HMO common entrance fire prevention measures

[karl]

Hi

I find myself in a Section 257 HMO situation.

Therefore I've been following the LACORS guidance.

Its a three storey house converted to self contained flats, with the common entrance and staircase only serving the first & second floors.

My flat is on the first floor, which I will be renting out. The second floor is a private owner occupier (who doesn't want to know about any modifications!!) and the ground floor (with separate entrance) is rented out.

I'm carrying out the following works to the common entrance corridor and staircase/landing up to my first floor flat:

1. 30 min fire rated accessible and lockable box around the electricity meters in the entrance.

2. New common front door lock which cannot lock from the inside with a key.

3. Integral battery backed emergency lighting - powered from the existing lighting circuit - one at ground and one at first.

4. Grade D LD2 fire detection

5. The carpet is circa 5 years old but we don't have any documentation. Carpet stores advise that carpets of that age would comply with the EU regulations for fire. Therefore I don't propose to change the carpet.

 

Any comments on my approach would be much appreciated

 

Many thanks

 

 

[Tom Sutton]

From what you have said you are not a HMO, however any common areas are subject to The Regulatory Reform (Fire Safety) Order 2005 and the person/persons defined as the Responsible Person (RP) has a duty to conduct a Fire Risk Assessment amongst other things. You are using the correct guidance FIRE SAFETY Guidance on fire safety provisions for certain types of existing housing.

The owners of all the flats are most likely to be designated the RP and the have to co-operate with each other.

Firstly you must establish your legal position by contacting a solicitor that specialises in Fire Safety and make the other owners aware of their duties. If they will still not cooperate get the local Fire and Rescue Service involved as they are the enforcement authority.

[karl]

Thanks Tom,

I understood that it is a HMO because the conversion was before 1991 and if more than 2/3 of the house is rented then it falls under Section 257.

Apologies I didn't clarify that.

 

 

[AnthonyB]

Yes it is technically an HMO if converted, or purpose built up to 2 flats, but not under mandatory licensing unless it meets the 5 persons, 2 households threshold (number of floors is irrelevant as that's gone in England), there may be additional or selective licensing requirements dependant on Council.

 

[Tom Sutton]

I stand corrected, after a little research I realized definitions had changed in 2006 but also the RR(FS)O still applies to the common areas so my suggestions still apply. Check out with the local council and FRS to see if there is any agreements, if not, then the RR(FS)O may be the best route to go. 

[karl]

Thanks again for your feedback.

Your views on the measures I’m implementing would be greatly appreciated.

I’m most concerned about the Grade D detection. I’m worried that it might need to be Grade A, which is really a big difference. 

The common escape route serves the first and second floor flats and not all three, so I figured Grade D would be acceptable.

Many thanks 

[Tom Sutton]

I think your problem is you cannot consider only your flat, the FRA should cover the whole of the building so you need to get the cooperation of all the owners who under the RR(FS)O are the Responsible Persons.

[karl]

 

I am in consultation with the other owners.

However, the issue of Grade A or D detection has to be resolved.

LACoRS states that for houses 3 storeys and above, the common escape route should be Grade A.

The house is three stories but the escape route serves two flats.

Im hoping that on that basis, (I.e. that the escape route only serves two flats -  first & second)  that Grade D would be acceptable.

What do you think ?

Where can I get a definitive answer for this ?

Many thanks

[AnthonyB]

Unfortunately it's all guidance at the end of the day, and despite the fact there should be a consistent approach different Local Authorities have different interpretations (some out of date or plain wrong, others sensible and balanced) perhaps you should see what the EHO's in your area would be looking for.

[karl]

Thanks for your feedback.

Local Authority guidance states the following :

"An automatic fire detection and alarm system shall be provided to ensure early warning in the event of a fire. The actual works required in any particular case will depend on the layout of the property and are decided upon by the Council following consultation with the Fire Authority and having regard to the LACORS “Housing – Fire Safety” guidance."

Thing is, since I'm a section 257 HMO and don't currently need a licence, the EHO wont come out to view!!

So if I install a Grade D and they eventually come out when the licence is required (could be next year) and decide I need a Grade A, I will then have to pay all over again for a Grade A system.