AnthonyB

Who told you this?

Each flat in a sheltered housing block should have it's own self contained smoke & heat alarm system with a link to the flats telecare system to alert the remote warden service. It should be a Grade D1 LD1 system with smoke alarms to hallways, rooms other than bathrooms and a heat alarm to the kitchen. Older sites may have less provision but must by law have the smoke detector to the hallway as per the Smoke and Carbon Monoxide Alarm (England) Regulations 2015. These Regulations didn't apply to social housing providers originally, but as they have been found in recent years to be as bad as the worst private slum landlord they amended the law in 2022 via the Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 to include those as well. The common alarm is not there to save the life of the flat occupier - it is there purely to alert the building and remote monitoring in case no one from the flat raises the alarm. A heat detector would activate after a room occupier had died and is used to prevent false alarms to the whole building and must be supplemented by a local system of smoke alarms. Links: Fire safety guide for sheltered housing: https://www.nationalfirechiefs.org.uk/write/MediaUploads/NFCC Guidance publications/NFCC_Specialised_Housing_Guidance_-_Copy.pdf Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 guidance: https://www.gov.uk/government/publications/smoke-and-carbon-monoxide-alarms-explanatory-booklet-for-landlords/the-smoke-and-carbon-monoxide-alarm-england-regulations-2015-qa-booklet-for-the-private-rented-sector-landlords-and-tenants

Yes. The law also changed on 1st October meaning you must have a written FRA no matter how small you are or if you have employees or not. Here is the up to date guide to the law as of 1/10/23: https://assets.publishing.service.gov.uk/media/651567fe7c2c4a001395e180/14.310_HO_How_To_Guide_FINAL_RX_v04_.pdf Here is the FRA guide for small premises: https://www.gov.uk/government/publications/making-your-small-non-domestic-premises-safe-from-fire If you were just cutting hair in an unadapted room of your house that normally was a living or dining room it might be diffferent

Maintained fittings still have the charging light on, the only difference being they are lit in non emergency conditions.

Based on the new guidance: The FD20 doors would be fine without upgrading using fire & smoke seals (but would be a useful addition on a voluntary basis) The heritage doors would only be acceptable if of suitable solid construction, to quote the guide: "In most instances, it should be possible to accept solid, conventional doors that are a good fit in their frames. This will typically comprise a 44mm thick door of solid timber or with a core comprising flaxboard or chipboard. However, hollow core and thin panel doors, and any plain (non-fire resisting) glazing within doors or frames, provide little fire resistance and will normally need to be replaced with new 30-minute fire-resisting doors. Fitting intumescent strips and smoke seals to existing fire doors is not considered essential in properties covered by this Guide; in case of doubt, the advice of a competent fire safety specialist should be obtained."

There is brief mention of defend in place in the old (but still current until replaced) DCLG Residential Care Premises FRA guide & a lot more detail. including personal protection suppression, in the NFCC Specialised Housing Guide.

Guidance 50.—(1) The Secretary of State must ensure that such guidance, as he considers appropriate, is available to assist responsible persons in the discharge of the duties imposed by articles 8 to 22 and by regulations made under article 24. [F1(1A) Where in any proceedings it is alleged that a person has contravened a provision of articles 8 to 22 or of regulations made under article 24 in relation to a relevant building (or part of the building)— (a)proof of a failure to comply with any applicable risk based guidance may be relied on as tending to establish that there was such a contravention, and (b)proof of compliance with any applicable risk based guidance may be relied on as tending to establish that there was no such contravention.] (2) In relation to the duty in paragraph (1), the guidance may, from time to time, be revised. [F2(2A) Before revising or withdrawing any risk based guidance in relation to relevant buildings the Secretary of State must consult such persons as the Secretary of State considers appropriate.] (3) The Secretary of State shall be treated as having discharged his duty under paragraph (1) where— (a)guidance has been made available before this article comes into force; and (b)he considers that the guidance is appropriate for the purpose mentioned in paragraph (1). [F3(4) In this article— “relevant building” means a building in England containing two or more sets of domestic premises; “risk based guidance” means guidance under paragraph (1) about how a person who is subject to the duties mentioned there in relation to more than one set of premises is to prioritise the discharge of those duties in respect of the different premises by reference to risk.]

Yes - you really need to start referring to this https://www.gov.uk/government/publications/fire-safety-in-purpose-built-blocks-of-flats

Air BnB is considered using your house as a business like a guest house, BnB etc (& is taxable income as a result) and so requires more stringent safeguards. A lodger (which is not counted as taxable income up to a threshold) is more of a private arrangement with lesser requirements (but not if you have several) Holiday letting https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1147723/A_guide_to_making_your_small_paying-guest-accommodation_safe_from_fire.pdf Houses and lodgers https://www.lodgerguide.co.uk/landlord-lodger-legal-obligations/ https://www.cieh.org/media/1244/guidance-on-fire-safety-provisions-for-certain-types-of-existing-housing.pdf

You will see both configurations. The preference is not to cut normal lights that aren't combined EL units and in combined multi tube fittings only cut power to the tube with the battery pack, but it's not the end of the world if it's the more simple whole circuit cut as in most (but not all) situations it's just a quick disruption not a hazard.

Domestic detectors generally have a 10 year life. Original standards were to only put a smoke alarm in the hallway, but current practice is to also have a linked heat detector in the kitchen and possibly another smoke alarm in the living room, so most responsible landlords use the need to rewire a flat or otherwise renew the alarms as an opportunity to upgrade protection to the latest standard. The common alarm as described would only be required where there is some defect that cannot be readily resolved in the fire resistance/compartmentation of the building or, in anything other than the smallest blocks, the smoke control and Government guidance says this should be a last resort. This would also accompany a move from 'stay put unless affected' to 'simultaneous evacuation'. As for the doors, whilst they have limitations on gap sizes and should have close fitting smoke brushes, they shouldn't be difficult to open, there are standards governing how much force is needed to open a door and this would suggest a problem with the installation.

You could do it yourself, but the premises fall out of the scope of the small premises guidance and being a conversion of an older building would fall between two very different guidance documents with very different outcomes regarding installed fire protection and fire procedures depending on when, how and to what standard it was converted, so a degree of competence is required to determine which applies. If a modern conversion following the guidance in Approved Document B this is your guide: https://www.gov.uk/government/publications/fire-safety-in-purpose-built-blocks-of-flats If an older conversion or a modern one that departed from Approved Document B due to the constraints of the host building then this is your guide: https://www.cieh.org/media/1244/guidance-on-fire-safety-provisions-for-certain-types-of-existing-housing.pdf

No - that's why they are 1100mm from the floor - that is set in Building Regulations on the assumption people can crawl past the window (not that they would usually need to in a stay put block), the doors should still be fire doors though.

Plenty of houses exist without back doors at all and only the front and are perfectly fine. The door configuration appears a poor design though. I'd check on the council planning web site to see if the extension passed Building Control.

The assessor is correct in principle, however it may be adequate instead to expand the existing system to provide the correct cover. Regardless of whether it's done by one system or two separate systems the minimum cover would be (as has been for decades including when this would have been fitted. - Common system has detection to common stairs and hallway of each flat - 85dB at the bedroom doors from a common sounder (usually this means a sounder in each flat but you could always do an audibility test from the existing sounder location to see how loud it is when the sound gets to the bedroom doors) - If the common detector in each flat hallway is a heat (usually is but not always) then each flat would need a standalone smoke alarm in the hall. I'd extend the existing system with a couple of detectors (& if needed sounders) to achieve the physical cover above, which should be cheaper than ripping it all out and starting again. Whilst it isn't then a mixed system it provides the required level of protection - the only difference being an increased false alarm risk due to the common system having smokes in the flats.

The current definition of small is: • single premises of ground floor, or ground and first floor, providing sleeping accommodation for a maximum of 10 persons, with no more than four bedrooms on the first floor, such as houses, cottages, and chalets • individual flats (whether within a purpose-built block of flats or a house that has been converted into flats), other than unsually large flats (e.g. as often found in mansion blocks in London) The extra floor would make the larger premises guidance an applicable benchmark.

There are a variety of potential risks - fire, shock, mould from the resultant damp, etc. You are getting the runaround - further guidance here https://www.citizensadvice.org.uk/housing/repairs-in-rented-housing/

If your Fire Risk Assessment states a Category L1 fire alarm system is required then this is correct. The official government guidance (also referred to by Enforcers & Courts) points to care homes needing an L1 system if they are larger, particularly those accommodating more than ten residents above the ground floor, or where a significant proportion of the residents are dependant upon staff assistance to escape in the event of a fire. Other smaller lower risk homes can have an L2 system where there is more risk based flexibility as to the use of detection in certain rooms.

1. Yes - notwithstanding the fact they were already a requirement even back when the block was built, self closing flat front fire doors are a requirement now for all ages of block. The only difference is what standard of door is accepted based on age, number of storeys and layout of the block. See: https://www.gov.uk/government/publications/making-your-small-block-of-flats-safe-from-fire https://www.gov.uk/government/publications/fire-safety-in-purpose-built-blocks-of-flats 2. No, but they have legal duties under the Housing Act (& several subsidiary regulations) regarding the minimum condition & fitness of rented properties which includes fire safety, whilst a bit dated (& under revision) the guidance used by Council EHO's is: http://www.cieh.org/library/Knowledge/Housing/National_fire_safety_guidance_08.pdf The common areas FRA should always have considered flat front doors and spread between flats, but was so ignored by freeholders and risk assessors further legislation and guidance was introduced in the last couple of years to leave no doubt as to the requirement.

If you need a shop link you will need a Grade A system. A wireless system may be an option as cheaper to install. For the size of building you shouldn't need a big expensive system, a simple conventional system would suit. Due to the owner occupancy you can't be required to licensed, but that's a separate issue (& legislation) to the actual practical fire safety issue. If your risk assessment would tolerate only Grade D equipment AND the enforcers would accept that (even tough it's against guidance) you would be fine, but it's not guaranteed.

Number of detectors has no connection with the required Grade of system. Where a Grade A system is required it essentially uses the same equipment as a commercial system to BS5839-1 with just some slight differences in system design The categories and types come from here The lay person gets understandably confused by referring to flats as HMO's. They are not HMO's in the traditionally recognised sense (House of bedsits or bedrooms with shared kitchen and living room) but are houses (or similar) converted to flats but not to the standard required by post 1992 Building Regulations. As a result these are high risk premises and where the flats are majority rented a Council can choose to license it under s257 of the Housing Act using the HMO licensing scheme. It's not mandatory licensing so not all Councils require s257 flat conversions to be licensed. From a Fire Safety Order point of view the risk is the same even if a flat conversion is majority or exclusively owner occupied (& thus not eligible for licensing under s247) so risk assessors and enforcers will apply the same fire safety requirements as set for those that do fall under the s257 system if it does not follow modern building regulations (& thus requires a full evacuation policy not stay put). Of course you imply you are in Scotland. If this is the case there are no modern fire safety regulations protecting flats and residential premises beyond the recent smoke alarm requirements as the Scottish equivalent of the Fire Safety Order specifically excludes these premises - you don't even need a FRA like you do in England & Wales. So in theory as long as you meet the basic smoke alarm regulations which you state you do you are fine whereas in England & Wales you would need further work.

Difficult to say without seeing it or the design fire strategy that should have been produced if it's a legal conversion. It doesn't sound right - you should ask for the Fire Risk Assessment - from October you have legal rights to receive far more detailed information than ever before on the property. If you are really worried the fire service are the enforcers you could ask them to check.

https://www.gov.uk/government/publications/making-your-small-block-of-flats-safe-from-fire gives a measured approach. If the only thing wrong with a doorset is it doesn't have a certiifcation plug or sticker then it's not always proportionate or necessary to replace.

What type is the existing system and where are the sounders and detectors fitted? How many floors is the property over? The assessment is saying the right sort of things, but without more info I can't say for sure if it's proportionate or not.

It's up to the lender. If they feel their investment is potentially at risk they will not lend for fear of not getting their money and interest back. Different lenders will have different approaches.