This article is relevant to some of the projects we undertake. The content is courtesy of (and copyright of) HMO Daddy. See link to their excellent website at the end of the article.
I have, for a long time wrestled with the point of the fire safety precautions e.g. fire doors, fire alarms etc., required by the Local Authority Housing Standard Departments (HSD) for Houses in Multiple Occupation (HMOs). Apart from blatant risks , namely, leaving cans of petrol in the hall and the insignificant costs such as fitting stand alone battery operated smoke detectors (which the Fire Service are giving them away free of charge or can be purchased for as little as £2.50p each). I would also ban chip pans and smoking; as, if you believe the statistics, over half of fires in HMOs are caused by chip pans and most fire deaths are caused by smokers.
My issue is I cannot find any evidence of the effectiveness of the fire precautions imposed by HSDs.
If you apply a rational evidence based approach, where is the evidence that shows that the fire precautions HSDs impose on HMO landlords have any effect? Nowhere can you find statistics to show that more deaths are caused in unprotected HMOs than protected HMOs. I once spoke to an HSD officer who told me he estimated that 90% of HMOs in their area were unknown to him – if they are unknown, how they could estimate this – I don’t know. When I asked him about all the fire deaths and injuries which resulted from these presumably unprotected HMOs, he could not answer. He could not identify one death in an unprotected HMO; though there had been a number of deaths in HMOs in his area which had fire precautions and yet, strangely enough, this was the reason that this authority aggressively enforced fire standards. I am still trying to understand that logic.
We are not talking about small costs involved in fitting the fire precautions required by HSDs; from experience I find it costs between £5k to £10k, depending on the property and your ability to source reasonably priced tradesmen to bring an average 6 bed HMO up to the standard HSDs require. This is not an insignificant amount and I believe should have demonstrable benefits before being imposed.
Neither am I talking about very large HMOs, such as hotel size properties or HMOs which house high risk occupants since the dynamics are very different with these types of properties; I am talking about house shares or up to 6 room properties let to professionals, working people or those who are capable of working.
HSDs will often say it is the law that stipulates that HMOs have fire precautions – but is this true? There are 3 pieces of legislation which I can find governing this area:
1. The Licensing and Management of Houses in Multiple Occupation and other Houses (Miscellaneous Provisions) (England) SI 2006 no 373 schedule 3 Paragraph (5) states that a licensed HMO (generally, this is a property which has 3 or more storeys let to 5 or more occupants who share facilities such as a bathroom or kitchen) must have:
‘Appropriate fire protection facilities and equipment must be provided of such type, number and location as it is considered necessary’
2. The Housing Health and Safety Rating System (HHSRS) which requires an evidence based assessment to be made of the risk to occupants including the risk from fire and action taken to reduce this risk.
3. The Regulatory Reform Order 2005 which requires a fire risk assessment to be made of the common parts of HMOs and presumably the risk identified acted upon.
All this legislation is very vague and nowhere does it state you must have fire doors on all rooms and a Level 1 Grade A fire alarm (fire alarm with control panel) these being the most expensive items which are generally required in HMO properties. I have not included emergency lighting as it is relatively cheap to install, though I think it is pointless as the odds of a fire and a power failure are remote and the tenants who live in the property will be familiar with the layout of their home so do not need emergency lighting to find the exit should there be a power failure.
It gets even better (or worse) let’s examine what these expensive pieces of kit do. A fire door will, if properly fitted and closed, stop a fire breaking through the door for 30 minutes and prevent smoke spreading through the door jams. Very good, but an ordinary solid door will stop a fire for a good 20 minutes and prevent most of the smoke from spreading – providing it is shut. Many fire officers have told me that with an average house fire you are either dead or out of the property within 10 minutes!
I am told the statistics show that most fire deaths in HMOs are the result of tenants, usually drunk, falling asleep while smoking. The fire door does not protect them, it may protect the other occupants from the spread of fire but for the occupant it is nothing more than a lid to their coffin. An ordinary door can pretty well do the same job and has the possible added benefit of allowing smoke to leak around it which along with the smoke detectors activating; warn the other tenants of the fire and possibly saving the poor tenant in the room from suffocation.
The effectiveness of a fire door in preventing the spread of fire and damage to the rest of the property is remarkable, as I have seen, a room can be totally destroyed by fire yet on the other side of the fire door there is no damage at all. However, an ordinary door does a reasonable job as well, if closed. Fire doors also offer much better sound insulation and are more robust. Most HMO landlords I know including myself say, ‘If you fit a door fit a fire door’. A fire door only costs about £20 but the cost alone is not an argument for making us fit fire doors.
The problem with retro fitting fire doors is the cost of fitting them, they need special door frames or existing frames need adapting; the amount of work involved in fitting them in an old house along with the door furniture can run to hundreds of pounds. The major disadvantage of fire doors, apart from their cost, is that they are inconvenient for the tenants. They are heavy and, if door closures are fitted, can be noisy when they close. Fire doors covering communal areas such as lounges and kitchens are usually propped open. The overhead door closures are often removed by the tenants. Such is the problem with door closures that a recent review of Building Standards suggested that door closures should no longer be required as they are so misused making them practically useless – this was not implemented.
All in all, I do not believe that fire doors do much to stop fire deaths which is their main purpose. It could be argued that they actually contribute to fire deaths in preventing the early detection of the source of the fire but I have no evidence to support this.
The next piece of expensive kit required is a fire alarm system. For some HMOs, depending on the whim of your Housing Standards Department, it needs to be a Level 1 Grade A system which has a fire panel by the front door, requires a professional installer to install and has to have a bi-annual service by a qualified engineer – the cost of which is not insignificant. It has no more benefits, in the event of a fire, than a much cheaper system costing one tenth of the price; it makes a noise when it detects a fire but is no better at detecting a fire than the cheaper versions!
So what is the benefit of having the expensive fire detection system? As I said at the beginning I would not argue against having some fire detection system, such as self contained battery operated smoke detectors (even better if they are wired into the mains – as the batteries get removed), as it clearly does provide an early warning of fire and costs very little so the risk versus reward benefit is insignificant. If it costs nothing or very little and may have some benefit why argue against doing it or am I contradicting myself?
Again, like fire doors, fire alarms are not appreciated by tenants, often abused, deactivated and damaged. It is not uncommon to find the smoke detectors have been covered by a plastic bag, or a sock etc.
What is really needed, if fire protection for HMOs is required, is a fire protection system which is not prone to being abused by the tenants, and ideally from the landlord’s point of view costs less than the current fire protection advocated by HSDs and does a better job. It is not as if such a system does not exist, it does – it is called ‘Fire Sprinklers’ and if some over the top standards for fire sprinklers were relaxed they would, in most cases, surprisingly, cost less to install.
Fire sprinklers will not only detect a fire but will contain the spread of fire thereby reducing the damage caused by fire by up to 80%. But more crucially there has never been a death through fire in a property with a fully fitted sprinkler system, which is more than you can say about the current system, called passive fire protection, which is imposed on HMO landlords. Even with the expensive fire precautions required by HSDs, tenants will continue to die in HMO fires. There is a lot of misunderstanding regarding fire sprinklers which has been addressed in my article ‘How Landlords Can Save Lives and Money’ available free of charge on my website
The relevant authorities prefer the superior system, in high risk situations where they insist on the use of fire sprinklers but only as a bolt-on to the existing passive fire protection system, not instead of. Why? It is difficult to understand their standpoint if fire sprinklers do a better job and are cheaper. It seems that an irrational institutional thought pattern is in place which nobody seems to be able to break.
The industry standard of providing passive fire protection in HMOs results in nobody fitting fire sprinklers as they are not required by law; apart from me – I fit them whenever I refurbish a HMO, because as I said at the beginning of this article, there is little evidence, on a risk basis, to support the need for very much fire protection in HMOs.
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