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#1 Posted : 05 January 2022 16:14:58(UTC)
Rank: New forum user

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

A Kurdziel  
#2 Posted : 05 January 2022 16:39:15(UTC)
Rank: Super forum user
A Kurdziel

Ask him where the 18 m rule comes from: I can't  remember it being in the RFFSSO, which is the law. They should also explain why they think this extra 3 metre travel distance poses a “severe”  risk to residents entailing a possible prohibition notice.

John Elder  
#3 Posted : 05 January 2022 16:55:03(UTC)
Rank: Forum user
John Elder


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.

#4 Posted : 05 January 2022 16:59:54(UTC)
Rank: Forum user

I used to be a Fire Service Inspecting Officer and in my Brigade, what you describe is nowhere near the threshold for a Prohibition Notice. It would need a risk of fire (poor compartmentation, dodgy and untested electrics) as well as an excessive travel distance.

On its own, an extra 3 metre travel distance on top of the arbitary 18m travel distance in the guides would not be sufficient for an Article 31 prohibition. I would have to justify getting a very senior officer off the golf course or probably out of the 19th hole and an extra 3m TD is not enough

Fire safety is all about time. Detecting the fire as early as possible by fire detection, holding the fire back by compartmentation, providing safe escape routes in which peole can escape quickly by providing emergency lighting and restricting travel distances. 

How long would it reasonably take an 'average' person to travel that extra 3m (under 10ft!!)? The provision of a new escape route would be disproportionate 

Is your single staircase a 'protected route'?

That is,

1) Is it fitted with fire detection and manual call points? (please say yes if its L2)

2) Are there FD30 fire doors with self closing devices onto the staircase? Are the walls around the staircase 30min fire resisting 

3) Are there very few ignition sources? Perhaps limited to socket outlets, lighting and EL only?

4) Are combusitible items limited in the staircase? No sofas, bookcases, or reception areas (with or without a PC)?

If so, you have created a place of limited combustion - a protected route. Travel distances are measured to the protected route and not to the final exit. Is this less than 20m???

More on travel distances here

According to ADB 'travel distance' is:

'The distance that a person would travel from any point within the floor area to the nearest storey exit, determined by the layout of walls, partitions and fittings.

Where a storey exit is a final exit, or a doorway that gives direct access into a protected stairway firefighting lobby or external escape route 

More on protected routes here


Please take into account, the post I have written has been compiled from details in your post and without sight of the premises, plans or any further information. So tread carefully and get your fire risk assessor to justfy his FRA rather than leaving it to you to consult a solicitor. That sounds like a very cowardly action

thanks 3 users thanked Messey for this useful post.
redman22 on 05/01/2022(UTC), peter gotch on 05/01/2022(UTC), A Kurdziel on 06/01/2022(UTC)
#5 Posted : 05 January 2022 17:11:20(UTC)
Rank: Super forum user


Travel distance page 70

There may be something helpful in this document.


thanks 2 users thanked chris42 for this useful post.
redman22 on 05/01/2022(UTC), peter gotch on 05/01/2022(UTC)
#6 Posted : 05 January 2022 17:52:27(UTC)
Rank: New forum user

Thank you for all the feedback. 


Thank you for the Sleeping Accommodation Guide Book link. I have a hard copy of this book and I have had a good read of it. Page 20 of the book states a flexible approach need to be taken when applying the rules which is the basis of my argument in extending the 18 meter rule.

I have also looked into Building Regulations Approved Document B and the travel distance states 18 meters but dosn't suggest measures can be put in place to compensate for the extended travel distance. 


The property is fitted with detectors and sounders in all rooms apart from en suite bathrooms. 

All of the doors are 30 min fire doors fitted with self closers appart from the boiler room which is a 1 hour fire door. All walls are half hour minimum with some 1 hour. While the stair ways are protected they are not lobbied (you don't have 2 fire doors between each bedroom protecting the escape route). 

The hall, stairs and landing are very limited in the way of flamible material. The carpet is 80% wool and I am quite sure this means its has fire resisting properties. There are no chairs or soft furnishings, its quie clinical.

Thank you

peter gotch  
#7 Posted : 06 January 2022 12:00:33(UTC)
Rank: Super forum user
peter gotch

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.


thanks 2 users thanked peter gotch for this useful post.
A Kurdziel on 06/01/2022(UTC), redman22 on 06/01/2022(UTC)
#8 Posted : 06 January 2022 12:10:31(UTC)
Rank: New forum user

Thanks Peter Gotch

I appreciate your response. 

If I appeal the prohibition notice I am concerned that I could be liable for the Frie Service legal costs if I loose. This would likely cost alot more than the costs to repair and reinstate the fire escape. 

#9 Posted : 06 January 2022 13:30:05(UTC)
Rank: Super forum user

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.

thanks 1 user thanked Alfasev for this useful post.
redman22 on 06/01/2022(UTC)
peter gotch  
#10 Posted : 06 January 2022 15:31:31(UTC)
Rank: Super forum user
peter gotch

Redman - fully understood, but it doesn't stop you challenging this officer BEFORE they serve the Notice and then looking very carefully at its wording IF they are brave enough to serve it whilst also having the context of your risk assessment from another fire professional (who may or may not have been competent to do the assessment) and the guidance to which others have referred.

Whilst it is usually impossible to see the full story when you read about enforcement action, I see narratives more often than before where I think "why did they not appeal that Notice" or "why did they not go to trial in that Prosecution" but I fully understand that there are often multiple reasons not to, even where the enforcement action lacks merit.

Usually - I have been the Defence Expert in two HSE prosecutions that went to "Newton Hearings" which are essentially mini trials to look at HOW guilty the defendant is on a scale of only just through to very badly. The subsequent HSE press releases entirely ignored most of what was agreed in a Joint Experts' Report to make it sound like a minor offence was heinous!!

thanks 1 user thanked peter gotch for this useful post.
redman22 on 06/01/2022(UTC)
#11 Posted : 09 January 2022 19:45:30(UTC)
Rank: Super forum user

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.

thanks 2 users thanked firesafety101 for this useful post.
A Kurdziel on 10/01/2022(UTC), peter gotch on 10/01/2022(UTC)
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