(i) General Questions on Guidance
1. Is Fire Safety Guidance for Specialised Housing required in your view?
Nearly all (37 of 38) respondents confirmed that the Fire Safety Guidance for Specialised Housing is required. Further qualifying comments confirmed that there is a need for enhanced fire safety measures for Specialised Housing, particularly due to the vulnerability of residents and an ageing population.
2. Is the purpose of the Fire Safety Guidance for Specialised Housing clear?
The majority (33/38) of respondents felt that the purpose of the Guidance was clear. Nevertheless, a few commented on the clarity of paragraph 9 (application of the Guidance to small care homes) and 28 (simultaneous evacuation strategy for shared group homes). An individual and a housing association queried the applicability of the Guidance to Specialised Housing where children reside. This included comments about children's care homes not being mentioned in the definitions (paragraph 9) or Glossary.
Another housing association suggested that the responsibilities of "duty holders" should be further defined, with regard to 'Care at home', lease agreements and tenancy agreements. The information provided in the Glossary was generally welcomed, with a joint response suggesting an additional Appendix with more detail on different types of Specialised Housing. Similarly, a joint response from three Consultants/contractors carrying out fire safety risk assessments recommended placing the Glossary earlier in the document to make reading and understanding the Guidance easier. In addition, one local authority suggested that the types of housing in scope of the Guidance could be more clearly presented by using graphics and charts.
3. Is it clear who should use the Guidance?
The majority of respondents (29 out of 38) answered "yes". This included five local authority housing providers who confirmed that the intended audience was clearly defined.
Fourteen advice agencies confirmed that the Guidance is mainly clear on who should use it. It was suggested that reference be made to the potential role of personal assistants under self-directed support, social care providers and other enforcing authorities. The agency answering 'no' suggested including all relevant responsibilities for each group in paragraph 22
While the majority were clear on who the Guidance was aimed at, three local authorities felt the division of responsibilities between parties could be made clearer. In contrast, four of five housing associations confirmed that the Guidance was clear on this.
Other comments included:
a) One local authority housing provider suggested adding a clear statement that housing providers are responsible for premises based fire safety risk assessments and care and support providers are responsible for person-centred assessments.
b) Another local authority requested clarification on who should take the lead in completing a person-centred risk assessment.
c) One housing association asked to what extent the Guidance applies to amenity housing (which is included in the definition of Sheltered Housing in the Glossary section of the Guidance).
d) One care and support provider felt that the person-centred risk assessment may lead to confusion and prompt housing providers to carry out assessments for every tenant and that the housing provider is responsible for evacuation. The other care and support provider objected to one of the key points in Chapter, which states that: "Fire safety design of supported housing is usually based on the same principles as dwelling houses". The care provider insisted that this does not apply to residential child care homes.