Ranch-style layouts with open plan living areas are relatively common in rented accommodation, including social housing; these layouts often include “inner” bedrooms whose fire escape route is through the open area. This is clearly against the guidance under two pieces of major recent legislation, the Housing Act 2004 and the Regulatory Reform (Fire Safety) Order 2005, which introduced new responsibilities for landlords and housing organisations. Some ambiguities in these laws have since been addressed by the LACoRS guide, published by the Local Government Association and endorsed by Central Government and the Chief Fire Officers’ Association; this document outlines how safe layouts must be achieved.
Some key facts:
- Although the LACoRS guide itself does not have legal force, it is now regarded as the standard interpretation manual for the new legislation.
- Unlike changes to building regulations, the new legislation applies retrospectively to all rented properties.
- Properties that don’t meet the new standards may remain in use only where it is “not reasonably practicable” for the landlord to remedy the problem.
- Landlords found to be in violation of the new laws can be imprisoned or face an unlimited fine.
Inner Bedrooms – What’s the Problem?
The LACoRS guide defines an inner room as one for which the only escape route is through another “access” room; this poses a risk to the occupier if a fire starts unnoticed in the access room.
Figure 1: Example social housing property layout featuring an inner bedroom
Figure 1 shows a social housing property layout featuring an inner bedroom. Inner bedrooms are particularly dangerous as an inhabitant may be deeply asleep and perhaps also intoxicated when a fire starts in the outer room. A closed bedroom door is a mixed blessing – although it may hold back smoke for a time, it also reduces the sound level of any alarm sounding in the outer room. Slow to rouse, the sleeper may awaken to discover a major fire and thick smoke on the exit route.
Section 12.2 of the LACoRS guide makes it quite clear that inner bedrooms and even living rooms are no longer allowed above first floor level:
[Inner rooms] should be avoided wherever possible. However, where unavoidable it may be accepted where the inner room is a kitchen, laundry or utility room, a dressing room, bathroom, WC or shower room.
Where the inner room is any other type of habitable room (for example a living room, sleeping room, workroom or study) it should only be accepted if:
- the inner room has access to a suitable door opening onto an alternative safe route of escape, or it is situated on a floor which is not more than 4.5m above ground level and has an escape window leading directly to a place of ultimate safety [and]
- an adequate automatic fire detection and warning system is in place; and
- a fire-resisting door of an appropriate standard is fitted between the inner and outer rooms (typically FD30S standard for non-high-risk outer rooms).
What can be done?
Provision of automatic fire suppression is allowable as a compensatory feature against such layout shortcomings. The LACoRS guide states:
… provision of a suitable water suppression system can, in some circumstances, allow for relaxed provision of certain other fire safety measures [such as] relaxed requirements for inner rooms.
A fire suppression device aims to control and suppress fires, significantly reducing the risk of injury, loss of life and property damage by maintaining tenable conditions for as long as possible while occupants evacuate. This is achieved by:
- Reduction of room temperature
- Reduction of smoke and toxic gases
- Prevention of flashover (the rapid ignition of combustible items in the room)
- Providing cooling and hence fire resistance to structural elements of the home.
In the immediate years following the introduction of the new legislation, the cost of retrofitting sprinklers to properties with dangerous layouts was prohibitive. Not only would housing associations face huge installation costs; disruption to families would also be enormous. It was therefore straightforward to argue that there was no reasonably practicable solution available to address poor layout. This is no longer the case.
Retrofittable fire protection
Inner rooms can now be protected by installing innovative water suppression devices in the access room. Several such devices are now available, designed to provide effective, retrofittable fire protection within the frameworks both of the new legislation and building regulations. Plumis’s Automist is one such solution and is the first active fire protection system that combines low cost and ease of retrofit with excellent aesthetics. Intended as a more practical and affordable alternative to sprinklers, Automist uses a high pressure pump to generate a fine water mist from nozzles mounted under a kitchen tap, on a work surface or in a wall. In extensive BRE testing, Automist was found to render a lethal environment survivable.
In the event of a fire, an automatically-triggered pump drives mains water through the unique nozzle unit, quickly filling the room volume with fog. The use of conventional heat detection, already the standard in kitchens, effectively eliminates nuisance activation. Unlike conventional sprinklers, Automist can be stopped and reset instantly via its control panel. As Automist uses much less water than a traditional sprinkler system, water damage in the event of activation is minimised.
Automist is safe to use in kitchen areas. Adding water to a cooking oil fire can greatly exacerbate the fire; the same is not true for water mist, as the up-draught from the flame and the evaporation of the tiny droplets prevents water from reaching and collecting in the pan.
To determine whether retrofittable fire suppression is suitable for a specific application, standards are available; notably, PD7974 (Application of fire safety engineering principles to the design of buildings) provides a framework for analysis of where the fire risks are, how fire and smoke will spread, and how passive and active fire protection and detection/alarm systems will function in a given layout.
New legislation requires the responsible person (landlord, occupier or both) to carry out a fire safety risk assessment, maintain a fire management plan, implement fire safety measures and address specific dangerous layouts.
Landlords who fail to address inner bedroom and living room configurations risk prosecution, unlimited fines and even prison sentences. Two landlords in Haringey, Greater London, were sentenced to six months’ imprisonment and ordered to pay £5,000 costs each because a fire in their property had revealed inadequate fire safety measures. In 2008, a Suffolk hotel case over an inner bedroom resulted in a prison sentence and a fine of £204,000.
With systems like Automist now available, landlords and housing groups can no longer claim that no viable solution exists for these problem layouts. Those who continue to permit these layouts without adequate fire safety measures do so at their peril.