In 2019 I had a professional fire risk assessment carried out for my Guest House by an ex fire officer. At the time he said we should decommission the fire escape (as its unsafe), provided we upgraded the ceilings in the basement to 2 hours compartmentation, updated the basement doors to half hour fire doors, carry out additional staff training and put a fire escape plan on the back of the bedroom doors as this would reduce the risk and extend the travel distance from 18 meters. 2 weeks later the local authority fire officer visited us and said we should carry out the work noted in the fire risk assessment which we did.

About 2 weeks ago we had a visit from a different fire officer to carry out an audit of the fire risk assessment. The fire officer disagreed with his colleague and the risk assessor. He measured the travel distance to be 21 to 22 meters from the furthest point on the top floor of the building. He doesn’t think there is any flexibility in the 18 meter rule and is talking about issuing a prohibition notice so we can’t use the top floor of the building.

The property comprises of a basement, ground, first and second floor. The Guest House accommodates 21 guests and has L2 Fire alarm system in place with sounders in every room. Half hour fire doors are in place to all rooms apart from the boiler room that has a 1 hour door and the en-suite bathrooms that are standard doors.

We have a 5 year periodic electrical assessment certificate for the hard wiring, a fire alarm and emergency lighting certificate, the firefighting equipment (extinguishers and fire blanket) is tested every 12 months and a gas certificate every 12 months. There is an emergency escape plan in place and a Personal Emergency Evacuation Plan. We do a fire drill every 6 months.

I have read through the sleeping accommodation guide book at great length and it does say where the risk can be reduced the travel distances can be extended but there is nothing definitive in there that I could go back to the fire officer with. The book does say were a fire alarm is in place the travel distance can be extended but he disagrees as he said guest houses need to have a fire alarm.

I have also read Part B of the building regulations for ‘buildings other than dwellings’ and can see anything about extended travel distances in that. I have read articles about about BS 9999 which seems to be a little more helpful, in that it talks about increasing the travel distance by 15% where a fire alarm is in place but I am not sure if it applies to me as I can’t read the document in full.

I have spoken to the professional who produced the fire risk assessment since the last fire officer visit but he has advised asking to speak to a superior or getting a solicitor involved (which will probably be expensive).

I would like to know is the fire officer being reasonable in asking us to reinstate the external fire escape? If you think he is can anyone point me in the direction of a good source of supporting information so I can maybe change his mind or his superior. Are there any other steps we can take to reduce the risk (I know its probably difficult to say just by reading a few paragraphs).

Reinstating the fire escape is going to cost a lot of money and after the last few years of trading during covid its not the best timing.

Thank you

redman22

I recommend looking in the building regulations 2010 fire safety approved document B free to download from HM Government or do a quick search using an internet search engine.

This gives you all the information in an easy to read format that you will require.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/422192/9281_Sleeping_Accomodation_v2.pdf

Travel distance page 70

There may be something helpful in this document.

Chris

Hi Redman

I am out of my comfort zone as to the technical bit of your question and defer to the sound advice you have been given.

So, my advice [partly based on my former experience as an HSE Inspector] is only about you facing that "Notice" and due process.

You need to read the specific legislation under which any notice is served along with whatever official guidance is available, but be prepared to challenge the officer serving it and if they cannot come up with convincing arguments as to the merits of the notice, be prepared to appeal against the Notice.

As an HSE Inspector I was taught to make sure that I had the evidence to rebut any appeal!

In 12 years I only faced one appeal against however Prohibition and Improvement notices I served (Haven't a clue how many but it was in the 100s, probably more than a thousand) - I was surprised but the recipient had thought that he was supposed to fill in the appeal form I had provided - they had every intention of complying and once I explained that it wasn't mandatory to appeal, they withdrew the appeal.

In contrast, some years later an HSE Inspector didn't collect the evidence to rebut an appeal and served us with two Improvement Notices which we duly appealed. After a four hour meeting, the Inspector was instructed by a superior to withdraw the Notices. [Not going to go into the detail but it was 99% certain that our appeals would have been successful]

So, the moral of the story is that enforcing authority officers are not infallible. Just because they tell you to do something doesn't necessarily mean that they are right. If they tell you to reinstate a fire escape that has been condemned as being not structurally sound, to do so could be deadly.

P

I only have experience of new builds where the mitigation measure to extend the travel distance can be technical and complex, and has been tighten up post Grenfell. Trying to understand all the guidance documents, British Standards, PAS , Building Regs etc. is a formidable task. I know enough to know to leave it to the experts.

From experience, again only new build, a protected staircase that is considered a place of safety as part of the mitigation travel distance is not a staircase offering 30/60 protection but some more like a concrete/masonry shell, with AOV, emergency lighting, 120 fire doors off a hall with no access to the rooms.

You could consider taking action against the original fire risk assessor for flawed advice. Some fire risk assessors do not have the competence to propose mitigation strategies.

Reinstalling the fire escape may be your best option, alternatively consult fire engineer, which will come at a cost and are like hen’s teeth post Grenfell. However their recommendation may not be good news and include items like fire sprinkler, smoke extraction, fire alarm system etc.

I think your answer is in your first paragraph.  You had a FRA carried out that was checked by a local authority fire officer who agreed with the FRA and told you to have the recommened work done.

As far as I am concerned this was enough and just because a different fire officer comes along with different views should not mean you should do what they say.

Good luck.