Practical fire safety for existing specialised housing and similar premises: guidance

Part 3: Ongoing Management Control

Chapter 6: Ongoing Management Control

Key Points

Arrangements for managing fire safety should include:

• Developing a fire policy and agreeing which person should take overall responsibility for fire safety.
• Providing staff training (where applicable) and fire safety awareness training to other agencies involved in the provision of housing or care services.
• Preparing fire procedures and making everyone aware of them.
• Managing the risk from building works, including adopting a ‘hot work’ permit system.
• Putting in place programmes for routine inspection, testing, servicing and maintenance of fire safety measures and systems.
• Monitoring the internal common areas and external areas through formal inspections, and as part of day-to-day activities by staff.
• Liaising with SFRS and encouraging residents to take up the offer of Home Safety Visits.

Introduction

397. Physical fire safety measures need to be managed and maintained to remain effective. 

398. Fire safety responsibilities may be shared between many organisations.  It is vital they co-operate with each other, share relevant information and co-ordinate the measures.  Where fire safety law applies, this is a legal requirement (see Part 4 of the Guidance).

Responsibilities for Fire Safety in the Building

399. Those responsible for fire safety include owners, landlords, managing agents, commissioners of care services (for example, local authorities) and care providers. 

400. In sheltered and extra care housing, landlords and others responsible for fire safety may have limited rights of access and control over the activities of tenants within their flat, and even less with owner occupiers. This is not likely to be the case in supported housing or small care homes.

401. There should be a documented fire safety policy for the building.  This should identify a named individual with overall responsibility and authority for fire safety to ensure that activities are coordinated and no key aspects of fire safety management are overlooked. 

402. The policy should also set out the roles and responsibilities of others who contribute to the management of fire safety. The more organisations that are involved, the more complex the situation.  There should be a formal agreement, documented in the form of a matrix, which clearly identifies the agreed responsibility for every key aspect of fire safety management.  The allocation of responsibilities may vary according to contracts and agreements e.g. between housing and care providers.  It is important that contracts include clear references to any delegated fire safety responsibilities (including responsibility for funding). A matrix template is provided in Annex 6.

403. The fire safety risk assessment should take account of this matrix and verify that the agreed arrangements are in place and working effectively.  

404. On-site staff will have a role to perform in the event of fire. They may also take responsibility for housekeeping matters and, in some cases, routine checking and testing of fire protection measures i.e. confirming that fire extinguishers are present, checking that fire doors operate effectively and weekly testing of the fire alarm system.

405. Regular and ongoing engagement with residents is equally important for fire safety (see Part 1 of the Guidance).

Instruction, Training and Information for Staff

406. Staff must be provided with instruction, training and information relating to the fire procedures and measures provided. 

407. For most employees, all that is required is basic fire safety awareness training. They should receive instruction upon appointment and refresher training at appropriate intervals.  This will ensure that they:

• Are aware of fire hazards that might occur -  in supported housing, where there is a right of access to residents’ accommodation, this extends to hazards in the residents’ accommodation.
• Know how to prevent fires.
• Recognise the importance of good housekeeping.
• Know when and how to use any fire extinguishers.
• Understand what to do if they discover a fire.
• Know how to escape from the premises if they encounter a fire.
• Are aware of how their actions might adversely affect the fire safety measures present in the building, for example, wedging open fire doors.
• Are able to identify and report obvious deficiencies in fire safety measures.

408. More extensive training will be required for staff with a specific role to play in responding to alarm signals. They should know the emergency plan, understand the evacuation strategy and be able to interpret and, where appropriate, operate the fire alarm panel.

409. Additional training may also be required for staff who undertake fire safety inspections. Risk assessors and reviewers will need appropriate training to ensure competence.

Emergency Plan

410. There should be a suitable Emergency Plan for the premises. This is sometime known as the Fire Procedure or Emergency Fire Action Plan.

411. In supported housing, the Emergency Plan will be a simple fire evacuation procedure.  There should be a Personal Emergency Evacuation Plan (‘PEEP’) for residents in supported housing who need assistance with evacuation. The minimum number of staff that must be available in case of fire should be determined.  Interim measures will need to be put in place whenever there is a staffing shortfall.

412. In sheltered and extra care housing, staff will not always be present to respond to alarm signals or assist residents.  If staff do have a role, this needs to be clearly defined in the Emergency Plan.  The risk of entering a flat where there is a fire needs to be considered.  

413. Residents’ support needs are usually assessed when they take up occupation and should be kept under review.  This should include their ability to escape unaided in a fire. 

414. In sheltered and extra care schemes, SFRS may have to rescue residents that cannot escape by themselves. Information relating to particularly vulnerable residents should be available to SFRS on arrival by keeping it in a ‘premises information box’ at the main entrance.  This should be accessible to SFRS or unlocked remotely by a Telecare alarm receiving centre. Details of residents using medical gases should also be included.  A plan should be provided next to the fire alarm control panel, showing the locations of residents who need assistance to evacuate (for example, by using red stick-on dots).  Such information must be kept up to date.

415. In larger schemes, plans detailing the layout of the building and its services should be included in the “premises information box” for SFRS.

416. Fire action notices are not normally necessary in supported housing, but should be provided in sheltered and extra care housing (see Annex 2). Notices should be relevant to the specific building.  It is good practice to place them where they will be viewed routinely by people entering the building, such as by the main entrance or inside a lift.

417. In most specialised housing, there will be a communal fire alarm system.  The fire action notice should reflect this and clearly state the action to be taken on hearing the alarm.

418. Contact details should be available by the fire alarm panel so that residents can arrange for the system to be silenced and reset as quickly as possible in the event of a false alarm.  A prolonged delay could result in residents attempting to silence or re-set the system themselves.

Fire Drills

419. It is neither practical nor necessary to carry out drills in most sheltered and extra care housing. Discussing a pre-planned scenario with residents can be a good way to check they understand what they should do in the event of a fire.

420. In larger housing complexes with extensive communal amenities, such as hairdressers, cafeterias and shops, fire drills may be necessary. These will only apply to people present in the common areas. Residents in flats would not be expected to take part.

421. In supported housing, fire drills can be useful and should be considered as part of the fire safety risk assessment.  They reinforce the Emergency Plan for staff and give an indication of the likely evacuation time.  Some residents may also benefit from practicing the evacuation procedure.  They are also useful learning opportunities and can highlight:

• Any shortcomings in the emergency plan.
• The need for further staff training.
• Any challenges with assisted evacuation.
• Changes to residents capabilities and the need to review their PEEPs.

Controlling Building Work and Alterations

422. Building Regulation approval should be obtained where relevant.

423. Building works can create new hazards or impair existing fire safety measures and can often be the cause of fire.

424. Those undertaking building works must implement appropriate fire precautions.  Contracts may include requirements and method statements and these should be available for scrutiny.  Inspections should take place during the course of the works. This should happen for all building works, not just major projects.  

425. ‘Hot work’ is a particular risk. It is vital that control is exercised by adopting a ‘permit to work’ system.  This places obligations on those carrying out the work to inspect the areas in which work is taking place, both before and after the work, and to take all necessary precautions, including provision of accessible fire extinguishers. 

426. Contractors should be made aware of lines of fire separation and other fire resisting enclosures in the building, so that any breaches to walls or floors (for example, for pipes or ducts) can be appropriately fire stopped. Following the work, checks should be made to ensure that the original fire resistance is restored.  

427. Examples of new hazards or impairments to existing fire safety measures that can arise from building works include:

• Making holes in separating walls and floors.
• Removing stairway doors to allow free access for delivering materials
• Parking over fire hydrants.
• Placing site huts/waste skips too close to the building.
• Leaving gas cylinders inside the building overnight to avoid having to store them properly away from the building.
• Blocking access to a rising fire main inlet.
• Opening up parts of the structure without providing suitable fire-resisting hoarding to separate work areas from occupied areas.
• Blocking exit routes.
• Leaving combustible building materials and waste in common parts.
• Wedging of fire doors.
• Disablement of fire detection / covering of detectors.

428. Further advice on fire safety during construction work is available from the HSE (HSG168 Fire Safety in Construction) and the Fire Protection Association (Fire Prevention on Construction Sites).

429. Tenancy agreements should restrict the works that tenants can undertake without permission. Examples of alterations which could be detrimental to fire safety include:

• Replacing a flat entrance door with one that is not fire-resisting and self-closing.
• Installing a new bathroom suite, but not ensuring that breaches of riser walls created for new drains are fire-stopped afterwards to maintain fire separation to the common riser.
• Removing the doors and walls to the kitchen and lounge to create an open plan living area, but in so doing making all the bedrooms inner rooms, and possibly impairing protection to the common parts.
• Installing new gas supplies to flats and creating ventilation to gas meters with unprotected openings into common corridors and stairways.
• Adding a pitched roof to a flat roofed block without providing suitable cavity barriers.
• Fitting non-condensing tumble dryers with holes through fire walls and doors for vent pipes.
• Replacing smoke vent windows with sealed units
• Installing a new false ceiling without transfer grilles to allow smoke to reach existing permanent vents
• Fitting rain screen cladding to an existing block of sheltered or extra care housing without considering the potential for a fire from a flat to travel upwards through the cavity behind the cladding to spread into the flats above
• Installing downlighters which are not ‘fire-rated’, have no intumescent fire hoods or an insulation support box, thereby diminishing the fire resistance of the ceiling.
• Damaging the protection to the timber frame construction by installing additional electrical sockets.

Inspection, Testing and Maintenance of Fire Safety Systems and Equipment

430. Fire safety systems and equipment need to be maintained in effective working order.  There must be arrangements for routine inspection, testing, servicing and maintenance.

431. The maintenance and testing of some systems and equipment fall within the recommendations of British Standards. Frequencies for testing and maintenance should be followed where possible although minor deviations may be appropriate for reasons of practicality and should be based on an assessment of risk.

432. Some of the inspection and testing may be carried out by competent in-house staff.  Other work should be carried out by competent contractors.  Third party certification and approval schemes provide confidence that listed companies have been assessed against recognised standards.

433. Where systems are tested by in-house staff or other non-specialists, call-out arrangements will be required to repair any deficiencies.

434. The following guidance outlines the basic requirements for routine inspection, testing and maintenance of fire safety systems. See Annex 8 for summary table.

Emergency escape lighting

435. Emergency lighting should be tested as follows (unless self-testing):

• A monthly functional test using a suitable test facility to check that the fitting has not failed. This simple test can easily be undertaken in-house.
• A full duration discharge test once a year to confirm that the batteries are still capable of supplying the fitting for its duration. (Care should be taken not to leave a building entirely without escape lighting while batteries recharge after a test).

436. Further guidance on testing and servicing emergency escape lighting systems can be found in BS 5266-8.

Smoke ventilation

437. AOVs and electrically operated OVs should be tested once a month for correct operation using the manual controls provided. Windows and other non-electrical means provided for venting smoke should be operated at least once a year. These are simple tests that can be undertaken by non-specialists.

438. Testing and maintenance of the interface between smoke detectors and the controls associated with AOVs should take place at least twice a year, and in accordance with the manufacturer’s instructions. Further guidance can be found in BS 7273-6.

439. Other systems of smoke control, including smoke extract systems and pressurisation systems, should be tested and serviced periodically in accordance with the manufacturer’s instructions. This will normally be at least annually, but may involve monthly or more frequent functional tests where the systems are intended to protect the means of escape. It is important that those servicing such systems are familiar with the performance parameters used in the design of the system.

440. Further guidance on testing and servicing of smoke control systems can be found in BS 9999.

Fire extinguishing appliances

441. Fire extinguishers and fire blankets should be inspected and maintained every 12 months. This is a task for suitably trained specialists. 

442. Staff should look out for missing or damaged equipment as part of normal walk-rounds or formal fire safety inspections.  Defects should be reported. A simple visual check of fire extinguishers should be carried out monthly.

443. Further guidance on inspection and maintenance of fire extinguishing appliances can be found in BS 5306-3.

Fire detection and alarm systems

444. Where relevant, alarm receiving centres (ARC) should be warned before carrying out the test.  They should be contacted again after the test to ensure that the signal was received correctly.

445. A different manual call point should be tested each week. This can be carried out by non-specialists. Swing-free arms, electromagnetic door holders and other interlinked devices should be checked to ensure they operate correctly.

446. Where remote monitoring is in place, transmission from a resident’s flat should also be tested. A different flat should be tested each week so that, over a period of time, all residents’ systems are tested.

447. Periodic servicing should be undertaken at least once every six months.  Further guidance on testing and servicing of fire alarm systems can be found in BS 5839-1.

Smoke and heat alarms

448. Smoke and heat alarms should be tested preferably weekly but at least every month, using the test button or remote test switch. Many residents will be able to carry out this test themselves.  Alternatively, contractors may undertake this as a value-added service during a routine repair or annual safety check.

449. Anyone engaging with residents in sheltered or extra care housing could carry out a quick visual check to ensure alarms are not damaged or batteries removed.  

450. Further guidance on testing smoke alarms can be found in BS 5839-6. Alarms should be replaced at the end of their lifespan in line with manufacturer’s recommendations.

Fire dampers

451. Fire dampers should inspected and tested at least once every two years for those operated by fusible links and every year for those that are spring operated. Guidance on testing of fire dampers can be found in BS 9999.

Automatic fire suppression systems

452. Domestic/residential sprinkler and watermist systems should be maintained annually. Further guidance on maintenance of sprinkler systems can be found in BS 9251.  Sprinkler systems installed in accordance with BS EN 12845 should be subject to a weekly test and quarterly maintenance in line with that standard. Further guidance on testing and servicing of watermist systems can be found in BS 8458. 

Rising fire mains

453. Rising fire mains should be inspected every 6 months.  Outlets should be checked for damage and padlocks and straps on landing valves should be in place. This could be carried out in-house. The rising main should be subject to an annual pressure test which will require a specialist contractor. Further guidance can be found in BS 9990.

Firefighters lifts

454. Firefighters lifts should be subject to monthly inspections and annual testing and maintenance. More information can be found in BS EN 81-72.

Fire-resisting doors

455. Fire-resisting doorsets (including flat entrance doors) should be inspected every six months to identify defects such as:

• Missing or ineffective self-closing devices.
• Damaged or missing intumescent strips and smoke seals.
• Damaged doors or frames.
• Poorly fitting doors caused by distortion, shrinkage, or wear and tear.
• Newly fitted, inappropriate, door furniture.
• Doors that have been replaced using non-fire-resisting types.

456. Staff can be trained to identify these defects and remedial action should be taken as soon as possible.  Checks of flat entrance doors could be combined with routine repairs or annual gas safety checks.

457. Further advice on routine inspection and maintenance of fire-resisting doors can be found in BS 8214.

Fire-resisting construction

458. Damage to walls or signs of unauthorised work are likely to be obvious in common corridors, lobbies and stairways. Fire safety checks should also include areas such as riser cupboards and plant rooms.

459. When flats become vacant or change tenancy, the condition of fire-resisting construction should also be inspected.

460. Separating walls should be checked annually where the fire strategy relies on fire separation within roof voids (for example, in sheltered and extra care housing). Checks should be made during fire safety risk assessments but more comprehensive inspections may need to be carried out, particularly following works affecting the roof space. For example, new penetrations in separating walls should be checked to ensure they are properly fire stopped. 

External escape routes

461. The use of external stairways should be avoided owing to the age and vulnerability of the residents. If provided for staff use, they should be subject to periodic inspection which includes visual checks for:

• Evidence of damage or corrosion.
• Build-up of moss or other slip hazards.
• Trip hazards or obstructions on the stairway.

462. A structural integrity survey is required every 3 years by a specialist.

Checking Fire Safety Standards

463. Formal inspections can identify fire safety shortcomings but many routine activities also provide useful opportunities to monitor fire safety in the common areas. The standard of fire safety can be improved by encouraging staff and others to be fire safety aware. 

464. The extent of formal inspections will depend on how well standards are being maintained.  Inspectors should also be alert to new hazards, for example, the use of extension leads to charge a mobility scooter brought in by a visitor.  Inspection checklists should at least cover the following:

• Monitor housekeeping in common areas and check policy is being followed.
• Doors to residents’ store rooms, electrical cupboards, plant rooms, bin stores and other ancillary rooms are secure and not being left or held open.
• Front doors and other entrance and exit doors are closing properly.
• Fire extinguishing appliances are not missing, discharged or damaged, if provided.
• There are no signs of damage to fire-resisting walls, doors and glazing.
• Smoke control vents have not been tampered with or obstructed.
• Fire exit signs (if fitted) or fire action notices are not missing or defaced.
• Fire detectors, call points and sounders are still in place and have not been damaged, covered over or interfered with.
• Rising fire main outlets are not damaged or obstructed.
• Permanently illuminated (maintained) emergency lights/signage are working normally.

Records

465. Records of fire safety risk assessments should be kept.  It is also good practice to keep records of:

• The fire safety policy (fire safety management arrangements). 
• Staff training and drills, where appropriate. 
• Inspection, testing and maintenance of fire safety measures. 

466. Records can provide evidence of good management. Where fire safety law applies, Enforcement Officers from SFRS will want to review records as part of their fire safety audit.

467. In larger schemes, a fire safety manual should contain a record of the fire safety arrangements.  Guidance on the content can be found in BS 9999.

Upgrading Fire Safety Measures

468. Alterations and improvements can provide an opportunity to upgrade fire safety measures. For example, when lift replacement becomes necessary, upgrading to evacuation lift standard will significantly improve the ability to evacuate mobility impaired residents.  

Liaising with SFRS

469. SFRS may visit premises to obtain information so that operational crews can become familiar with the features of the building, including access, availability of water for firefighting, and firefighting facilities such as firefighters lifts and rising fire mains. They may also check on legal obligations to maintain the property and facilities for firefighter use or safety.  

470. Supported housing is unlikely to receive such a visit. Sheltered and extra care schemes may be visited although this is a matter for SFRS.

471. Home safety visits are a key component of SFRS’s community safety engagement work. Housing providers and agents should inform residents of this service and make a referral to SFRS if they have concerns. Details on how to do this are found at https://www.firescotland.gov.uk/your-safety/for-householders/home-fire-safety-visit.aspx

472. Some premises, for example, care homes and some supported housing may be subject to a fire safety audit to check compliance with fire safety law.