency; people with disabilities that would affect them using the means of escape without assistance (i.e. impaired mobility, hearing or vision) and people with difficulty understanding English.

Sources of ignition  

Potential sources of heat that could get hot enough to ignite surrounding materials should be considered. These may include:

  • Cookers, toasters and other kitchen equipment (especially when shared);
  • Radiant and portable space heaters;
  • Smokers materials such as cigarettes, matches and lighters (if people smoke within the premises);
  • Faulty or misused electrical appliances;
  • Electrical wiring in poor condition;
  • The gas installation;
  • An inadequate number of electrical power points causing overloading, and
  • Naked flames such as candles and night lights.

Sources of fuel  

Anything that burns is fuel for a fire. Therefore a risk assessment should identify things that burn reasonably easily and that are in large enough quantity to provide fuel for a fire or cause it to spread to other fuel sources. Sources of fuel include:

  • Non-fire retardant fabrics and furnishings;
  • Textiles, bedding, clothing, curtains and laundry;
  • Accumulations of unwanted mail, paper, cardboard, books, etc;
  • Flammable liquid-based products such as varnish, paint, thinners, etc;
  • Plastics and rubber such as video tapes, and
  • Wall, floor and ceiling coverings and surface finishes.

1.2 Factors that increase the risk of harm from fire

The main building characteristics that increase the risk of death or injury from a fire include the following:

  • The number of occupiers;
  • The number of storeys;
  • The travel distance to evacuate the building;
  • The complexity of the escape route;
  • The presence of final exit doors requiring the use of a key for opening;
  • The location of the kitchen;
  • Flammable materials within the escape route, including wall coverings, furniture and fittings;
  • The size of rooms;
  • The presence of key operated security grilles fixed to escape windows and external doors, and
  • Rooms where the means of escape is through another high fire risk room, i.e. through a kitchen and/or living room.

1.3 Fire safety measures

The following fire safety measures will reduce the risk of death or injury from fire:

  • The provision of a 30 or 60 minute fire protected route of escape;
  • Fire separation between units of accommodation, including walls & ceilings;
  • The provision of fire doors with intumescent strips (and cold smoke seals as necessary) and self closing devices;
  • Automatic and manual fire detection systems;
  • Emergency lighting;
  • Whole stair lighting;
  • Escape windows;
  • Sprinkler and mist systems, and
  • Fire extinguishers and fire blankets.

1.4 The basic principles of undertaking a fire risk assessment

When carrying out a risk assessment the responsible person should consider the hazards and factors outlined in paragraphs 1.1-1.3 to enable them to determine the following:

  • The likelihood that a fire may cause death or injury;
  • The building characteristics that could increase the risk of harm, and
  • What fire safety measures are needed to reduce the fire risk to a reasonably acceptable level or to minimise the likelihood of harm should a fire start. This could include for example, raising the occupiers awareness of fire safety; removing potential sources of ignition and providing fire safety measures as outlined in paragraph 1.3 above.

2.0 Design principles for fire safety schemes

The fire safety schemes detailed in this guide are based on properties which present a normal risk, i.e. there are no factors that increase the level of risk in the property and the occupiers are not from high risk groups. 

Where such factors exist, or if a property deviates from the types listed below, then the risk can be deemed higher and accordingly a higher level of fire protection may be appropriate. 

Please note the new LACORS guidance also proposes the possibility of some properties being classified as to be of lower risk. A definition of the applicable criteria can be found in the glossary to this document.

2.1.1 Three or four storey buildings converted into self-contained flats

Where one or more floor level exceeds 4.5 metres above the ground level:        

  • A 30 minute protected route of escape in the building with FD30S doors (with self closing devices fitted) to entrances of flats where they open onto the route of escape. There is generally no requirement for a 30 minute protected route within the flats but sound, well constructed and close fitting conventional doors are required. For multiply occupied flats, the route of escape must not pass through a risk room and where there are poor construction standards, long travel distances or high risk factors, a 30 minute protected route will be required within the flat and/or an LD2 AFD system within the flat;
  • A mixed grade AFD is required comprising an LD2 Grade A AFD to the common areas of the building and an interlinked heat detector in each flat located in the room/lobby opening onto the route of escape plus:
  • for a flat occupied by a single household, a non-interlinked LD2 Grade D1 smoke alarm in each individual flat, located in the room/lobby opening onto the escape route. This is to protect the sleeping occupants of the flat, or
  • for a one storey flat in multiple occupation, an interlinked LD2 Grade D1 smoke alarm in each flat, located in the internal hall and a heat detector in the communal kitchen, or
  • for a two storey flat in multiple occupation, an interlinked LD2 Grade D1 smoke alarm each flat, located in the escape route at each level, communal lounge and a heat detector in the communal kitchen.

Where a risk assessment identifies a higher than normal risk, rooms within flats requiring automatic fire detection may include living rooms, kitchens and bedrooms, in which a Grade D system should be used to prevent whole house false alarms:        

  • A dedicated lighting circuit should be installed so that the use of any one switch/control anywhere along the route will illuminate the entire escape route;
  • A manual fire alarm;
  • Final exit and signage along the escape route if the escape is complex;
  • Fire blankets are recommended in the kitchens of flats occupied by single households and are required in the kitchens of multiply occupied flats;
  • A multi-purpose fire extinguisher is recommended at each floor in the common parts of the building containing the flats;
  • Emergency lighting is only required in the escape route for the building containing the flats and in flats that are in multiple occupation, where the escape route is long and complex or where there is no effective borrowed light, and
  • If there is a basement see section 2.6 of this guide.
2.1.2 Two Storey Buildings Converted into Self-Contained Flats

Where no floor level exceeds 4.5 metres above the ground level:      

  • A 30 minute protected route of escape with FD30S doors (with self closing devices fitted) to entrances of flats where they open onto the route of escape. There is no requirement for fire doors within flats but sound, well constructed and close fitting conventional doors are required. For flats occupied by single households, a lower standard of protection in the protected route may be acceptable where there are suitable escape windows from bedrooms and living rooms (see the Glossary for escape window requirements); For flats in multiple occupation, the route of escape must not pass through a risk room. Where there are poor construction standards, long travel distances or high risk factors, a 30 minute protected route will be required within the flat and/or an LD2 AFD within the flat.
  • A mixed grade AFD comprising an LD2 Grade D AFD to the common areas of the building and an interlinked heat detector in each flat, in the room/lobby opening onto the route of escape, plus:
  • for a flat occupied by a single household, a non-interlinked LD2 Grade D1 smoke alarm in each individual flat, located in the room/lobby opening onto the escape route. This is to protect the sleeping occupants of the flat, or
  • for a one storey flat in multiple occupation, an interlinked LD2 Grade D1 smoke alarm in each flat, located in the internal hallway and a heat alarm in the communal kitchen, or
  • for a two storey flat in multiple occupation, an interlinked LD2 Grade D1 AFD in each flat, located in the escape route at each level with an interlinked smoke alarm in the communal lounge and an interlinked heat alarm in the communal kitchen.

Where a risk assessment identifies a higher than normal risk, rooms within flats requiring automatic fire detection may include living rooms, kitchens and bedrooms, in which a Grade D system should be used to prevent false alarms:      

  • A dedicated lighting circuit should be installed so that the use of any one switch/control anywhere along the route will illuminate the entire escape route;
  • Fire blankets are recommended in the kitchens of flats occupied by single households and are required in the kitchens of multiply occupied flats;
  • A multi-purpose fire extinguisher is recommended at each floor in the common parts of the building containing the flats;
  • Emergency lighting is only required in the escape route for the building containing the flats and in flats that are in multiple occupation, where the escape route is long and complex or where there is no effective borrowed light;
  • If there is a basement see section 2.6 of this guide.
2.2.1 Category A HMO - three to four storey buildings

Where one or more floor level exceeds 4.5 metres above the ground level:

  • A 30 minute protected route of escape with FD30S doors with self closing devices to all risk rooms that open onto the route of escape. Travel distance must not be excessive;
  • A mixed grade AFD is required, comprising an LD2 Grade A AFD with a control panel located on the inside wall adjacent to the exit door and including smoke detectors located throughout the route of escape plus:
  • where cooking facilities are located within the bedsits, there should be an interlinked Grade A heat detector in each bedsit and a non-interlinked Grade D smoke alarm in each bedsit.
  • where there are communal cooking facilities, not being within the bedsits, there should be an interlinked Grade A smoke detector in each bedsit and Grade A heat detectors in each communal kitchen;
  • Manual fire alarm;
  • A dedicated lighting circuit should be installed so that the use of any one switch/control anywhere along the route will illuminate the entire escape route;
  • Final exit and signage along the escape route if the escape is complex;
  • A fire blanket is required in each bedsit with cooking facilities and in any shared kitchen;
  • Emergency lighting is only required in the escape route where the escape route is long and complex or where there is no effective borrowed light;
  • If there is a basement see section 2.6 of this guide.
2.2.2 Category A HMO - two storey buildings

Where no floor level exceeds 4.5 metres above the ground level:

  • A 30 minute protected route of escape with FD30S doors with self closing devices to all risk rooms opening onto the route of escape. Travel distance must not be excessive. Note that a full 30 minute protected route is the ideal option. However, in a normal risk 2 storey HMO the provision of suitable escape windows from all bedsit rooms may be acceptable in lieu of a fully protected route (see the glossary for escape window requirements);
  • A mixed grade AFD system is required comprising an LD2 Grade D AFD with interlinked smoke detectors located throughout route of escape plus:
    • where cooking facilities are located within the bedsits, there should be an interlinked heat detector in each bedsit and a non-interlinked Grade D smoke alarm in each bedsit, or
    • where there are communal cooking facilities, not being within the bedsits, there should be interlinked smoke detectors in each bedsit and interlinked heat alarms in each communal kitchen;
  • A dedicated lighting circuit should be installed so that the use of any one switch/control anywhere along the route will illuminate the entire escape route;
  • Signage along the escape route if it is complex;
  • A fire blanket is required in each bedsit with cooking facilities and in any shared kitchen;
  • Emergency lighting is only required in the escape route where the escape route is long and complex or where there is no effective borrowed light;
  • If there is a basement see section 2.6 of this guide
2.3.1 Large shared (higher risk) HMO - three to four storey building
  • A 30 minute protected route of escape with FD30 doors (without smoke seals) with self closing devices to all risk rooms opening onto the route of escape. Travel distance must not be excessive;
  • Where exit from the property is possible in more than one direction at ground floor level via risk rooms (ie either the front or rear rooms) then FD30S doors between these ground floor rooms and the staircase will be required. Vision panels must be provided in these doors to allow tenants to identify the source of the fire and the appropriate route of escape;
  • LD2 Grade D1;
  • A dedicated lighting circuit should be installed so that the use of any one switch/control anywhere along the route will illuminate the entire escape route.
  • Signage along the escape route if it is complex;
  • A fire blanket in each shared kitchen is required;
  • Emergency lighting is only required in the escape route where the escape route is long and complex or where there is no effective borrowed light;
  • If there is a basement see section 2.6 of this guide
2.3.2 Medium sized shared (lower risk) HMO - three to four storey buildings

In order for a property to be classified as ‘lower risk’ the following features must be present:                                                                                          

  • Three storeys or less above ground level;
  • An occupancy of 6 or less people, who are able bodied and capable of using the means of escape without assistance; the occupiers do not present a higher risk due to factors such as limited mobility or alcohol/drug dependency;

And                                                                                          

  • Either a secondary alternative means of escape, for example a dedicated escape window at first floor in addition to the normal route of escape having sound, conventional construction (which for the purpose of ‘low risk’ cannot pass through a risk room)
  • or an enhanced fire detection system at the property - an LD2 Grade D AFD,

And                                                                                          

  • There is a minimal chance of a fire occurring and few, if any, highly combustible or flammable materials or other fuel for a fire

In ‘lower risk’ properties, meeting the above, the standard for a protected route may be relaxed. In such cases, the property must meet the following criteria:                                                                                          

  • Doors opening onto the escape route should be sound, solid construction, close-fitting, conventional doors (lightweight doors and doors with very thin panels should be avoided) and self closing;
  • an appropriate system of fire detection and warning is in place (LD2 Grade D1 as a minimum);
  • the stairs must lead directly to the final exit without passing through a risk room;
  • the staircase enclosure must be of sound, conventional construction throughout the route.

In addition:                                                                                          

  • A fire blanket in each shared kitchen is required;
  • Emergency lighting is only required in the escape route where the escape route is long and complex or where there is no effective borrowed light;
  • If there is a basement see section 2.6 of this guide
2.3.3 Small shared HMO - up to two storey buildings
  • There is no requirement for a full 30 minute protected route of escape, but the escape route should have traditional construction and not pass through risk rooms. There is no requirement for fire doors but sound, well constructed and close fitting conventional doors are required. Alternatively suitable escape windows can be provided from bedrooms and living rooms. Note that where construction standards are poor in the route of escape, travel distances are long or other high risk factors are present a 30 minute protected route of escape may be required;
  • LD2 Grade D1;
  • A fire blanket in each shared kitchen is required; and
  • If there is a basement see section 2.6 of this guide
2.4.1 Three to four storey buildings
  • There is no requirement for a full 30 minute protected route of escape but the escape route should have sound conventional construction not passing through risk rooms and travel distance should not be excessive. There is no requirement for fire doors but sound, well constructed and close fitting conventional doors are required. Note that where construction standards are poor in the route of escape, travel distances are long or other high risk factors are present a 30 minute protected route of escape may be required;
  • LD2 Grade D1 AFD;
  • A fire blanket in each kitchen is recommended, and
  • If there is a basement see section 2.6 of this guide
2.4.2 Up to two storey buildings
  • There is no requirement for a full 30 minute protected route of escape but the escape route should have sound conventional construction, not passing through risk rooms and travel distance should not be excessive. There is no requirement for fire doors but sound well constructed and close fitting conventional doors are required. Alternatively suitable escape windows can be provided from bedrooms and living rooms. Note that where construction standards are poor in the route of escape, travel distances are long or other high risk factors are present a 30 minute route of escape may be required;
  • LD2 Grade D1 AFD;
  • A fire blanket in each kitchen is recommended, and
  • If there is a basement see section 2.6 of this guide
    2.5.1 Two to three storey back-to-back (shared house up to 6 occupiers and single household)
    • A 30 minute protected route of escape at the first and second floor levels, with FD30 doors to risk rooms on those floors;
    • In all cases the door separating the ground to first floor should at least be FD30S. However in circumstances where the staircase from first to ground floor extends into the ground floor living room, then it may not be possible to fit a FD30S. In such cases it will be permissible to fit a fire door blank with intumescent strip and cold smoke seal. A self-closing device will not be required. It is recommended that a fixed glazed panel is fitted to this door in order to allow borrowed light onto the staircase and ensure safe access and egress;
    • In all cases the door to the kitchen should be at least FD30S. Where a kitchen and living room are open plan, then a fire door to the kitchen is not appropriate;
    • LD2 Grade D1;
    • An escape window at first floor level. Please see the Glossary for the requirements for escape windows. Note that where this requirement cannot be met, alternative arrangements may have to be made, by for example:
    1. constructing a 30 minute protected route of escape through the house to the final exit, or
    2. providing 60 minute fire separation between the ground and first floor levels, along with arrangements for calling the fire and rescue service (such as a fire alarm linked to the fire brigade or to a monitoring agency), or
    3. installing a domestic water suppression
    • A fire blanket in the kitchen is required;
    • Emergency lighting is only required in the escape route where the escape route is long and complex or where there is no effective borrowed light;
    • If there is a basement see section 2.6 of this guide;
    • Where an alternative scheme of fire safety measures is proposed, this may be accepted if it meets the relevant fire safety standards and with prior consent from the Housing Regulation Team.
      2.6.1 Habitable basements
      • Thirty minute fire separation between the basement and ground floor, including the staircase soffit and spandrel, with a self-closing FD30S door fitted at the head of the basement stairs. Note for single household or low risk shared houses (both of no more than two storeys) the existing construction such as lath and plaster or plasterboard can be accepted provided it is sound and in traditional Also existing doors to all risk rooms can be accepted where they are solid, in a sound condition and self–closing. Lightweight doors and doors with very thin panels should be avoided;
      • In very large occupied basements, two FD30S doors (one at the top and one at the bottom of the basement staircase) are required. This is to ensure that occupiers do not have to escape through a trapped layer of smoke and heat;
      • The route of escape from a basement habitable room should not pass through a risk room such as a living room or Ideally a separate exit to an ultimate place of safety is required at basement level. However, where this is not possible escape windows should be provided to all habitable rooms in the basement (see the glossary for escape window requirements). If escape windows cannot be provided then a 30 minute protected route is required, and
      • The AFD and warning system in the house should be extended to cover the It should be of the same grade and type as that required for the remainder of the house.
      2.6.2 Unoccupied basements/cellars

      Unoccupied basements and cellars are often used for storage and usually contain gas and electric meters and electrical wiring. As a result fire can spread quickly and attack the underside of the ground floor, thus compromising the escape route at ground floor level.                                                  

      • Thirty minute fire separation between the basement and the ground floor escape route, including the staircase soffit and spandrel, with a self-closing FD30S door fitted at the head of the basement stairs. Note for single household or low risk shared houses (both of no more than two storeys), where the basement is well maintained, the existing construction such as lath and plaster or plasterboard can be accepted provided it is sound and conventional. Also an existing door at the head of the basement stairs can be accepted provided it is solid, in a sound condition and self–closing. Lightweight doors or those with very thin panels should be avoided, and
        • There should be AFD coverage in the basement/cellar areas. It should be of the same level as that installed in the remainder of the Large multi-roomed cellars may require a number of detectors as appropriate. As a minimum there should be interlinked hard wired smoke alarms with integral battery backup in the circulation areas.