HMO clarity, please...

[Fireman1987]

I've carried out a  number of fire risk assessments on three buildings which are, I believe, single domestic dwellings.  None of the premises are on a Register of HMOs.

One bungalow has a single occupant with a 22/7 (there's a day-time 2-hour 'break' in care) carer.  The house is owned by a housing association and on long-term rent to the tenant, with care provided by a third party.

The second bungalow is similar, but with three residents and a 24/7 carer, each with their own bedrooms but the rest of the house is shared.

The third is a two-storey house with 2 residents and a 24/7 carer, each with their own bedrooms but the rest of the house is shared.

I think the bungalow with three residents may come under the RRO, but surely the other two are domestic dwellings and do not?

All the houses are fitted with full L2 fire alarm systems (including MCPs) and emergency lighting, therefore requiring testing and maintenance, and the member of staff carry out 6-monthly fire drills.

Any thoughts?

Thanks.

Edited October 21, 2019 by Fireman1987
Added detail

[Tom Sutton]

I am assuming in bungalow one, the carer doesn't live in therefore I would class it as a single domestic dwellings. Bungalow two and three  have multiple tenants so there will be common areas therefore subject to the RR(FS)O. The appropriate guidance would be Fire Safety in Specialised Housing.

[Fireman1987]

19 hours ago, Tom Sutton said:

I am assuming in bungalow one, the carer doesn't live in therefore I would class it as a single domestic dwellings. Bungalow two and three  have multiple tenants so there will be common areas therefore subject to the RR(FS)O. The appropriate guidance would be Fire Safety in Specialised Housing.

Thanks, Tom.

There is a live-in carer in all these scenarios, but I'm still not sure about this.  My understanding from quite a few years ago (It may be brain fade, but I'm happy to be corrected) is that a carer is part of the household, like a butler or a housekeeper.

In essence, the owner rents the building to a tenant, and the tenant's care is provided by the local healthcare provider, all be it on a 24/7 basis.  As I see it, the carer's employer is responsible for their employee, but the fire safety responsibilities lay with the tenant, not the landlord?  I suppose another side of this is if the landlord has the right to carry out an FRA in a domestic dwelling!

So, back to the books for me...

 

[AnthonyB]

https://www.nationalfirechiefs.org.uk/write/MediaUploads/NFCC Guidance publications/NFCC_Specialised_Housing_Guidance_-_Copy.pdf

This is the guide referred to by Tom

[Tom Sutton]

Fireman 1987 I would agree with you, a carer would not form a separate household and is part of the tenants household. Also I believe the landlord has the right to conduct a FRA but if it is a single tenant then it would not be subject to the RR(FS)O. What I do consider important that the guide to use, is Fire Safety in Specialised Housing.

[Fireman1987]

Thank you ?