New Fire Safety Guidance for Holiday Lets: Is Your Fire Risk Assessment up to Date?

How has fire safety guidance for holiday lets changed?

There are two main changes to note between the previous and the current guide for self-catering holiday lets.

Changes to holiday let fire extinguisher regulations

Firstly, there are changes to the holiday let fire extinguisher regulations. Powder fire extinguishers are no longer permitted in this type of accommodation and should be swapped for two-litre Biomax Foam fire extinguishers. These are multi-purpose, domestic sized and will have passed the 35KV dialectical test.

Changes to legislation on fire escape routes

Secondly, the new fire safety guidance for self-catering holiday lets provides revised information on fire escape routes.

Holiday let owners have always been required under the FSO to ensure it is possible for guests and staff to evacuate the premises as quickly and as safely as possible in the event of a fire. Emergency routes and exits must lead as directly as possible to a place of safety.

In addition, it has always been imperative under the FSO to ensure that any escape routes can be used safely and that they are kept clear of obstructions. An escape route includes any rooms, corridors, and stairs that people must pass through to escape from a building.

A room where the only escape route is through another room is known as an 'inner room'. Anyone within an inner room could be at risk if a fire starts in the outer (or access) room. Although this arrangement should be avoided wherever possible, it is acceptable where the inner room is a kitchen, laundry or utility room, bathroom, WC or shower room, and where steps have been taken to mitigate the risk.

It is important to note that inner rooms should not be used for any form of sleeping accommodation, unless the rooms are on the ground floor and have direct access to a door or “escape window” that can be used by the occupants to reach a place of safety clear of the accommodation.

Escape windows on the ground floor can only be considered acceptable if they can be easily accessed, and if they provide a clear opening of sufficient size to allow able-bodied persons to escape in the event of a fire in the access room.

It is not permissible to allow mobility impaired people to sleep in rooms where the means of escape relies on escape windows.

The new fire regulations for holiday lets explicitly state that the use of escape windows for rooms on the first floor is not considered a safe means of escape for paying guests. This is because they will not usually be familiar with the property's layout.

Previously, first floor fire escape windows were accepted by Fire Enforcing Authorities and Fire Risk Assessors to address inner room bedrooms resulting from an open plan layout of the escape route, for example, a staircase leading into a lounge or kitchen.

Therefore, if your property has inner rooms on the first floor and these are used by paying guests, and you cannot reasonably change the use of these rooms, then you should seek advice from a competent fire safety professional in order to consider additional fire safety measures that might provide an alternative way of keeping people safe.

You will also need to review your holiday let Fire Risk Assessment in line with the revised guidance.

We estimate that around 50% of the holiday lets in Cumbria's Lake District have now become non-compliant due to this new fire safety guidance for holiday lets.

The issue is further compounded as Building Control officials will often sign off a self-catering holiday let conversion as residential, and will therefore allow the use of first floor fire escape windows as an alternative escape route. This means that owners will go through all the correct procedures, identifying the intended use to the design team and Building Control Authority, yet still end up with a property that is non-compliant.

Any clients that are looking to convert a property into self-catering accommodation should arrange for a preliminary Fire Risk Assessment so that we can comment on the suitability of the design to comply with the relevant legislation.

Our initial thoughts are that we may be able to permit inner room bedrooms, providing that the access room is a lounge that contains no fires, a high fire load or significant ignition sources.

In terms of additional fire safety measures, these may be difficult for owners to implement, but could be, for example, fixed fire suppression systems in the access room where the internal route cannot be readily protected. However, fixed fire suppression in isolation may not always be suitable to address this issue.

The new fire safety guidance for holiday lets states that it does not apply to properties that incorporate open plan living on the ground floor, and instead the aforementioned Sleeping Accommodation guide should be used. This guide has less scope for permitting existing close-fitting doors and domestic style fire alarms in these types of premises, but does allow inner rooms, providing the access room does not present a high fire risk.