Annex 7: Mobility Scooter Guidance
Mobility vehicles are categorised under the Use of Invalid Carriages on the Highways Regulations 1988. Class 1 refers to manual wheelchairs that are not electrically propelled. Class 2 refers to powered wheelchairs and scooters intended for use on footpaths. Class 3 refers to powered scooters and invalid carriages intended for use on the road.
Class 3 vehicles are generally much larger, have a much wider turning circle and have potentially larger and heavier batteries, which are more difficult to remove for charging. This limits the options for internal storage, including within private dwellings. Even if this is possible, it may not be possible to proceed beyond the entrance hall, which may, in itself, present a risk to the individual resident as it blocks their means of escape if fire occurs within their flat. This removes the option for this type of scooter to be stored inside residents’ own accommodation, which is why Class 3 mobility scooters are often left outside flat entrance doors in common corridors and on escape routes, which can pose a significant risk.
It is possible for Class 2 scooters to pass through flat entrance doors. However, the risk to individual residents from storing and charging mobility scooters within their own accommodation needs to be considered.
BS EN 12184: 2014 applies to the manufacture of mobility scooters in the UK and Europe. The standard considers two specific aspects related to fire, namely the resistance to ignition and the risk of ignition from the power and control systems. The ignition resistance test is based on the simulated match test used for fire testing of upholstered furniture. The test for power and control systems is designed to reduce the risk from ignition of any part of a power and control system, including the battery charger.
Understanding the Risk
Mobility scooters are generally constructed around a steel frame, with plastic fairings, rubber tyres, foam seats, wiring and batteries. They are often retro fitted with vehicle registration number plates, waterproof covers and storage bags.
The type of batteries used in mobility scooters are generally lead acid (wet cell) or sealed lead acid scooter batteries. Other battery types include Gel and Absorbed Glass Mat (AGM) batteries.
The recent use of lithium iron phosphate (LiFeP04) batteries instead of lead acid batteries to power mobility scooters has increased risks due to their unpredictable and adverse reaction when subjected to fire. All batteries can give off hydrogen when charging.
Mobility scooters involved in a fire can release large volumes of smoke and generate significant heat outputs in a very short period of time. If mobility scooters are stored on escape routes and are involved in a fire, there is a likelihood that escape routes will become impassable due to smoke and heat, placing residents at significant risk. Therefore, appropriate measures must be considered within the building fire safety risk assessment to address the risks posed by the storage and charging of mobility scooters.
Mobility scooters that are stored externally are not always kept in a secured compound and can be at risk from deliberate ignition. This has allowed fire to spread through windows and doors, into buildings and internal compartments, and has led to fatalities.
Storage and Charging
There cannot be a ‘one size’ fits all approach taken to storing or charging mobility scooters. The layout and design of each building will be different; the type, number and location of mobility scooters will also differ and the needs of individual residents should be considered as part of the overall assessment of risk. The maximum numbers of mobility scooters for the premises should be identified by the fire safety risk assessment. Residents should be aware of local arrangements which will help to future proof mobility scooter storage issues in buildings. A solution that might be appropriate in one building may not be acceptable in another. Although external storage may be an option, the vulnerability and mobility of residents may make it impracticable for them to utilise external facilities.
The options detailed below offer a solutions based approach, based on a general hierarchy of risk. Any one of the options might be acceptable in the right circumstances. Where there is a reference to fire-resisting construction and fire-resisting doors, the period of fire resistance should normally be 60 minutes. If an area contains no more than three mobility scooters or is provided with automatic fire suppression, 30 minutes’ fire resistance will normally be adequate.
Option 1: External parking with charging facilities:
Mobility scooters may be parked outside premises. A charging facility is normally provided adjacent to the parking area. Security and the risk of fire-raising would need to be considered. The location of the parking space should not present a risk of fire spread into the building in the event of a fire.
Option 2: External storage with charging facilities:
This could be external storage with charging facilities which are:
- Purpose-built, including individual storage units.
- Converted external facilities, such as garages or storerooms.
Depending on their location and proximity to the building, such facilities may need to be fire-resisting enclosures and may also be fitted with automatic fire detection if they can be monitored.
Option 3: Purpose-built internal storage rooms:
Purpose-built rooms inside premises for the storage and charging of one or more mobility scooters might be an option. Rooms would need to be enclosed in fire-resisting construction, and be fitted with fire-resisting, self-closing doors and automatic fire detection.
Option 4: Adapted internal storage rooms:
Specially adapted rooms inside premises for the storage and charging of one or more mobility scooters might be an option. Rooms would, as a minimum, need to be enclosed in fire-resisting construction, and be fitted with fire-resisting, self-closing doors and automatic fire detection.
Option 5: Existing fire-resisting rooms utilised for storage:
The use of rooms which are not originally designed for this purpose but which are separated from the remainder of the premises with fire-resisting construction and self-closing fire doors, might be considered. This may include options to utilise storerooms, utility rooms, on a permanent or temporary basis. In these instances, the use of the rooms, or clearly separated areas, might need to be restricted to the storage and charging of mobility scooters and not combined with other uses.
Option 6: Storage and charging within residents’ own accommodation:
Suitable storage and charging arrangements might be possible inside residents’ accommodation. This option removes the risk from the common areas, and places the storage and charging of scooters within a fire-resisting enclosure beyond a fire-resisting, self-closing door. However, this potentially places individual residents at risk from a fire involving a mobility scooter in their own home. If this option is considered, the scooter should not be stored or charged in the private hallway, if this is the only means of escape available. The scooter should, preferably, be stored and charged in a separate room, which is fitted with a fire-resisting or substantial door and fire detection. Residents should be provided with advice on the safe use and charging of scooters as part of a person-centred approach.
Option 7: Internal storage in other areas:
If mobility scooters are stored in areas not mentioned above, they must be thoroughly fire risk assessed with the housing provider’s involvement. Compensatory factors to reduce risk could include:
- An automatic sprinkler or watermist system.
- A comprehensive fire detection and alarm system (which is automatically linked to an alarm receiving centre).
- Smoke ventilation (to keep flats smoke free).
- Alternative means of escape available from all flats that open directly onto the escape route in question.
- Scooters with limited flammability.
The appropriate combination of measures should be determined by the fire safety risk assessment for the premises.
The charging of scooters in dead end corridors and single stairway escape routes should not be permitted in any circumstances. Even where alternative means of escape is available, the storage, and particularly the charging, of mobility scooters in common corridors and escape routes is not generally recommended and all other alternatives should be considered.
Consent/Permissions and Insurance
No mobility scooters should be stored in premises where permission or consent has not been given or where policies or legislation is breached. Managers should also reserve the right to refuse storage where none of the options in this guidance are suitable and/or this would breach legislation or impact on the health, safety or welfare of other occupants within the premises.
Expectations should also be appropriately identified and supported within tenancy agreements and communicated to tenants.
Appropriate insurance cover should be in place by tenants that covers liability for damage or injury to others. Contents insurance alone is not sufficient to provide third party cover (should damage occur to the premises or to another person). Permission should not be given if appropriate insurance cover is not in place for the equipment being used.
Maintenance and Testing
Tenants should ensure that mobility scooters are maintained in line with manufacturer recommendations; this should include mobility scooter usage and charging. Those responsible for the premises should ensure that appropriate maintenance and testing regimes are in place to ensure designated storage areas are fit for purpose and offer effective fire protection, including:
- Fixed wiring installation testing.
- Portable appliance testing of equipment.
- Fire detection maintenance and testing.
- Fire doors and fire door furniture.
- Emergency lighting.
- Inspection of floors, walls or ceilings.
The above guidance includes information taken from the NFCC publication “Mobility Scooter Guidance for Residential Buildings” (2018). The full, unedited guidance can be found at https://www.nationalfirechiefs.org.uk
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