Consultation outcome

Government response: Emergency Evacuation Information Sharing Plus (EEIS+) consultation (accessible)

Updated 2 December 2024

Published on 2 December 2024

Contact details

This document is the post-consultation response to the Emergency Evacuation Information Sharing Plus consultation.

It covers:

• the background to the consultation;

• an overall summary of the consultation responses;

• a detailed summary of the responses to the follow-up free-text questions asked in the consultation;

• a summary of the points raised in the four workshops held during the consultation period;

• a summary of the responses to the calls for evidence in the consultation;

• the next steps following this consultation.

This report is available at Emergency Evacuation Information Sharing Plus (EEIS+).

Fire Safety Unit
Home Office, 2 Marsham Street,
Peel Building
London
SW1P 4DF

Email: FireSafetyUnitconsultations@homeoffice.gov.uk

Alternative format versions of this publication can be requested from: FireSafetyUnitconsultations@homeoffice.gov.uk

Complaints or comments

If you have any complaints or comments about the consultation process, you should contact the Home Office at the above address.

Ministerial foreword

Protection of the most vulnerable people in our society is a key priority for government, and making improvements to fire safety is a vital part of this protection. With the Grenfell Tower tragedy and the publication of the public inquiry’s final report on 4 September at the forefront of my mind, this protection is more vital than ever. That is why I am pleased to publish the response to the Emergency Evacuation Information Sharing Plus consultation and to introduce a set of measures called Residential Personal Emergency Evacuation Plans (Residential PEEPs) policy – addressing three of the Grenfell Tower Inquiry’s Phase 1 recommendations aimed at government.

I want to thank those who took the time to respond to the consultation: the responses have helped shape and refine the proposals into a practical, proportionate and safe package to improve fire safety for vulnerable residents. I also wish to thank the many key stakeholder organisations and individuals who worked with Home Office officials in the numerous workshops and meetings that have taken place.

With the publication of this response document, we will move to lay Regulations to deliver the Residential PEEPs policy. Our engagement with key stakeholders, including disability stakeholder organisations, will continue, to help to ensure a smooth road to implementation, including the production of supporting guidance that will sit alongside the Regulations.

The Rt Hon Dame Diana Johnson DBE MP

Minister of State (Minister for Policing, Fire and Crime Prevention)

Introduction

One of the Home Office’s key priorities is to protect vulnerable people and communities. A vital aspect of this is fire prevention and rescue. This includes responding to the recommendations concerning fire safety made by the Grenfell Tower Inquiry in its Phase 1 Report and returned to in its Phase 2 report published on 4 September this year. Two of these recommendations (33.22(e) and (f)^{[footnote 1]}) relate to Personal Emergency Evacuation Plans (PEEPs), while a third recommendation (33.22(c)) covers evacuation plans.

The Home Office developed a package of measures to deliver against these recommendations and put them out to consultation in the Emergency Evacuation Information Sharing Plus consultation which ran from 18 May – 21 August 2022. The consultation sought views on proposals for:

• Responsible Persons (RPs)^{[footnote 2]} to identify and engage with mobility impaired residents^{[footnote 3]} in higher risk buildings (that is, those with simultaneous evacuation strategies in place), offering them a Person-Centred Fire Risk Assessment (PCFRA) and considering with them what interventions might be reasonable to put in place to mitigate against the risks identified in the PCFRA;

• RPs to then, in cases where there are remaining issues that prevent the resident’s evacuation, make the resident’s details available to the local Fire and Rescue Service (FRS) who would factor this information into their operational response in the event of a fire and potentially carry out an emergency evacuation.

Other elements within the consultation package included a proposal for a toolkit to support fire safety measures in all buildings; a Working Group to examine the role that neighbours and relatives can play in supporting the evacuation of mobility impaired residents; and a call for evidence for existing fire safety initiatives (including PEEPs) implemented in residential settings.

Views were sought from a broad spectrum of stakeholders, including: residents of high-rise buildings; disability groups; FRSs and the wider fire sector; local authorities, housing associations and other housing providers; academics; and numerous professional bodies. The consultation also considered and tested the evidence and assessment made at the end of the previous consultation on PEEPs, held in the summer of 2021, so that all of the evidence garnered during both consultations is taken into account to inform the decision-making process.^{[footnote 4]}

Since the recommendations were made by the Inquiry Chair, significant improvements have been made in the fire and building safety environment, notably:

• As reported in the thematic updates on progress against the Grenfell Tower Inquiry Phase 1 recommendations^{[footnote 5]}, the implementation of 11 of the Inquiry recommendations aimed at government, primarily through the Fire Safety (England) Regulations 2022, which came into force on 23 January 2023). These regulations set out new responsibilities for RPs of thousands of buildings across England. Among other requirements, the regulations include: mandated instructions to residents on what they should do in the event of a fire; a rigorous regime of fire door inspection to protect the compartmentation which is so vital to inhibit the spread of fire; stricter requirements of signage to help both residents and the FRS in the event of an emergency; and a requirement for a secure information box to be installed in and maintained for all high-rise residential buildings.

• A tranche of new and revised guidance relevant to residential blocks, with nine new fire safety guides published and more in train.

• Commencement of the Building Safety Act 2022 which established the new Building Safety Regulator to regulate high-rise/higher risk buildings in England. The Building Safety Regulator places additional duties on Fire and Rescue Authorities, and government is providing new burdens funding to support their contribution to the new regime.

While these measures provide further protection and support to all residents of affected buildings, this consultation response addresses measures that specifically focus on residents whose ability to self-evacuate may be compromised, to supplement the wider, more generic arrangements in place for all residents.

This response: explains the consultation (including our methodology in analysing the quantitative and qualitative data drawn from the answers submitted); summarises the respondents and the responses; details the Impact Assessment accompanying the consultation; and sets out the additional work which has taken place beyond the consultation such as the workshops held during the consultation period, the proposed toolkit for RPs and work undertaken by our Evacuation and Fire Safety Working Group. The conclusions start on page 73 and set out the actions government will now take as the outcome of this programme of work, including new legislation.

The consultation

The consultation outlined a five-step process that makes up the Emergency Evacuation Information Sharing proposals. These steps are:

1. Defining the building evacuation strategy

2. Identification of those needing support to evacuate

3. Person-Centred Fire Risk Assessment checklist

4. Sharing information with the local FRS

5. The FRS access and use this information in the event of a fire

In this five-step process, the RP would be required to carry out a Person-Centred Fire Risk Assessment (PCFRA) for any resident they identify as a resident whose ability to self-evacuate is compromised in their building. Such PCFRAs would identify the risks to the individual’s fire safety and their ability to evacuate in the event of a fire. The RP would then work with the resident to review the outcomes of the PCFRA and identify what measures could be reasonably implemented to mitigate against the identified risks. Where such measures have been implemented and there are still issues preventing the resident’s evacuation, information pertaining to the resident and where they are located in the building would, under the proposals, be made available to FRSs for them to use as necessary to support evacuations.

In addition, the consultation sought evidence of PEEPs working in residential buildings and sought further views on the policy proposals consulted on within the 2021 PEEPs consultation.

Readers were asked 18 questions to elicit their thoughts on these steps and the broader policy.

Included within these questions were calls for evidence asking for:

• examples of PEEPs in residential buildings which fully or partially avoid the concerns over safety, proportionality and practicality as set out in the government response to the 2021 PEEPs consultation;

• examples of buildings where staff have been installed on site to support the enacting of PEEPs or other fire safety initiatives (outside of Waking Watch);

• other initiatives for how mobility impaired residents can be made safer in their homes or be evacuated from a high-rise residential building in a way which is safe, proportionate and practical;

• evidence on the numbers of residents in respondents’ building(s) who are mobility impaired and would likely have difficulty self-evacuating.

The consultation included a proposal for the Home Office to work with RPs and others to produce a toolkit that supports RPs with their thinking as to the interventions and strategies available to them to further improve the fire safety of their mobility impaired residents, regardless of the evacuation strategy applicable to their building. This would contain examples of real-life initiatives that RPs have already successfully put in place that other RPs could consider for deployment in their own buildings, including stay put and low-rise buildings.

The consultation also addressed a proposal put forward by FRSs by asking whether respondents thought the addition of an on-site individual to a building, who would provide additional support for the evacuation of mobility impaired residents, would add enough value to the EEIS+ proposals to justify the costs.

As proposed by the Local Government Association, the consultation also referenced government’s commitment to establish a short-term working group comprised of housing providers, disability groups and other key stakeholders. The purpose of the working group is to explore and seek to resolve issues concerning reliance on neighbours or volunteers to help mobility impaired residents evacuate.

In addition to the written consultation, the Home Office held four online 90-minute workshops to discuss the consultation proposals in more detail. These workshops were open to those with an interest or expertise in fire safety and the evacuation of mobility impaired residents, and the general public. These discussions have been summarised on page 63 of this document.

The Home Office maintains a regular dialogue with the National Fire Chiefs Council (NFCC), the Local Government Association, and relevant technical experts to ensure the department fully understands operational issues and keeps up to date with the position on the ground, in order to set our consideration of the policy in context. The Home Office has taken care to ensure that these discussions have not affected unduly the conclusions of the consultation.

Methodology

The consultation was open from 18 May to 21 August 2022.

To ensure that all interested parties were able to respond as fully and effectively as possible, an online survey was hosted on GOV.UK with hard copy and alternative formats available on request.

A total of 142 consultation responses were received: 84 using the online survey format; and 58 submitted in an alternative format via email or post.

We especially wanted to hear from those who would be affected by the consultation’s proposals. Those who responded represent a wide range of interested groups and individuals including disability groups, residents’ groups, FRSs, local authorities and other RPs, fire safety professionals, and responses from individuals such as Grenfell survivors.

At the same time as the new consultation was launched on 18 May 2022, the government’s response to the 2021 PEEPs consultation was published.^{[footnote 6]} Home Office subsequently received 168 pieces of correspondence commenting on the decision announced in that document to not proceed with mandating PEEPs at this time. Each of these expressed their disappointment at that decision, but did not propose any solutions regarding the issues of practicality, proportionality and safety identified in the 2021 PEEPs consultation; nor did these emails comment on the proposals laid out in the Emergency Evacuation Information Sharing Plus consultation. Each piece of correspondence was replied to, with respondents being encouraged to input their views into the new consultation.

Those responding to the Emergency Evacuation Information Sharing Plus consultation were able to answer as many or as few questions as they wanted and could provide supplementary narrative for some questions. The figures set out in this document represent the total number of responses submitted to the consultation as well as, where possible, the number of responses for each of the questions included in the consultation.

Some of the questions prompted those responding to select a level of agreement or disagreement with particular proposals; some asked for those responding to pick from a choice of options; and some allowed those responding to write their answer in a free-text box. Where possible, the responses received are presented in table format. Where open questions were asked or free-text boxes provided, or separate narratives were provided in covering letters, all responses were analysed to identify common themes and coded where possible to collate similar views and comments. Key themes or issues are presented to provide a summary of these responses.

All responses received by the closing date were considered and this document provides a summary of those responses. The most common themes raised by the responses have been reflected in the summary data set out in each question. A separate section under each question has been included detailing any ‘other’ issues raised and any issues raised that were beyond the scope of the question.

Of the 58 responses submitted offline, some did not follow the questions or sections as set out in the consultation document and online questionnaire. As a result, only some of these responses could be included within the quantitative data for specific questions, resulting in lower bases for calculation of percentages provided in summary. However, these responses have all been considered as part of the analysis of the free-text questions they addressed.

Note that all percentages provided, including those that have been summed, are rounded to the nearest whole percentage.

Limitations

Quantifying

In some cases it has not been possible to give the total numbers commenting on a specific point, for example, where those responding supported part but not all of a proposal, or otherwise caveated support elsewhere in their response. Others who responded made the same point several times in answer to different questions. This made quantifying the exact number of those who held the same view in the free-text sections difficult or in some cases not possible. A precise number as to how many responses agreed on the same point was assigned where possible but in some circumstances it was not feasible to do so. Therefore, the volume of responses that made the same point has been described generally by using language such as ‘some’ or ‘others’. Specific points raised by individual responses have also been drawn out where these points have not been raised elsewhere or have added to the range of considerations. This consultation response aims throughout to give the best sense of the different points raised, the number of responses commenting on them and the degree of support given to provide a comprehensive summary of the views held.

Interpreting the free-text boxes

There were points throughout the consultation where those who responded were allowed to choose whether to submit detailed free-text answers in addition to indicating their support of or opposition to a proposal. This opportunity was provided so that the consultation could gauge not only the overall number of responses in support of or in opposition to each proposal, but also the rationale behind each view. It should be acknowledged, however, that those who supported the proposals may have been less likely to fill out the free-text box compared to those who did not accept the proposals.

NFCC and FRSs

The NFCC sent an offline response setting out their views on the Emergency Evacuation Information Sharing Plus proposals. Letters were subsequently received from 23 FRSs stating their support of the views laid out in the NFCC response.

While NFCC and all of these 23 FRSs have been counted as distinct responses in this document, it needs to be recognised that these responses are all effectively the same. Consequently, while the responses are counted discretely, they are referred to collectively in this document as responses from ‘the NFCC and supporting FRSs.’

Of these 23 FRSs, four of them had previously submitted their own independent response. Where an FRS submitted two responses, free-text points made in both responses have been taken into account, but the total numbers noted below avoid double-counting.

Beyond the NFCC and supporting FRSs, a further 13 FRSs sent in their own independent responses.

Therefore, a total of 36 FRSs sent in responses to the consultation, making up a quarter (25%) of all the consultation responses.

Workshops

As noted on page 63, the Home Office held four online workshops during the consultation to discuss the proposals in more detail. These workshops were open to the general public but representation tended to focus on those from: disability groups; those who consider themselves to be mobility impaired (which, as explained in the consultation, includes any condition that would affect an individual’s ability to evacuate in the event of a fire such as, for example, those with hearing, sight and cognitive impairments); FRSs; Local Government; fire safety experts; leaseholders; housing associations; and concerned citizens. These workshops allowed officials to respond to detailed questions on the proposals, for participants to present their own detailed views of the proposals, and for attendees to hear the views and counterviews of other participants.

Care has been taken not to put more weight on views provided at the workshops over those received directly via the consultation document. To foster as open and balanced a conversation as possible, the Chair sought to encourage the full range of views represented to be expressed and for points of disagreement to be debated, while preventing particular individuals or viewpoints from dominating discussion. Consideration was also given to the capacity in which attendees were responding where they declared an affiliation to an organisation.

Where declared attendance from disability groups was low in the workshops, Home Office proactively wrote to some key disability groups to encourage their attendance. Where this attendance was not possible, the Department held separate conversations with these groups.

Additionally, where it was considered that a point of particular importance or interest had been raised in the workshops or where the detail of the point raised was unclear, Home Office endeavoured to follow up with the person who raised the point.

Both these approaches aimed to be as flexible as possible in order to receive the broadest and fullest range of views.

Summary of those who responded to the consultation

Who responded?

Questions 1-4 requested the following information from the respondents:

1. Whether they were responding as an individual or on behalf of an organisation;

2. In what capacity they were responding;

3. The details of the organisation they were responding on behalf of (if applicable);

4. The details of the representative group they were responding on behalf of (if applicable).

In total, 142 organisations and individuals answered questions in this consultation. Those who responded could choose which questions they answered and not all organisations/individuals answered all the questions. The number of responses (n) received for each question is noted in each summary table. In instances where total percentages do not sum to 100 or where combination percentages do not sum, this is due to rounding. In table 1, this is due to those responding selecting multiple categories.

Out of the 142 responses, 129 provided details as to the capacity in which they were responding to the consultation, with more responding on behalf of an organisation (99 responses, or 77% of the total number of consultation responses) than as an individual (30 responses, or 23%). The largest groups who responded to the consultation were those who identified themselves as enforcing authorities (42 responses, or 31%), RPs (24 responses, or 18%), building owners (18 responses, or 13%) and duty holders (14 responses, or 10%). The full breakdown is in table 1. Respondents were able to select multiple options to this question in order to establish the capacity in which they were responding.

Table 1: Breakdown of respondents

Capacity of response	Definitions	No. of responses	% of responses (n=142)
Enforcing authority	A body responsible for enforcing compliance with the Fire Safety Order, as referred to in Article 25 of the Order.	42	31%
Responsible Person (RP)	One who has control over a premises to which the Fire Safety Order applies, defined by Article 3 of the Order, who is responsible for ensuring that Fire Safety Order duties referenced in Article 5(1) are complied with in respect of those premises.	24	18%
Building owner	For the purposes of this consultation, a person or persons, company, corporation, authority, commission, board, governmental entity, institution, owner, lessee, or any other person or entity that holds title to the relevant premises.	18	13%
Duty-holder	A person other than the Responsible Person upon whom any duties are imposed by the Fire Safety Order as referred to in Article 5(3) of the Order.	14	10%
Resident	An individual living in a high-rise residential building.	12	9%
Local authority	An administrative body in local government.	12	9%
Disability Groups	Individuals or groups representing voices of disabled people.	8	6%
Other resident or residential group	An individual or a collective body different than the ’resident’ and ‘residential group for a high-rise building’ categories.	7	5%
Property company	A company that buys, sells and/or rents properties.	6	4%
Professional body	An organisation that promotes, supports and protects a particular profession.	6	4%
Construction company	A company that undertakes construction projects.	3	2%
Trade Association	A body representing businesses of a particular sector.	3	2%
Charity and other organisation	Charities and external bodies interested in fire safety precautions.	2	1%
Residential Group for a high-rise building	A collective body of those living in high-rise residential buildings.	2	1%
Building Control Body	A body responsible for ensuring compliance with the Building Regulations.	2	1%
Other	Any individual or organisation not covered above.	20	15%

Residents’ groups

Responding residents’ groups represented different numbers of people, ranging from those saying they represented fewer than 10 people to those which said they represented over 1,000 people. Residents’ groups most often said they represented more than 1,000 people (five residents’ groups, or 63%).

Table 2: Respondents from residents’ groups

If you are responding on a behalf of a residents’ group, please indicate how many people the organisation represents?	No. of responses	% of responses (n=8)
Less than 10	1	13%
10–49	2	25%
50–249	0	0%
250–999	0	0%
1,000 or more	5	63%

Organisations

The majority of responding organisations (29 organisations, or 69%) said they employ 50-249 people, and three organisations or 7% do not employ anyone.

Table 3: organisations’ employment numbers

How many people does the organisation employ?	No. of responses	% of responses (n=42)
None	3	7%
Less than 10	3	7%
10–49	7	17%
50–249	29	69%

Trade bodies or representative groups

Most organisations responding on behalf of a trade body or another representative group or organisation said they had more than 1,000 members (six trade bodies or other representative groups, or 60%).

Table 4: Membership numbers of trade bodies or representative groups

Number of members (of trade body or other representative group of individual or organisations)	No. of responses	% of responses (n=10)
Less than 10	1	10%
10–49	1	10%
50–249	1	10%
250–999	1	10%
1,000 or more	6	60%

Summary of responses

This section sets out a summary of the responses to the questions put forward by this consultation. Most questions included a free-text box where those who responded were able to expand on their answers to the proposals. Responses that were specific to each question have been summarised under the relevant proposal. There was, however, a significant amount of repetition across responses to the questions, so these recurrent issues have been summarised in the Recurring themes section on page 56.

Step 1: Defining the building evacuation strategy

Questions 1, 2 and 3 invited views and comments on the following proposal:

Step 1: we propose that steps 2 – 5 below are mandated specifically for simultaneous evacuation buildings i.e. those which have been assessed as at higher risk, regardless of their height. In our view, these steps represent a proportionate way forward, that focuses action and resources where they will add the most value.

Question 1: Do you agree or disagree that the initial change in legislation should be focussed on the buildings with the greatest fire safety risk i.e. buildings with simultaneous evacuation strategies in place?

Table 5: Responses to Question 1

Strength of agreement/disagreement	No. of responses	% of responses (n=131)
Strongly agree	20	15%
Tend to agree	35	27%
Neither agree nor disagree	36	27%
Tend to disagree	17	13%
Strongly disagree	23	18%

Overall, 42% of participants agreed that the initial change in legislation should be focussed on the buildings with the greatest fire safety risk i.e. buildings with simultaneous evacuation strategies in place, 27% neither agreed nor disagreed, and 31% disagreed.

Question 1 (free-text section of question): If you disagree, what category of buildings do you propose should be included?

There were 106 responses to the free-text section of this question.

It should be noted, free text was also provided within responses that had agreed or expressed a neutral view on the scale-response above.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Half of the free-text responses (53) to the question expressed support for the switch to a risk-based approach while pointing out some considerations to take into account with this move to a risk-based approach. The other half of the free-text responses (53) raised concerns regarding the proposed move to a risk-based approach. Details of the various issues raised are covered below, in order of prevalence.

Agreement that change in legislation should be focussed on the buildings with the greatest fire safety risk

Half of the responses (53), including the NFCC and supporting FRSs, expressed agreement with prioritising the buildings according to highest fire risk for the initial change in legislation. While the NFCC and supporting FRSs (who accounted for 18% of the total free-text responses to the question) answered with ‘Neither Agree nor Disagree’, in their responses they said that they agreed buildings temporarily moved from a stay put to a simultaneous evacuation strategy should be prioritised for any evacuation information sharing. Although the NFCC and supporting FRSs agreed that the proposed steps 2-5 should be mandated for buildings with simultaneous evacuation strategies in place, they also stated: ‘it is NFCC’s view that such policies should also be applied to other more complex premises types, especially those with sleeping risk and/or with vulnerable occupancy’.

The issues below provide more detail as to the respondents’ concerns regarding the proposed move to a risk-based approach.

Height being used to measure risk

Many responses (42) said that height should not be a factor in determining the greatest fire safety risk in buildings. Most of these responses (26), including the NFCC and supporting FRSs, wrote that they were content EEIS+ proposals do not currently have any height thresholds and that they would not want an expansion of the policy limited to residential buildings over 18 metres.

However, some responses (11) did suggest that different levels of height should be used to determine which buildings should be the focus of initial change in legislation. Two of these responses said that height is the most important factor. Three responses suggested all buildings over 11 metres should be included in initial changes whereas three other responses suggested all high rises should be covered regardless of evacuation strategy.

Two responses suggested prioritisation should be based upon the number of units within a building.

Building type and characteristic focus

Many responses (33) said that certain building types and characteristics should be included and classified as high risk. Most of these responses (26), including the NFCC and supporting FRSs, said that specialised housing should be included in the initial change in legislation, ‘as well [as] those with sleeping risk and/or with vulnerable occupancy’. While the NFCC and supporting FRSs do not explain how they are defining ‘vulnerable occupancy’, they do, however, explain specialised housing as buildings ‘which have a stay put evacuation strategy combined with the potential for a particularly high number of occupants who find themselves in a vulnerable position and may require assistance to evacuate’.

Definition of high risk

25 responses expressed concerns over the definition of high risk, including three disability groups. These concerns were either: that defining high-risk buildings as those in simultaneous evacuation is too limited a definition; or that the definition as used in the consultation runs the risk of excluding buildings which should be considered high risk.

A number of these responses (12) said that using simultaneous evacuation as the definition of a high-risk building is too narrow a scope, with one of these responses saying that a clearer definition of ‘higher-risk buildings’ was needed.

Some of these responses (14) expressed concern that potential high-risk buildings would not be included as high risk. Other responses said that: (i) buildings with a stay put strategy may need to switch to an ‘emergency evacuation’ (five); (ii) not enough is known about the safety of the current building stock (five); or (iii) expressed concerns over the current building stock due to the quality and quantity of fire risk assessments taking place (four).

All buildings should be included

A number of responses (15) said that all buildings should be covered by the EEIS+ proposals, including five disability groups. Most of these responses (11) said that all buildings should look to be covered by the initial change of legislation.

Vulnerability of residents

A number of responses (11) said that the focus should be on the vulnerability of residents in buildings. Some of these responses (three) said that vulnerable people in stay put buildings should also be considered when calculating risk. Others said that vulnerable persons need to be prioritised as they are at the greatest risk of harm from fires.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) calling for evacuation plans for residents who may require assistance in an evacuation (12);

(ii) questioning whether Stay Put would be adhered to by residents following the Grenfell fire (seven);

(iii) questioning how EEIS+ would line up with current legislation and guidance in the sector (six);

(iv) not supporting the consultation (three);

(v) arguing that EEIS+ is an interim measure and that a longer-term solution needs to be identified;

(vi) and saying that increased powers for RPs should reflect what RPs are practically and reasonably able to do.

Question 2: Do you agree or disagree that the toolkit, as described, would be a suitable resource to support RPs in fulfilling their duties under the Regulatory Reform (Fire Safety) Order 2005 (i.e. Fire Safety Order)?

Table 6: Responses to Question 2

Strength of agreement/disagreement	No. of responses	% of responses (n=129)
Strongly agree	21	16%
Tend to agree	32	25%
Neither agree nor disagree	22	17%
Tend to disagree	13	10%
Strongly disagree	41	32%

Overall, 41% of participants agreed that the toolkit would be a suitable resource to support RPs in fulfilling their duties under the Fire Safety Order, 17% neither agreed nor disagreed, and 42% disagreed.

Note: There was no free-text box for those responding to submit an answer for Question 2. Some of those replying online responded qualitatively to Question 2 in their answers to either Question 3 or Question 18. These qualitative responses broadly detailed why those responding thought the toolkit would or would not be a suitable resource to support RPs in fulfilling their duties under the Fire Safety Order.

There were 47 free-text responses regarding Question 2 which were contained within the free-text responses to Question 3 or Question 18.

Details of the various issues raised are covered below, in order of prevalence.

Fire Safety Order and Article 50 guidance

The most prevalent issue raised by responses to this question concerned the Fire Safety Order and Article 50 guidance. These responses (26), including the NFCC and supporting FRSs, said they wanted to see clarification of or further Article 50 guidance.

The majority of these responses (20), including the NFCC and supporting FRSs, said the Home Office should consider introducing new guidance under Article 50 of the Fire Safety Order or via amendments to existing statutory guidance. The purpose of this would be to make requirements clear for residents/RPs/enforcing authorities rather than relying on a toolkit which is open to interpretation.

Some responses (four) said guidance should be used with the toolkit to ensure the clear link to safety in buildings. The London Fire Brigade was concerned about whether the toolkit would be used instead of Article 50 guidance, arguing that using the toolkit instead of the government’s Article 50 guidance would weaken rather than improve fire safety standards for disabled residents.

An additional response wanted guidance on the principals and legal responsibilities of the RP when using the toolkit.

RPs taking different approaches

These responses (23), including the NFCC and supporting FRSs, said they were concerned about the risk judgements being left to RPs. The majority of these responses (20) were from the NFCC and supporting FRSs and said: ‘The FSO [Fire Safety Order] needs to ensure that there is a clear and consistent approach, with no room for ambiguity on what the requirements are for RPs, and provide safeguards for residents of all tenures from disproportionate treatment across relevant buildings. Relying on individual RPs to make these judgements risks creating a multi-tiered system of protections for those residents that may require assistance to evacuate safely from their home’. The implication is that the NFCC and supporting FRSs want duties to be clear in the Article 50 guidance pursuant to the Fire Safety Order and want to avoid interpretation by individual RPs through the toolkit. The NFCC and supporting FRSs believe interpretation by individual RPs may result in a variety of different approaches being taken to resolve similar obstacles for residents who may require assistance in an evacuation. The other three responses said that RPs would have different opinions on what is reasonable and proportionate.

Does not go far enough

These responses (23), which include the NFCC and supporting FRSs, said they were concerned that the proposed toolkit does not go far enough. The majority of these responses (21) were from the NFCC and supporting FRSs and said the toolkit does not go far enough to fully support RPs in fulfilling their duties under the Fire Safety Order. While the NFCC and supporting FRSs did not specify exactly why the toolkit does not go far enough, their various concerns regarding the toolkit are detailed under the other issues raised for this question, namely: their concerns regarding the Fire Safety Order and Article 50 guidance; their fear that the toolkit will result in a multi-tiered system of protections; and their desire for building regulations to be updated. The two other responses (one of which is from the London Fire Brigade) wrote that a toolkit alone would not be adequate: the London Fire Brigade argued that updated guidance which clearly explains to both RPs and enforcing authorities how to satisfy legislation would be of greater benefit; and the other response argued that guidance should be issued on any new duties for the RP under Article 50 of the Fire Safety Order.

Building regulations to be updated to include fire safety measures

These responses (22), including the NFCC and supporting FRSs, suggested that building regulations should be updated to include further fire risk mitigations. The majority of these responses (20) were from the NFCC and supporting FRSs and listed additional measures such as ‘multiple staircases, evacuation lifts and refuge areas with communications’ which they said should be put in regulations. One response said sprinkler systems should be included and another called on government to make general updates to the regulations.

General comments agreeing that a toolkit would be a suitable resource

These responses (12), including the London Fire Brigade (although see above paragraph covering the issue ‘Does not go far enough’, which also refers to the London Fire Brigade’s response), agreed with the creation of a toolkit to support RPs in fulfilling their duties. Five responses argued that the toolkit would be vital for new RPs, who may be unfamiliar with the Fire Safety Order, to help them understand their duties. The seven other responses all said that the toolkit may be useful in assisting an RP in their duties.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) from the NFCC and supporting FRSs suggesting that government should guarantee costs would not be an obstacle for a vulnerable person to be secure and stay in their accommodation (20);

(ii) outlining initiatives that should be included in the toolkit. These include suggestions that the toolkit provide details of residents’ responsibilities such as the resident’s responsibility to self-identify (two); suggestions that the toolkit should cover the complete range of mixed-tenure buildings and be suitably comprehensive (two); suggestions that the toolkit should make clear what the government expects of RPs and other groups such as FRSs (two); and a suggestion that the toolkit guidance should be unambiguous (one);

(iii) saying they needed more information about the toolkit before passing judgement as to whether the toolkit would be a suitable resource for RPs (three);

(iv) from disability groups and charities asking to be involved in the formation of the toolkit (four);

(v) saying there should be a definition of what is ‘reasonably practical’ for landlords when making adaptions and adjustments (one);

(vi) and saying they supported PEEPs instead of a toolkit (one).

Question 3: Call for evidence – Are you aware of any initiatives that enhance the fire safety of mobility impaired residents, that could be considered for inclusion as case studies in the toolkit?

Table 7: Responses to Question 3

Awareness of any relevant initiatives	No. of responses	% of responses (n=122)
Yes	71	58%
No	51	42%

Question 3 (free-text section of question): If yes, please provide details below. If you disagree, please explain why. What alternative resources do you think could support RPs in this regard instead?

There were 92 responses to the free-text section of this question.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised are covered below, in order of prevalence.

Include fire suppression and detection systems in the toolkit

The most prevalent issue raised by responses to this question concerned fire suppression and/or other detection systems, with nearly a third of the responses (29) writing that fire suppression and/or other detection systems should be included in the toolkit. The majority of these responses (15) said they either wanted information on or were already installing misters and sprinkler systems. Four responses said they wanted to see suppression systems included more generally. A few responses (10) also wrote about including different detection systems in the toolkit, such as: enhanced detection through remote monitoring (four responses); tele-assisted systems where FRS can communicate to the residents (three responses); and/or visually/hearing impaired alarm systems such as strobe lighting and vibrating pillows (three responses).

NFCC Specialised Housing Guide

Some responses (28) pointed to the NFCC Specialised Housing Guide as a source to use for creating the toolkit. The responses (all of which came from the NFCC and FRSs, with the exception of one housing association) explained that the NFCC guide provided fire safety advice for vulnerable residents (such as those with sight, hearing or mobility impairments) by outlining various possible initiatives that could be considered.

Concern RPs will use toolkit as a minimum standard

Some responses (22), nearly all of which were the NFCC and supporting FRSs, wrote that they were concerned the toolkit would be treated as the minimum standard for the RP to fulfil their duties, instead of a toolkit of example case studies. The NFCC and supporting FRSs wrote that RPs would use the toolkit as a ‘benchmark’ and make assessments based on comparisons instead of individual needs (21 responses). The London Fire Brigade response wrote that the RP ‘needs clear instructions’ that the toolkit is only case studies.

PCFRAs

Some responses (13) said they either carried out or wanted information in the toolkit on PCFRAs. These responses said they conducted some form of PCFRA with one response saying it has led to PEEPs for the resident. One response suggested information should be included in the toolkit to help understand the content of a PCFRA for the resident.

Training and information sharing

A number of responses (11) wrote that the toolkit should include examples of training practices and useful frameworks for FRS/RP/resident interactions and information sharing. Some of these responses (four) said they were engaging with residents through PCFRAs or through other information collection initiatives; and others (three) said they have been engaging with FRS on information sharing with residents. Some of the responses (two) said they had carried out practice drills with family members. Two responses wrote that they offered training to residents and staff, with one respondent stating that they offered training on evacuation chairs.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses that:

(i) pointed to the National Fire Protection Association’s planning committee and guide in the USA as a resource to help inform the toolkit (nine);

(ii) called for the government to commit to the PEEPs proposals (three);

(iii) confirmed their support for the toolkit (two, one of which was from the Local Government Association);

(iv) suggested disability organisations and charities should be consulted on case studies for the toolkit (four);

(v) said everyone should have an evacuation plan no matter their situation (two);

(vi) asked if examples of how RPs dealt with residents’ tenure/status changes could be included in the toolkit (two);

(vii) suggested that the toolkit should not focus solely on physical impairments (three);

(viii) said that RPs should provide alternative accommodation for residents (one);

(ix) said the toolkit would not lead to systematic change in the sector (one);

(x) said costs and staffing should be taken into account for all the case studies included (two);

(xi) and promoted the use of PCFRAs and explained that they (the FRS) had helped with the use of heat detectors in high-risk areas to reduce the number of fire signals to FRSs.

Step 2: Identification of those needing support to evacuate

Questions 4 and 5 invited views and comments on the following proposal:

Step 2: RPs would be required to ask residents to make themselves known to the RP for their building if they consider they would need support to evacuate in the event of a fire.

Question 4: Do you agree or disagree that the proposed identification process laid out above i.e. the RP asking residents to self-identify (when resident first moves in, comms to all residents on an annual basis and via residents coming forward themselves outside of those times) strikes the right balance of responsibilities between an RP and an individual resident?

Table 8: Responses to Question 4

Strength of agreement/disagreement	No. of responses	% of responses (n=132)
Strongly agree	23	17%
Tend to agree	75	57%
Neither agree nor disagree	8	6%
Tend to disagree	12	9%
Strongly disagree	14	11%

Overall, 74% of participants agreed that the proposed identification process laid out (i.e. the RP asking residents to self-identify) strikes the right balance of responsibilities between an RP and an individual resident, 6% neither agreed nor disagreed, and 20% disagreed.

Question 4 (free-text section of question): If you disagree, please explain why and outline what your alternative approach would be.

There were 85 responses to the free-text section of this question.

It should be noted, free text was also provided within responses that had agreed or expressed a neutral view on the scale-response above.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised are covered below, in order of prevalence.

Accuracy of information

The most prevalent issue raised by responses to this question concerned accuracy of information, with 44 responses addressing the issue of ensuring information provided under the self-identification proposal is accurate. Of these 44 responses: many responses referred to how health is variable and conditions which may affect a person’s ability to evacuate are subject to change (26); many responses, including the NFCC and supporting FRSs, said that annually may not be frequent enough to ensure that information is kept up to date (30); and a few responses referred to the issue of subletting (seven), which means that RPs do not have a relationship with occupants and would therefore be unable to engage them in the self-identification process, impacting information accuracy.

Data sharing by third parties

A group of responses (29), including the NFCC and supporting FRSs, suggested that increased data sharing between third parties should be explored as part of the identification process. These responses said that agencies who regularly interact with residents (such as local authority care providers) should be linked into the identification process.

Burden

Some responses (18, which included four responses from disability groups, four responses from housing associations or housing association groups/representatives, and a response from a cladding campaigning group) raised the issue of where the burden of identification should sit. There was a divergence in views under this theme. Seven responses said that placing the burden on residents to self-identify was not the right approach as there was a concern this could absolve the RP of their duties. Seven responses agreed that self-identification by residents was the most appropriate approach and felt the emphasis on self-identification did strike the right balance of responsibilities.

Accessibility

Some responses (14, six of which came from disability groups) said it was important to ensure that communications and the process for self-identification are accessible. Responses proposed a range of ways in which the process needed to be accessible, including the use of multiple channels, a range of languages or using plain English. Some responses also suggested that a mechanism which allows another person to act on behalf of the resident should be put in place. Two responses said the tone of communications needs to be considered.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses that:

(i) expressed agreement to the approach (five);

(ii) and made suggestions on the best way for RPs to engage with residents, arguing that communications should not refer to costs or negative consequences but rather should emphasise that health data would not be shared and give examples of how someone may struggle to self-evacuate (one).

Question 5: Do you have any additional comments on the proposed identification process as laid out in step 2 above?

There were 99 responses to this free-text question.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question covered issues raised under Question 4, in particular: data sharing by third parties (24 responses); ensuring accuracy of information (10 responses); where the burden of identification would lie (seven responses, with the majority saying there was a need for the RP to be actively engaging with residents, and three responses which felt the burden should sit with the resident); and five responses arguing that the process and communications need to be accessible, such as ensuring clear language usage, considering language barriers and considering levels of literacy.

Step 3: Person-Centred Fire Risk Assessment checklist

Questions 6, 7 and 8 invited views and comments on the following proposal:

Step 3: For those who self-identify as needing support to evacuate, the RP would be required to offer a Person-Centred Fire Risk Assessment (PCFRA) checklist and connect them with a Home Fire Safety Visit (HFSV) from the local FRS, in order to establish the fire safety risks present and whether there are any measures that could be introduced to mitigate those risks.

Question 6: Do you agree or disagree that this approach is a viable way to identify fire safety risks, including barriers to evacuation?

Table 9: Responses to Question 6

Strength of agreement/disagreement	No. of responses	% of responses (n=130)
Strongly agree	16	12%
Tend to agree	70	54%
Neither agree nor disagree	14	11%
Tend to disagree	19	15%
Strongly disagree	11	8%

Overall, 66% of participants agreed that this approach is a viable way to identify fire safety risks, including barriers to evacuation, 11% neither agreed nor disagreed, and 23% disagreed.

Question 6 (free-text section of question): If you agree, whilst viable, are there still issues to consider in implementing this approach? Please give details. If you disagree, please explain why and outline what your alternative viable approach would be.

There were 112 responses to the free-text section of this question.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised are covered below, in order of prevalence.

Training and expertise

A significant theme emerging from responses to this question centred on who completes the PCFRA and whether training is needed, with many responses (49) concerned as to whether the RP has the relevant expertise to complete a PCFRA.

Some responses (26), including the NFCC and supporting FRSs, said that the PCFRA should be undertaken by those with expertise in both fire evacuation and disability/impairment. Other responses (17) said that training should be given to RPs and one said that this needs to be conducted in a systematic way. This links to a related theme around quality assurance, with a number of responses (eight) saying there is a need to ensure that the process is consistent and accurate, and a suggestion made for an accreditation scheme for those carrying out PCFRAs.

Supportive of approach

Many responses (34) expressed support for the approach set out under this proposal. The majority of these responses (20), including the NFCC and supporting FRSs, said that a PCFRA is a viable way to identify fire safety risks, including barriers to evacuation, for the individual and could be further supported by a Home Fire Safety Visit (HFSV)^{[footnote 7]} from FRSs.

In-flat measures

A number of responses (10) critiqued the use of a PCFRA, saying that PCFRA checklists (or other risk assessment checklists) relate to in-flat measures as opposed to issues in communal areas. These responses said that the current PCFRA templates are based on reducing the risks from fire within the home and do not consider the risk to residents from a fire elsewhere.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) commenting on the costs to FRSs with concerns regarding the capacity of FRSs to adopt this process, specifically in relation to the capacity of FRSs to carry out the required HFSVs (nine);

(ii) highlighting the need to quality assure the information (eight);

(iii) commenting on the costs to the RP with concerns regarding the capacity of RPs to adopt this process (seven);

(iv) commenting on costs potentially being incurred by residents but noting that more substantial costs should be supported;

(v) discussing where the burden of responsibility sits, with most concerned this would place a burden on FRSs and one saying that residents, RPs and FRSs have a shared responsibility (four);

(vi) suggesting greater efforts should be made to ensure individuals are rehoused in more suitable accommodation (four);

(vii) and concerned that making reasonable adjustments could negatively impact other residents’ use of the building.

Question 7: Do you agree or disagree that this approach is an adequate way to identify suitable measures to mitigate against fire safety risks, including barriers to evacuation?

Table 10: Responses to Question 7

Strength of agreement/disagreement	No. of responses	% of responses (n=126)
Strongly agree	13	10%
Tend to agree	66	52%
Neither agree nor disagree	11	9%
Tend to disagree	17	13%
Strongly disagree	19	15%

Overall, 63% of participants agreed that this approach is an adequate way to identify suitable measures to mitigate against fire safety risks, including barriers to evacuation, 9% neither agreed nor disagreed, and 29% disagreed.

Question 7 (free-text section of this question): If you agree, whilst adequate, are there still issues to consider in implementing this approach? Please give details. If you disagree, please explain why and outline what your alternative adequate approach would be.

There were 102 responses to the free-text section of this question.

It should be noted, free text was also provided within responses that had expressed a neutral view on the scale-response above.

Many of the key issues emerging from this question are the same as those raised by Question 6, but with the additional topic of enforcement. For discussion of these key issues, with the exception of enforcement, see Question 6.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question and not covered by Question 6 are detailed here.

Enforcement

Some responses (36, four of which came from disability groups) raised the issue of how the completion of a PCFRA would be enforced. Many of these responses (27), including the NFCC and supporting FRSs, asked how the implementation of a PCFRA’s findings can be evidenced or assured, and how this process can be enforced. Five responses said that there is little benefit to identifying risks and mitigation measures if there is not a clear duty to implement them. Three responses said there is no provision under these proposals for the RP to evidence that they have engaged with residents and considered all options in order to demonstrate due diligence. One response said that there needs to be a robust process to ensure that an RP meets the requirements placed on them. Another response argued that RPs would not have a suitable level of knowledge regarding evacuation and mitigation measures.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) commenting on the cost and resource implications for both RPs and FRSs (four). Some said that additional resources would be required to complete the assessments and, in cases where RPs do not have in-house competency, resources would be needed to upskill staff or outsource this process. One response also said that the increased use of PCFRAs would increase demand for HFSVs, which would have a resource implication for FRSs;

(ii) discussing accuracy of information (four). Responses cited issues with change-over of tenants and not making the managing agent aware of changes, and the need to review the information for new residents was also raised as an issue;

(iii) saying that an issue would be how the RP notifies the local FRS about their PCFRA(s) and the individual(s) identified, and that there needs to be close partner working (one);

(iv) and arguing that HFSVs do not take into account protection work and are not equivalent to evacuation strategies, and that FRSs are not responsible for producing such evacuation strategies.

Question 8: Do you foresee any issues with the provision of a PCFRA checklist (by the RP) AND the provision of a Home Fire Safety Visit from the FRS?

There were 107 responses to this free-text question.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised are covered below, in order of prevalence.

FRS resources

The most prevalent issue raised by responses to this question concerned FRS resources. Many responses (49), including the NFCC and supporting FRSs, made reference to FRS resources and identified potential implications that the PCFRA process would have for FRSs. The responses from the NFCC and supporting FRSs stated: ‘the approach to information sharing and PCFRAs may lead to an increase in HFSV and S&WV, particularly for London Fire Brigade, whose service area includes the highest number of buildings that have reverted to a temporary simultaneous evacuation strategy. More staff may be needed to undertake visits, which may not always be immediately possible due to existing staffing burdens, and there may not be sufficient staff in place with the requisite competencies’. Responses questioned how this extra responsibility would be funded and said there would be a delay between the PCFRA and the HFSV taking place due to the anticipated volume of requests for HFSVs.

Crossover between PCFRAs and HFSVs

Some responses (38) discussed the crossover between PCFRAs and HFSVs. Most of these responses (33), including the NFCC and supporting FRSs, suggested that there would be some duplication between the two tools. Five of these responses said that the PCFRA is a more in-depth, comprehensive assessment than a HFSV and that there may not be a need for a HFSV if a PCFRA is done correctly.

It is worth noting, however, the earlier reservations expressed about PCFRAs by some of the responses to Question 6, namely: the 49 responses concerned about whether the RP has the relevant expertise to complete a PCFRA; and the 10 responses that critiqued the use of a PCFRA on the basis that PCFRA checklists (or other risk assessment checklists) relate to in-flat measures as opposed to issues in communal areas.

Also relevant are responses to Question 8 which said that: there could be an issue where there is a disagreement between the findings of a PCFRA and HFSV, and in such cases there is a danger that a resident may be given conflicting advice (four responses); and messaging between the two tools needs to be co-ordinated and agreed, unless there are fundamental differences (one response).

Burden

Some responses (32) raised the issue of the burden and where liability would sit under this process.

The majority of these responses, including those from the NFCC and supporting FRSs (27), said that a PCFRA would initiate a HFSV by the FRS and, by linking the PCFRA to a HFSV, it could transfer responsibility to FRSs. These responses said that RPs should not be encouraged to direct residents to the FRS as this could create a misunderstanding on the part of RPs as to their responsibilities. These responses called for clarity on the role of the RP and the role of the FRSs within this process.

Two responses said that any approach must be taken in a holistic way which does not place responsibility on FRSs. One response said that the process placed burdens on residents and two responses said that the burden needs to fall to the RP.

Information sharing

Some responses (28) referred to the importance of data sharing between relevant stakeholders. The majority of these responses (23), including the NFCC and supporting FRSs, said that the HFSV and S&WV should act as the start of a signposting process involving numerous other stakeholders.

Consistency in HFSVs

Some responses (26), including the NFCC and supporting FRSs, raised a potential lack of consistency in the completion of HFSV as an issue. These responses said that the HFSV process is not standard across the UK and varies from FRS to FRS, and some FRSs will undertake HFSVs while others will undertake a Safe and Well Visit (S&WV).

Quality of information

A number of responses (17) questioned the quality of information that could be collected under this process. A range of different reasons were given for this: non-cooperation from individuals (three responses); the ability of residents to provide accurate information due to cognitive difficulties (two responses); residents providing false information (two responses); residents being unwilling to provide information (one response); and high turnover of residents (one response). Two responses also said they had experienced poor record keeping by FRSs from HFSVs.

Training and expertise

The issue of training and expertise was raised by a small number of responses (15). This issue was also raised in responses to Questions 6 and 7. See Question 6 for the discussion of this issue.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) highlighting UK General Data Protection Regulation (UK GDPR) and the need for appropriate data sharing agreements to be put in place (three);

(ii) arguing that HFSVs complement a PCFRA approach (four);

(iii) and saying the PCFRA and subsequent HFSV by the FRS dovetail well together (one).

Step 4: Sharing information with local FRS

Question 9 invited views and comments on the following proposal:

Step 4: For those mobility impaired residents where there are still issues preventing them from self-evacuating in the event of a fire, the RP would be required to share the residents’ details with their local FRS.

Question 9: Do you agree or disagree that this approach is sufficient to allow the FRS to execute an emergency evacuation, if required?

Table 11: Responses to Question 9

Strength of agreement/disagreement	No. of responses	% of responses (n=126)
Strongly agree	16	13%
Tend to agree	28	22%
Neither agree nor disagree	13	10%
Tend to disagree	17	13%
Strongly disagree	52	41%

Overall, 35% of participants agreed that this approach is sufficient to allow the FRS to execute an emergency evacuation, if required, 10% neither agreed nor disagreed, and 55% disagreed.

Question 9 (free-text section of this question): If you disagree, please specify what further information should be required. If this is personal information, how do you propose it is kept secure?

There were 102 responses to this free-text question.

It should be noted, free text was also provided within responses that had agreed or expressed a neutral view on the scale-response above.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised are covered below, in order of prevalence.

Additional information should be included

The most prevalent issue raised by responses to this question concerned including additional information. These responses (42, four of which came from disability groups) said there is a need for additional information to allow the FRS to execute an emergency evacuation. Such additional information included: the physical characteristics and nature of the resident’s impairment, including specific risks; specialist equipment required by the resident, both to aid evacuation and sustain the resident; the medication and/or treatment which must be maintained; and access to Firelink mobile data terminals.

How the format to record information should be standardised

Some responses (32) included suggestions on a standardised format to record information: the majority of these responses (24), including the NFCC and supporting FRSs, suggested the use of clear and simple English and a user-friendly approach to information recording; a small number of responses (five) suggested the use of a common template or standardised information, but did not provide specific examples of what this could look like; and a small number (four) suggested a coding or banding system when recording information which would capture the priority for evacuation.

The challenges of information sharing between the RP and FRSs

Some responses (32) discussed the challenges of information sharing between the RP and the FRS: the majority of these responses (25), including the NFCC and supporting FRSs, said that there could be capability issues with the FRS when it comes to maintaining a digital infrastructure for receiving and storing information; most of these responses (24), including NFCC and supporting FRSs, also raised concerns that these proposals place responsibility on the FRS to ensure information is kept up to date; and three responses said that there could be challenges for the RP in keeping the information shared with the FRS up to date.

Views on digital information sharing

A number of responses (22, three of which came from disability groups) expressed views on digital information sharing: the majority of these responses (10) supported digital information sharing because it is easier and quicker to update than physical information in a secure information box, although one response disagreed and argued that physical information is easier to keep updated; four responses said that digital information is harder to compromise than physical information, with one response suggesting that residents could be more willing to provide relevant information if they knew it was held digitally and therefore more securely; three responses supported digital information sharing as it allows the FRS to review information before arriving at the scene of a fire.

Views on storing information in a secure information box

Of the small proportion of responses (13, two of which came from disability groups) that expressed views on storing information in a secure information box: most of these responses (seven) said that there are security risks to storing information in a secure information box, with a risk of unauthorised people gaining access to this information and using it for a variety of non-intended purposes; and three responses said the requirement to install a secure information box is only applicable for residential buildings over 18 metres and that this should not be the case, with one response saying this requirement should be for residential buildings over 11 metres.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) saying that they wanted clarity on what a resident is expected to do while waiting for the FRS to rescue them (23, including the NFCC and supporting FRSs);

(ii) saying that they wanted further independent research into evacuating multiple residents who require assistance at the same time, with building design strengthened as a result (23, including NFCC and supporting FRSs);

(iii) and that expressed views on the provision of information from residents to RPs (eight). Three of these responses said there were potential issues with residents not updating the RP of changes to their own information. The other responses expressed: a concern that tenants may change and the RP would not be made aware; a concern that residents may not update the RP if the resident has children with additional evacuation needs or short term visitors with additional evacuation needs; a concern that some residents may not be able to provide the RP with information in the first instance due to a communication barrier or cognitive impairment; and a view that residents should be able to update their information directly without informing the RP.

(iv) Singular responses included views that: there is inadequate regulation for sprinklers in residential buildings; there is inadequate regulation for fire-fighter safety, particularly with breathing apparatus; making all buildings adequate for a stay put strategy negates the need for this proposal; all buildings should have a simultaneous evacuation strategy; there should be refuges in all residential buildings; information should make clear this concerns emergency evacuations only as FRSs are not by default an evacuation service; and NFCC guidance should be followed regarding the information required in secure information boxes.

Step 5: The FRS access and use this information in the event of a fire

Questions 10 and 11 invited views and comments on the following proposal:

Step 5: If called to an incident in a building with a simultaneous evacuation strategy in place, the FRS would have the information described in Step 4 available to them very soon after arrival (if in a secure information box), or to review in advance of arrival (if shared digitally).

Question 10: What are your views on the use of the information by FRSs, including to support the emergency evacuation of mobility impaired residents?

There were 130 free-text responses to this question.

Details of the various issues raised are covered below, in order of prevalence.

Supportive of FRSs having information

The most prevalent issue raised by responses to this question concerned being supportive of FRSs having information. Over a third of responses (49) either supported or agreed that FRSs’ access to this information could help assist in evacuation and management. Most of these responses (26), including the NFCC and supporting FRSs, wrote that the information had the potential to be beneficial to FRSs, many responses (20) said the information sharing was reasonable and appropriate, and three responses considered the information useful and good for strategic planning.

Information detail

47 responses discussed details concerning information. Some responses (39) wrote about what the information shared with FRSs should include. Of these 39 responses: the majority (28), including the NFCC and supporting FRSs, said that they needed the flat/floor numbers with additional information on the impairment, equipment required and language barriers; a few (six) said the FRS needs enough information to facilitate for the resident’s evacuation; a few (three) suggested using a simple coding system (e.g. Red Amber Green, or RAG rating system) to allow the FRS to prioritise the situation quickly; and a couple (two) suggested the PCFRA should be made available to the FRS on arrival.

Beyond these 39 responses, there were also a number of responses (five) that raised concerns about GDPR issues in terms of getting and storing information, as well as a few responses (three) that suggested an opt-in approach for residents.

Storage and management

Over a third of responses (46, which includes five responses from disability groups) wrote about how the information should be managed and stored to effectively help the FRS. Some responses (17) wrote about the importance of making sure data is refreshed and kept up to date. Some responses (15) said the information should be stored digitally with the FRS being able to access it with ease during an emergency. A number of responses (eight) suggested the information should be stored on site in a secure information box for the FRS to access, and conversely two responses had concerns about storing information on site (due to the potential for theft/vandalism). There were also two responses that said Disclosure and Barring Service checks would be needed and two responses that thought the information would not be publicly available.

Liability and resources

A little under a third of responses (39) raised concerns about liability and the capacity of FRSs to facilitate evacuation. The majority of these responses (30), including the NFCC and supporting FRSs, wrote that it opened FRSs up to liability issues if evacuation was unsuccessful and that additional training and development may be required to facilitate the specialist equipment. A number of responses (nine) also said that there was a lack of staff, equipment and training to support evacuation.

‘Mobility impaired’ scoping

Some responses (33) wrote that the scope of the consultation should not be restricted to those with physical/mobility impairments and that EEIS+ should cover any individual who may require assistance in an evacuation.

It is worth reiterating that all references to ‘mobility impaired residents’ in both the EEIS+ consultation and in this response include any condition that would affect an individual’s ability to evacuate in the event of a fire and would include, for example, those with hearing, sight and cognitive impairments. Responses commenting on ‘mobility impaired’ scoping seem to have missed how the term ‘mobility impaired’ was defined in the EEIS+ consultation.

Concern over timescales

Some responses (32) questioned the consultation’s timescales identified for FRSs to carry out an evacuation. The majority of these responses (29) are from the NFCC and supporting FRSs, who noted the timescale given was the average time for the first vehicle to get to the building. NFCC and supporting FRSs said they would need more personnel and more vehicles to facilitate evacuation and combat the fire; consequently, it could take ‘more than 20 minutes before a sufficient number of firefighters are on site to ensure safe systems of work are in place allowing crews to begin simultaneously fighting the fire and evacuating any residents in need of assistance’. A few responses (three) also noted that the timescale was for an urban-based FRS and that timings may vary depending on local geography.

Psychological impacts and warning systems

Responses from the NFCC and supporting FRSs (26) wrote that, if FRSs were to facilitate evacuation, there would be a need to consider the psychological impact on fire officers who have to carry out these evacuations. They also wrote that there is need to include ‘a warning mechanism within the PEEP or PCFRA process’ to let the resident know when they have to evacuate.

FRS assistance in evacuation and Article 50 guidance

A number of responses (18, two of which are from disability groups) commented on the role of the FRS in evacuations or commented that the proposal contradicts guidance under Article 50. Some responses (11) said that FRSs should not be depended on to facilitate evacuation, writing that the FRSs’ main priority is to put out the fire. Some other responses (seven) said the proposal would be in contradiction with Article 50 guidance as evacuation should be possible without the assistance of the FRS.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that argued there should be better designed buildings and EEIS+ should not be restricted to high-risk buildings but should cover all building types (five);

(ii) that wrote the decision to evacuate a building is one which only the FRS can make (four);

(iii) concerned about the FRS having to prioritise resources and the provision of survival advice (four);

(iv) that wanted clear definitions and distinctions on the differences between ‘emergency evacuation’, ‘evacuation’ and ‘rescue’ (three);

(v) that made further calls for the government to move forward with PEEP legislation instead of EEIS+ (two responses, although note also the 168 pieces of correspondence responding to the 2021 PEEPs consultation response mentioned on page 9 above);

(vi) that said its residents would look to evacuate immediately regardless of evacuation strategy (one);

(vii) and suggested that clear information needs to be given to residents on their building’s policy and calling 999 in a fire (one).

Question 11: Do you have any additional comments on the EEIS proposal as laid out in Steps 2 - 5 above?

There were 103 free-text responses to this question.

Many of the key issues emerging from this question are the same as those raised in responses to other questions. In such cases, these comments have been included in the write-up for the relevant questions. Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised that are specific to this question are covered below, in order of prevalence.

The proposals do not go far enough

A number of responses (31), including the NFCC and supporting FRSs, said that the proposals in the consultation do not go far enough to meet the Grenfell Inquiry recommendations. The NFCC said: ‘these proposals represent a first step in laying out how to identify residents who may be in need of assistance to evacuate their building in the event of a fire. However, more must be done to ensure that RPs undertake their responsibilities in a more suitable and sufficient manner than simply providing a toolkit to guide them. Responsibilities should be mandated and criteria established that could result in a PEEP being developed’.

Sprinklers

A little over a quarter of responses (27), including the NFCC and supporting FRSs, advocated sprinklers. The responses said that sprinkler systems represent a cost effective and proportionate safety enhancement both in new buildings and when retrofitted, and that sprinklers have been evidenced to be 99% effective in extinguishing or controlling a fire. Two responses said that consideration should be given to mandating the retrofitting of sprinklers in high-rise buildings above 18 metres in height. One argued that there should be greater emphasis on the mandatory installation of fixed installations such as sprinklers in all premises that fall under the scope of the Fire Safety Order, in particular in high-rise residential premises.

Reviewing information

Some responses (25), including the NFCC and supporting FRSs, said steps 2-5 should be reviewed by the RP as soon as practicable if the resident indicates a change in circumstances. This should be done to mitigate the risk of the changes to circumstances going unnoticed because residents have not updated their RP.

Remediation

Some responses (24), including the NFCC and supporting FRSs, questioned what would happen when remediation of a building occurs. These responses said that the current proposals do not provide detail on what is expected of RPs or residents who have self-identified in cases where a building operating with a simultaneous evacuation policy is returned to a stay put strategy once remediation work is completed. The responses argued that the restoration of a stay put strategy after the completion of remediation work is a positive step. The responses argued, however, that removing any additional safeguards put in place could be viewed as an unnecessary step backwards because a resident’s potential barriers regarding evacuation are not necessarily removed with a change in evacuation strategy. One response said that guidance was needed to include an exit strategy as EEIS+ should be a short-term requirement for buildings with a temporary simultaneous evacuation strategy.

Enforcement

Some responses (21), all from the NFCC and supporting FRSs, expressed concern that the implementation of EEIS+ could undermine FRSs’ ability to assess and enforce the Fire Safety Order in a range of other regulated premises, such as care homes. The NFCC said: ‘It is vital that, where necessary, FRSs continue to have the powers to ensure that RPs meet their respective fire safety duties under the FSO [Fire Safety Order] to protect the most vulnerable members of society and other relevant persons. We hold concerns that allowing evacuation to be viewed as the responsibility of the FRS, to any degree, would dilute or, if not, frustrate the existing ability of FRSs to hold RPs to account for the provision of suitable and sufficient evacuation procedures elsewhere. For example, whether providers of care services in the future may seek to challenge FRS powers to require certain staffing levels, on the basis of lesser requirements in other premises’.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that focussed on prevention, arguing removal from danger is a last defence and carries risks of its own, and that there is a need to ensure tenants are properly protected in the first place (three);

(ii) that discussed the use of third-party assistance, arguing neighbour assistance could be made to work although there are issues that need to be considered before it can be introduced (three);

(iii) that said more needed to be done to ensure RPs undertake their responsibilities, that responsibilities should be clearly identified and mandated in law, and that the provision of guidance or a toolkit is likely to be insufficient in bringing about real change (two).

Additional proposal

While not part of the EEIS+ proposals, some stakeholders suggested the provision of an on-site member of staff in some buildings in addition to the EEIS+ proposals. Question 12 invited views and comments on this additional proposal.

Question 12: Do you agree or disagree that the addition of this on-site individual adds enough value to the EEIS proposal to justify the associated costs?

Table 12: Responses to Question 12

Strength of agreement/disagreement	No. of responses	% of responses (n=123)
Strongly agree	1	1%
Tend to agree	4	3%
Neither agree nor disagree	47	38%
Tend to disagree	31	25%
Strongly disagree	40	33%

Overall, 4% of participants agreed that the addition of an on-site individual adds enough value to the EEIS proposal to justify the associated costs, 38% neither agreed nor disagreed, and 58% disagreed.

Question 12 (free-text section of this question): Do you agree or disagree that the addition of this on-site individual adds enough value to the EEIS proposal to justify the associated costs?

There were 101 free-text responses to this question.

Any responses which detailed recurring themes are set out in the Recurring themes section on page 56; responses specific to this question are detailed here.

Details of the various issues raised are covered below, in order of prevalence.

The value added by an on-site individual

The most prevalent issue raised by responses to this question concerned the lack of material value being added by the on-site individual. Nearly half of the responses (49, 24 of which are from the NFCC and supporting FRSs, and five of which are from disability groups) questioned how much value is added by having one on-site member of staff. Responses said that other measures already present in the building, such as a Waking Watch or fire alarm, may already cover the responsibilities of the on-site individual. Responses also said that the on-site staff member did not add any value unless they physically assisted in an evacuation.

Decision to have an on-site individual should be part of the FRA

Some responses (37) argued that the decision as to whether an on-site individual is needed should be part of a wider fire risk assessment. Some responses (28, 24 of which are from the NFCC and supporting FRSs) suggested that the decision to have this on-site staff member should be made when conducting the fire risk assessment for the building. There is further support for this as nine responses referred to the need to be proportionate and to look at the scope of buildings when deciding whether to have an on-site staff member, and highlighted that it may be cost proportionate in large buildings but not in smaller ones.

Information sharing and engagement

Many responses (36, 24 of which are from the NFCC and supporting FRSs) suggested that some of the on-site staff individual’s responsibilities could be covered by engaging with residents and sharing resident information with FRSs (providing the information physically in a secure information box and/or sharing the information digitally). Some of these responses (six) considered that sharing information with FRSs effectively replaced the need for an on-site staff individual. A couple of these responses (two) emphasised the need for an online version of a secure information box that the FRS could access.

Too expensive

Many responses (36) said that having an on-site staff member would be too expensive. Responses were concerned that this cost would be passed on to residents and the total cost of hiring the staff member full-time would outweigh any benefit. Six of the 36 responses highlighted that a further burden to landlords and costs for residents could be added by on-site staff potentially needing a workspace/accommodation to carry out the role.

The on-site individual could potentially be beneficial

Some responses (29, 25 of which are from the NFCC and supporting FRSs) thought there could be some merit in having an on-site staff member in certain circumstances if they were trained appropriately. However, only one response fully supported the proposal on the basis that, while recognising the cost would be significant, they felt the benefit of this role in an emergency situation would outweigh the costs.

The on-site individual’s duties replicate existing duties for the RP

Some responses (25), all of which are from the NFCC and supporting FRSs with the exception of one response from a housing association, expressed the view that the on-site individual’s duties outlined in this proposal replicate existing duties for the RP under the Fire Safety Order and the Building Safety Act 2022. The implication of these responses appears to be that RPs should already be carrying out the proposed on-site individual’s actions.

Alternative options

Some responses (17) argued that alternative options should be considered. A number of these responses (11) suggested that the money spent hiring the on-site staff member could be used for other measures to fulfil the same responsibilities at a lower overall cost. Some of these responses suggested the money could be invested in detection and suppression systems, or suggested putting the money towards equipment such as evacuation chairs. A further six responses said the building could use ‘neighbours or buddies’ instead of the on-site staff member to also help with evacuation.

Existing staff training and sharing

A number of responses (11) proposed that current staff could be trained to take on some or all of the necessary responsibilities as opposed to hiring new staff, with one of these responses suggesting that staff could be shared among buildings to help reduce costs.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that found the question to be unclear as to what was meant by ‘some buildings’, namely, whether this solely refers to temporary simultaneous evacuation buildings or refers to all buildings (25, 24 of which are from the NFCC and supporting FRSs);

(ii) that said they did not want the costs of this or any other interim measures put onto leaseholders (10);

(iii) and said their preference was to have PEEPs instead of EEIS+ (three).

Calls for evidence

Question 13: Call for evidence

We are interested in examples of PEEPs in residential buildings, but which fully or partially avoid the concerns over safety, proportionality and practicality. Therefore, can you provide examples of existing PEEPs for residential buildings, agreed between resident and RP, that provide for evacuation from a building, that at least partially:

• avoids the staffing up of buildings to enact the PEEPs;

• avoids the liability issues for RPs and third parties who are enacting the PEEPs such as friends or neighbours;

• avoids the safety issues in enacting them e.g. the blocking of stairwells.

There were 64 free-text responses to this question.

Details of the various issues raised are covered below, in order of prevalence.

No examples of PEEPs

A little under a third of responses (18) expressly said that they did not have any examples of a PEEP which fully or partially avoided the concerns over safety, proportionality and practicality.

Examples of PEEPs

Some responses (16, which includes a response from a disability group) included what was, in their view, an example of a PEEP which they felt fully or partially avoided the concerns over safety, proportionality and practicality. These examples were provided by a range of stakeholders including individuals, housing associations, organisations from the fire sector including FRSs and a disability group.

These examples included: the recording and storing of information on residents who would require support in an evacuation; home visits and/or completed PCFRAs; staff, carers and/or neighbours being utilised as part of a PEEP; staff, carers and/or neighbours being trained to use equipment as part of a PEEP; and equipment such as evacuation chairs and a specialist smoke detector with a flashing beacon and vibrating pad.

While one response noted the distinction between a PCFRA and a PEEP, two responses (both from housing associations) made little distinction between a PCFRA and a PEEP. One of these housing associations said that PEEPs/PCFRAs are completed where necessary with information stored for FRSs’ use in buildings’ secure information boxes and noted that the implementation of these PEEPs/PCFRAs relies on the FRS. The other housing association described their PEEPs process as one in which relevant residents are identified and referred, with a visit arranged, and then a recorded conversation held and reviewed; they explain that simple cases require a telephone conversation whereas complex cases require home visits, with particularly complicated cases requiring a home visit from the FRS.

Evacuation chairs were discussed by some responses. One of these responses was from a company that provides evacuation chairs and it argued that the implementation of EEIS+ will prevent the proper use of an evacuation chair. Another response was from a carer who argued the case for evacuation chair installation and believed it would meet the criteria given in this question, but said their building’s managing agent had rejected the purchasing of evacuation chairs.

One disability group described an example of a PEEP in which an evacuation chair was purchased, and paid carers and neighbours were given training on how to use the chair; when a fire occurred, a paid carer transferred the disabled resident into the evacuation chair and took them down several flights of stairs until they were past the level of the fire; this evacuation took place before the FRS arrived at the building.

Another response provided a template of their PEEP form. The template:

• shows the type of information gathered (such as whether the means of raising the alarm is inclusive of the resident’s needs, e.g. a fire drill that relies on hearing an alarm is not inclusive of deaf residents);

• explains that the information must be reviewed annually or under specific circumstances detailed on the form (e.g. if a resident’s health changes);

• flags that training may be required in the use of necessary equipment;

• explains that the PEEP form should be shared among all relevant parties;

• and says the PEEP should be practised at least biannually.

Of these 16 responses, only two could, for a very specific scenario, demonstrate that it fully or partially addressed the concerns over safety, proportionality and practicality. One response provided an example of a resident who was mobile and could self-evacuate but required a bespoke alert system to inform the resident of the need to evacuate. The other response provided an example that involved an evacuation chair but it did not specify what floor it was on or whether staff were required to operate it.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that did not answer the question directly but instead stated broader concerns regarding the EEIS+ proposals (22). 20 of these responses came from the NFCC and supporting FRSs, and these responses said the EEIS+ proposals only highlighted barriers to residents with mobility impairments, and that the government is assuming residents with other impairments would be able to evacuate without any additional measures once aware of a fire. Of the other two responses, one argued that the government should focus on PEEPs as opposed to EEIS+ and the other argued that there was not enough guidance currently available for PEEPs;

(ii) that called for further stakeholder engagement and research on PEEPs and EEIS+ (21). 19 of these responses came from the NFCC and supporting FRSs and these responses welcomed the proposal to set up a working group with housing providers, disability groups and other key stakeholders to explore these issues and how they might be solved in the longer term;

(iii) that said they had cost and resourcing concerns on the implementation of PEEPs (two);

(iv) and singular responses, including: an example of a ‘disabled’ lift with a generator and automatic opening front door (it was not clear whether this lift could be used during a fire); a concern over a lack of FRS input into the 2021 PEEPs consultation; a view that interim measures in a building while it has a temporary simultaneous evacuation strategy in place have been used in lieu of a PEEP; and a view that maintaining buildings to a high safety standard would negate the need for PEEPs in the first place, i.e. the stay put policy is safest.

Question 14: Call for evidence – We are also interested in examples of buildings where staff have been installed on-site to support the enacting of PEEPs or other fire safety initiatives (outside of waking watch). Are you aware of any such examples?

There were 28 free-text responses to this question.

Details of the various issues raised are covered below, in order of prevalence.

Examples of buildings where staff have been installed on site to support the enacting of PEEPs or other fire safety initiatives

Nine responses provided examples of buildings where staff have been installed on site to support the enacting of PEEPs or other fire safety initiatives.

Of these nine responses providing examples of staffing to enact a PEEP: five appeared to utilise social or care workers in a general needs residential building, with three of these responses confirming that there was a 24/7 staff presence; two referred to the use of staff in specialised residential care buildings; one example utilised specialised staff in a special needs school which was staffed at all times during hours of operation; and one response said they had an example of a building where staff have been installed on site to support the enacting of PEEPs but provided no additional detail to allow further investigation.

Four of the nine responses which provided examples of staffing to enact a PEEP also highlighted staffing issues. Three of these responses were from disability groups. These three responses were identical and said that 24/7 on-site staff are present to sit outside a ‘disabled resident’s flat’, that the staff have not been trained on how to safely ‘handle’ the resident and the managing agency has had no discussion with the resident with regards to this provision. Additionally, these responses state that ‘the agency relationship […] means there will be little chance of securing continuity of staff trained to assist [the resident]’. The fourth response said that, as a social care provider, it could ‘be a battle with social services commissioners to ensure we have enough people onsite overnight’.

No examples of buildings where staff have been installed on site to support the enacting of PEEPs or other fire safety initiatives

There were a number of responses (nine, four of which were from housing associations and four of which were from FRSs) that said they had no examples of buildings where staff have been installed on site to support the enacting of PEEPs or other fire safety initiatives. In the case of housing associations, they did not operate any such buildings like this themselves and did not refer to any buildings beyond their responsibility. Three FRSs said that they did not have any examples or otherwise were not aware of any such buildings. One FRS mentioned a case where staff were in place within a building to assist with evacuation in the event of an alarm sounding, but stressed that this was an interim measure put in place due to compartmentation issues being identified in the building; once the building’s staircase was upgraded in terms of its compartmentation, the interim measure of having staff assist with evacuation was withdrawn.

Examples of buildings where staff have been installed on site but not to support the enacting of PEEPs or other fire safety initiatives

Four responses provided an example of buildings where staff have been installed on site but did not say that that the staff are on site to support the enacting of PEEPs or other fire safety initiatives.

Two of these responses referred to general concierge staff present in the building. While neither of these responses confirmed whether concierge staff were present 24/7, the responses related these examples to concerns around fire safety or the potential need to evacuate. One response explained that the buildings with concierges had emergency voice communication systems in place so that those who required assistance could call from the stair-cores; the other response explained that, where they had concerns about a building, concierge hours had been extended ahead of type 4 fire risk assessments or external wall system surveys being conducted.

Of the other two responses, one response said that, while there were staff present 24/7 on site who ‘are required to carry out and review PEEPS’, the ability of on-site staff to help residents evacuate was limited and the expectation was for all residents to self-evacuate. The other response said that there were staff present 24/7 on site in their building, but the managing agent had specifically instructed them not to assist in the evacuation of residents. This response did not say why managing agents had given this instruction. The response did say, however, that in general terms managing agents were keen to avoid responsibility and associated liability issues. The response argued that RPs have used the Local Government Association guide, the government response to the 2021 PEEPs consultation, the consultation position on the section 36 consultation^{[footnote 8]} as ‘reasons not to do PEEPs’.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that argued that the call for evidence is unclear as to whether it refers to evacuation management or concierges in a general needs block of flats as opposed to duty staff at specialised housing or a ‘live in’ carer for an individual with vulnerabilities within an independent living scheme (two responses, both from FRSs);

(ii) that were singular responses, including: a response which argued it could be gleaned via information in the media that there were examples of buildings with staff installed on site to support the enacting of PEEPs or other fire safety initiatives; a response that said it would promote this call for evidence to its members; a response arguing that individual organisations should provide examples; and a response saying that further stakeholder engagement or research is needed, and ministers should do this by consulting with disability rights campaigners to gather examples of best practice.

Question 15: Call for evidence – Are you aware of any other initiatives for how mobility impaired residents can be made safer in their homes or be evacuated from a high-rise residential building in a way which is safe, proportionate and practical?

There were 73 free-text responses to this question.

Details of the various issues raised are covered below, in order of prevalence.

Suppression systems

The most prevalent response was to advocate suppression systems, e.g. sprinklers and misting systems, which focus on reducing or stopping fire spread, thus making residents safer in their own homes rather than requiring evacuation. More than half of the responses (40) highlighted suppression systems: 36 out of the 40 responses, including the NFCC and supporting FRSs, expressed support for sprinkler systems; and five out of the 40 responses expressed support for misting systems in flats.

Monitoring systems

Over a third of responses (27), including the NFCC and supporting FRSs, referred to monitoring systems. The majority of these (26) highlighted tele-assisted remote monitoring. One of these responses provided an example of linking fire alarms to a social alarm to enable residents to communicate with someone on or off site. Another response provided an example of installing a warden call line connected to an automatic receiving centre that will initiate a response from the FRS automatically. The one response that did not highlight tele-assisted remote monitoring argued that proactive engagement of neighbours and direct connection through an alarm system to an alarm receiving centre would ensure earlier intervention by the FRS and support vulnerable residents.

Escape routes

Many responses (24), including the NFCC and supporting FRSs, highlighted escape routes. All but one of these responses emphasised the importance of ensuring the suitability of the designated means of escape routes extends to the exterior of the building. These responses also said that aesthetically pleasing external paving, a drop in pavement, or street furnishings may mean that a person with a disability who may have to be assisted down to the ground level will then struggle to get to ultimate safety. Singular responses suggested having additional fire exits and having more than one staircase in the building.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that alluded to initiatives without stating what they are or provided general views on EEIS+ or the wider fire safety sector which did not include an answer to this specific question (23). Included within these 23 responses were suggestions that buildings should be designed to meet the needs of the residents; that a better solution is to provide alternative accommodation to residents with mobility needs; and that they supported PCFRAs;

(ii) that highlighted lifts, supporting the installation of, or upgrading to, evacuation lifts (eight). Of these, one response said that evacuation lifts should be provided with back-up power supplies and another response said that the use of evacuation lifts should be supported by guidance. Another response supported the installation of, or upgrading to, fire-fighting lifts;

(iii) that supported refuge areas (four);

(iv) that supported the use of family or neighbours (four);

(v) that supported the use of fire or smoke alarms (three);

(vi) that supported smoke ventilation or smoke hoods (two);

(vii) that supported compartmentation (two);

(viii) that supported evacuation chairs (two);

(ix) that were singular responses which supported door openers, signage and sensory measures such as vibrating pillows.

Question 16: Call for evidence – Do you have any evidence on the numbers of residents in your building(s) who are mobility impaired and would likely have difficulty self-evacuating?

There were 72 free-text responses to this question. It is not possible to draw statistically robust conclusions from the evidence provided in response to this question, however, the responses do provide some useful data to contextualise the numbers of residents who are mobility impaired and would likely have difficulty self-evacuating in a range of buildings. Remaining responses discussed processes to identify residents in their building or provided rationale for not having access to this data.

Data

21 responses provided data (numeric or proportional) when answering this question. Responses to this question came from both residents and property managers. Some responses interpreted the term ‘mobility impaired’ differently from one another and from the definition as set out in the EEIS+ consultation^{[footnote 9]}; such responses consequently used different definitions when answering this question, with some incorporating issues beyond physical disabilities, for example, sensory and cognitive impairments. Of those who provided data on the proportion of people in their buildings who may require assistance in an emergency, these figures ranged from 0% to 36% of people who have a disability or would require assistance to evacuate, with an approximate average of 16%.

Process

14 responses discussed processes to identify residents in their building. Eight responses described ways of identifying people who could not self-evacuate, including house calls, Home Safety Checks, and self-identification at commencement of tenancy or at other tenancy checks. Four responses said they had started or completed an exercise to determine numbers in their buildings. Two responses said they had housing management systems which profile and flag residents who would likely have difficulty self-evacuating. One response described a specialist housing scheme where details relevant to self-evacuation are made available as part of care/support plans and housing management functions. Three responses referred to information on residents who would have difficulty self-evacuating being kept in secure information boxes for FRSs to use.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses that:

(i) emphasised the difficulty in determining exact numbers from any evidence (three);

(ii) said they can provide evidence on request (two);

(iii) said the government should consult with other groups to get this information, with one of these responses specifying that government should get the information from disability rights campaigners (two);

(iv) and singular responses which: said they do not have any such information but are concerned that the consultation’s Impact Assessment underestimates the number of residents impacted; said it is not their responsibility to hold such information, but housing providers such as local authorities and housing associations should be able to provide such evidence; said their building’s management company should hold such information; said many council housing buildings contain residents with mobility impairments (that is, physical disabilities, cognitive impairments etc.) but does not refer to any evidence of exact numbers; said they can provide evidence; and a response from an organisation that said it will circulate this call for evidence to their members.

While one housing provider emphasised the difficulty in determining exact numbers of mobility impaired residents likely to have difficulty self-evacuating from the evidence available, three other housing providers said they had information. The majority of the responses, however, came from individuals or organisations without management responsibilities for buildings and as such they would not have necessarily have access to or responsibility for such information.

Question 17: Do you agree or disagree that the provision of separate evacuation plan documents should be focussed on the buildings with the greatest fire safety risk i.e. buildings with simultaneous evacuation strategies in place?

Table 13: Responses to Question 17

Strength of agreement/disagreement	No. of responses	% of responses (n=120)
Strongly agree	22	18%
Tend to agree	23	19%
Neither agree nor disagree	7	6%
Tend to disagree	48	40%
Strongly disagree	20	17%

Overall, 38% of participants agreed that the provision of separate evacuation plan documents should be focussed on the buildings with the greatest fire safety risk i.e. buildings with simultaneous evacuation strategies in place, 6% neither agreed nor disagreed, and 57% disagreed.

Question 17 (free-text section of the question): Do you agree or disagree that the provision of separate evacuation plan documents should be focussed on the buildings with the greatest fire safety risk i.e. buildings with simultaneous evacuation strategies in place?

There were 90 free-text responses to this question.

Details of the various issues raised are covered below, in order of prevalence.

All multi-occupied buildings

The most prevalent issue raised by responses to this question concerned all multi-occupied buildings: this issue was raised by 54 responses (of which eight are from disability groups) that said the provision of evacuation plan documents should include all multi-occupied residential buildings. Nearly half of these responses (26) are from the NFCC and supporting FRSs and said that, while they agreed buildings at a higher risk should be targeted first, limiting the scope of the EEIS+ proposals and evacuation plan documents to buildings with a simultaneous evacuation strategy represents a watering down of RPs’ existing duties under the Fire Safety Order.

General comments agreeing with Question 17

A number of responses (11) agreed that the provision of evacuation plan documents should be focussed on buildings with the greatest fire safety risk. Singular responses within this group also said that: the RP should check residents understand these documents on a regular basis; having these documents in a building with a stay put policy could cause confusion; it is not clear how this would this apply to buildings where only part of the building has a change in evacuation strategy; it is possible this could act as a disincentive to change the evacuation strategy; it should be focussed on these buildings due to limited resources; further clarity is needed on what would be in these evacuation plan documents; the focus should only be on these buildings initially, but ultimately all buildings should fall within scope.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that did not directly address this question (nine). One of these responses said that all buildings where residents live above ground floor level pose a risk to disabled people when stairs form part of the evacuation route; one of these responses said that it would be difficult to justify to residents of high-rise buildings why they are not being offered a PCFRA; one of these responses said that the EEIS+ consultation does not cover what the evacuation plan is for disabled residents if the fire is in their flat or is elsewhere but threatens their flat; and one of these responses said that RPs should provide alternative accommodation for people with mobility impairments instead of trying to manage their evacuation;

(ii) that said the focus should be on other building thresholds (six). Of these responses, four said the focus should be on all high-rise residential buildings; one said the focus should be on all buildings with five or more accommodation units; and one said the focus should be on all buildings with a simultaneous evacuation strategy as well as buildings with a stay put policy over 11 metres;

(iii) that said the focus should be on the vulnerability of residents (four). These responses argued, essentially, that risk should be determined according to the vulnerability of the residents as opposed to the type of building the residents are housed in;

(iv) that said basing risk around buildings with simultaneous evacuation strategies in place was not defined enough (four). One response said there was an undefined line where the risk is no longer an issue and that this could be very subjective; one response gave an example of the difficulty in quantifying risk, comparing someone who lives on the 6th floor of a building that has a simultaneous evacuation strategy with someone who lives on the 20th floor of a building with known fire safety deficiencies that do not meet the threshold to change to simultaneous evacuation; one response said that defining buildings with simultaneous evacuation strategies as being of ‘greatest fire safety risk’ is too narrow a definition and that ‘high risk’, based on the Building Safety Act 2022’s definition and complex buildings, should be included; and one response said that while a separate evacuation plan should be completed for some buildings where a simultaneous evacuation strategy is required, it may not be warranted for very simple low-rise converted blocks with a single means of escape;

(v) and a response that said EEIS+ appears to indicate three distinct evacuation plans.

Clarification

Many who responded thought that the proposal only applied to residents who are physically impaired. It should be noted that the EEIS+ consultation explained under step 2: ‘In buildings with simultaneous evacuation strategies in place, Responsible Persons would be required to ask residents to make themselves known to the Responsible Person for their building if they consider they would need support to evacuate in the event of a fire. This would include not only those with mobility issues, but also, for example, those with hearing, sight and cognitive impairments’.^{[footnote 10]} This makes clear that the EEIS+ proposals apply not only to residents who are physically impaired but also to residents with any condition that would affect an individual’s ability to evacuate in the event of a fire.

Question 18: Do you have any further comments on the proportionality of applying the EEIS proposal and the requirement to create separate evacuation plan documents, only to simultaneous evacuation buildings at this time?

There were 103 free-text responses to this question. Many responses under Question 18 covered issues raised in responses to other questions. In such cases, these comments have been included in the write-up of the relevant questions. Some of the responses to this question are set out in the Recurring themes section on page 56.

The proposal does not go far enough

Some responses (25), including the NFCC and supporting FRSs, said that although EEIS+ represents a step forward, the current proposals do not go far enough to address the key concerns of the Grenfell Inquiry. A further response said that EEIS+ should be an interim and temporary measure. One response said that EEIS+ is not proportionate, practical or safe. One response expressed concern that the proposals could constitute a watering down of the duties already required of an RP under the Fire Safety Order. One response said that EEIS+ was a watered-down version of PEEPs.

Other issues and issues beyond the scope of this question

Other issues that were infrequently raised and issues beyond the scope of this question included responses:

(i) that said the proposals put forward in the consultation were proportionate (five). Two of these responses made specific reference to the scope of the consultation being proportionate. One response said that, although the proposals would require additional resources and competence, it is the right action, which reflects what is required in the social housing white paper regarding better engagement and customer services;

(ii) that raised rehousing (three), two of these responses commenting that rehousing should be considered and that social landlords should consider making an alternative offer of accommodation, and one response expressing concern that disabled people under these proposals could be moved from their homes;

(iii) that offered suggestions (two), including developing self-evacuation chairs that would not require an assisting person, assessing people prior to being housed to ensure the type of housing is suitable for their needs, retrospectively fitting sprinkler systems and creating a central digital information sharing portal;

(iv) and singular responses that: said more effort needs to be made to consider how this issue is addressed in other countries; any requirement that relates to disabled residents must be developed alongside disabled residents; noted the white paper and that, should this paper result in changes to the pay process for FRSs, it could give rise to judicial reviews or industrial action which could slow down the FRSs’ attendance within the targeted time for PEEPs.

Recurring themes

This section outlines the recurring points made where those who responded were invited to expand upon their response to each proposal or question. Under each heading below is detailed the proposal or question these points were made in response to. Those who responded to the consultation did not always comment directly on the specific proposal being put forward, but this section has been included to cover general themes which emerged throughout the consultation.

Engagement and self-identification

Many responses (34) to Question 4 said a flaw in the self-identification process was that people may not wish to engage. The majority of these responses (28), including the NFCC and supporting FRSs, said residents may not self-identify due to fear of discrimination and how this may affect their tenancy arrangement and/or future access to good quality housing. Some responses expressed concern that people would be reluctant to disclose due to a fear that they may be charged a cost to implement fire safety measures. Other reasons for not self-identifying, including stigma and a fear of being perceived as vulnerable, were also cited by three responses. Some responses (18) questioned whether residents would be able to self-identify as needing assistance; a few responses (11) said that this may be due to a cognitive impairment which could inhibit a person’s ability to identify, and four responses said that a disabled person may not appreciate the barriers they may face in an evacuation scenario and so may not be able to advise on their requirements. Singular responses said: that support with self-identification from a third party or family member may be required; that they have customers who do not see it as a priority; and that there is a lack of awareness to identify when a tenant moves in.

A number of responses (17) to Question 5 raised the issue of individuals potentially not being able to engage with the self-identification process as it assumes the person has the ability to self-identify. Five responses said that individuals may not be able identify themselves as being unable to self-evacuate in an emergency, due to some form of cognitive impairment, repeating the point made in response to Question 4. Six responses said that residents may not disclose due to fear of discrimination: in particular, they may believe that disclosing could affect their tenancy.

A little over a third of responses (40) to Question 6 discussed how issues around residents’ engagement may affect the viability of the PCFRA approach. Responses said that in order to carry out this approach successfully, residents would have to self-identify as requiring support, and some residents may not engage with the process for a number of reasons. The main reason given by 24 of these responses, including the NFCC and supporting FRSs, was that the resident may be afraid of discrimination, in particular discrimination impacting their access to housing or ability to secure a tenancy. Five responses also said the financial burden associated with possible measures resulting from a PCFRA may dissuade residents from engaging, and five responses said that people may have cognitive difficulties which prevent them from self-identifying.

Cost

More than half of responses (60) to Question 6 raised cost as an issue. Most responses (40), including the NFCC and supporting FRSs, said that it was unfair for the cost of mitigation measures which are identified by a PCFRA to fall to the individual; these responses raised concerns that disproportionate costs may be passed on to residents, and that some of the measures would be prohibitively expensive for some. Two responses said that any costs involved in making adjustments should be taxpayer funded and one response suggested a need for a clear funding mechanism.

Another issue raised in response to this question was around defining what is reasonable when looking to implement measures to mitigate against the risks identified. A few responses (six) said that definitions of what is reasonable will vary, and it will be challenging to reach an agreement between RPs and residents. One response suggested linking ‘determining what is reasonable’ to the extent to which funding is available from the Disabled Facilities Grant. One response asked for guidance on determining what is reasonable and how a resident may challenge RPs’ decisions.

A number of responses (14) to Question 7 raised cost in their response. As with responses to Question 6, many said that it would not be right for residents to be made responsible for mitigation measures. Some responses also asked for greater clarity regarding what would constitute ‘suitable measures and mitigation’, asking for guidance on this and what RPs’ responsibilities are. One response suggested that taxpayer funding through a central grant should be made available to fund mitigations.

A number of responses (13) to Question 8 referred to costs. Five of these responses were concerned with the cost to RPs of completing PCFRAs and implementing mitigating measures, four responses referred to the cost to residents of funding mitigating measures and four responses expressed concerns over FRSs’ resourcing. Other comments covered defining what is meant by reasonable and questioned what would happen if a resident did not agree to fund measures.

Data security

Over a quarter of responses (23) to Question 4 referred to data security. Two responses made explicit reference to the UK General Data Protection Regulation (UK GDPR) considerations. The majority of these responses (22), including the NFCC and supporting FRSs, referred to privacy considerations in more general terms. One response also suggested that, given constraints on data sharing due to UK GDPR, self-identification could represent the most viable option for identifying those who may require assistance to evacuate. A few responses (three) to Question 5 also covered UK GDPR privacy considerations, with one response also referring to European Convention on Human Rights Article 8 (right to respect for private and family life) and the protection of private information.

Some responses (28) to Question 6 raised concerns about the accuracy and security of information provided as part of this approach. Most of these responses (24), including the NFCC and supporting FRSs, said that information would need to be shared in line with UK GDPR requirements. Four responses said that there is a need to ensure information is kept up to date as there are those who may have a temporary change in circumstances. One response said that a robust method of storing the information should be considered. A small number of responses (three) to Question 8 raised UK GDPR and said that appropriate data sharing agreements should be put in place.

Broader building design

A number of responses (eight) to Question 6 said that it was important to consider physical changes to the building itself to help improve fire safety, as noted below.

A number of responses (10) to Question 11 said that there needs to be cross-government working to ensure evacuation strategies can actually be accessed by disabled residents, that is, that measures are built into new buildings to enable disabled people to have options for evacuation. Examples of ways in which buildings could be designed and built to improve evacuation were given; these included having multiple staircases (especially when over a certain height threshold), evacuation lifts, refuge areas with communications and detectors linked to FRS alarm-receiving centres.

Some responses (27) to Question 18, including the NFCC and supporting FRSs, discussed building construction and design. These responses said that the government must do more to ensure new buildings are designed and constructed in a way that makes them safer for people who occupy and use them in the event of an emergency.

Some responses (24) to Question 18, including the NFCC and supporting FRSs, said there is evidence that the Approved Documents [statutory guidance applying to new buildings] have not received appropriate oversight, and this has led to misinterpretation and ‘gaming’ of the Building Regulations. One response said that inadequate regulations, such as no sprinkler requirement and only one protected staircase, have exposed residents in high-rise buildings to unacceptable risk. One response recognised the work taking place reviewing the mechanisms under the Building Safety Act 2022 and other building regulations but asked for further changes in this area to ensure a multi-faceted approach.

Evacuation

Over a quarter of responses (28) to Question 1, including the NFCC and supporting FRSs, expressed concern that the implementation of EEIS+ could undermine FRSs’ ability to assess and enforce compliance with the Fire Safety Order. NFCC and supporting FRSs were concerned that, if evacuation was perceived as a responsibility for FRSs, this would weaken or undermine FRSs’ ability to hold RPs to account for the provision of evacuation procedures.

Many responses (36) to Question 11, including the NFCC and supporting FRSs, said that the proposal requires FRSs to evacuate residents who require assistance in order for there to be effective implementation. These responses said that this has the potential to dilute or frustrate the existing ability of FRSs to hold RPs to account for the provision of suitable and sufficient evacuation procedures elsewhere. Two responses said that this approach puts residents and firefighters at risk and two responses set out the additional resources they said would be needed in order for FRSs to evacuate disabled people. One response said it is unclear how the RP interprets information given under EEIS+ to then design a suitable evacuation plan and that there is more work required to ensure RPs carry out their responsibilities in a robust manner. One response said that the proposal absolved landlords of responsibility for evacuation planning and relied on FRSs for rescue.

Some responses (30) to Question 18 discussed evacuation and where the responsibility for evacuation would sit. Two responses said that the proposal focuses on information sharing and does not set out who would be ultimately responsible for the evacuation of a resident. One of these responses said that this needed to be defined and the means to enable it considered, particularly the means to finance adaptations, training and resources.

Some responses (25) to Question 18, including the NFCC and supporting FRSs, said that the proposals appear to imply there will be a transference of existing duties from the RP to the FRS, by suggesting that RPs are not already required to ensure all residents can evacuate. One response said that the proposals would increase costs for FRS by transferring the legal liability for evacuation on to firefighters. One response said the proposal would expose firefighters to unreasonable risk by placing the responsibility for emergency evacuation on the FRS. One response said that the EEIS+ approach relies on FRS-conducted rescue instead of supporting self-evacuation, which is an issue due to FRS response times and evidence given in the Grenfell inquiry which demonstrated the importance of timely evacuation to avoid serious smoke inhalation.

A few responses (11) to Question 9 expressed concern that this proposal conflated evacuation with rescue, arguing that it is not for the FRS to evacuate residents but rather the FRS should be rescuing residents.

Guidance

A small number of responses (eight) to Question 4 requested that the government provide guidance in order to help RPs discharge their duties correctly; this included specific guidance on where responsibility would lie in cases where there are several layers of management of the property.

A few responses (eight) to Question 9 said that clear guidance would be needed if this proposal goes ahead, with one of these responses saying that guidance should particularly cover the building scope of this proposal.

A small number of responses (three) to Question 8 asked for further guidance on which tool should be completed first (PCFRA or HFSV), on completing PCFRAs and acting on recommendations, and on what actions would be required following a HFSV.

Personal Emergency Evacuation Plans

Some responses (27) to Question 9, including the NFCC and supporting FRSs, raised PEEPs. They said that this proposal was not a replacement for a PEEP because a PEEP should include a plan for evacuation which goes beyond this proposal.

Some responses (31) to Question 18 spoke about PEEPs in their responses. Most of these responses (22), including the NFCC and supporting FRSs, said that there is a misunderstanding of what a PEEP is and the extent to which PEEPs can be used. NFCC and supporting FRSs argued that PEEPs can already be used: ‘RPs are already required to consider a suite of options to ensure that residents and relevant persons, whether they be disabled or otherwise, are able to exit regulated premises in an emergency. PEEPs form part of the toolbox that RPs can use to meet their existing duties and should be implemented where reasonably practicable, as determined by the fire risk assessment in combination with a person-centred fire risk assessment (PCFRA). PEEPs can be comprised of many different types of measures, as indicated within the government’s own matrix of escape options, published alongside statutory guidance’.

The remaining responses advocated for PEEPs. One response said that PEEPs is the right approach and that the only way to ensure disabled residents are safe in their homes is to offer a PEEP to all residents. One response said that implementing mandatory PEEPs is simple, well-tried and effective. One response expressed their support of the implementation of PEEPs on the condition that: all costs are borne by the taxpayer; the legal responsibility for creating and implementing PEEPs does not rest with the RP in Resident Management Company or Right to Manage blocks; and any arrangements that are agreed to by the person requiring the PEEP are that person’s responsibility.

Equality Impact Assessment

A number of responses (10) referred to the EEIS+ consultation’s Equality Impact Assessment. These comments were made under a range of questions ([Question 4, Question 6, Question 11 and Question 18). These have been addressed in the updated drafting of the Equality Impact Assessment. Some of these comments called on the Home Office to produce further Impact Assessments, to redo the Equality Impact Assessment and/or to publish the evidence on which the Equality Impact Assessment was produced. Some said that it was not reasonable for disabled residents to pay for adjustments to common areas (e.g. to pay for additional handrails or lighting) as disabled residents were not responsible for buildings failing to meet inclusive design standards. It was also argued that several protected characteristics had been disregarded in the Equality Impact Assessment and that no evidence or data was provided to support the assessment.

Impact Assessment

A number of responses (15) referred to the EEIS+ consultation’s Impact Assessment. These comments were made under a range of questions (Questions 1, Question 3, Questions 6-8, Question 11-Question 12, Question 16 and Question 18). Common arguments were that costs have been incorrectly assessed through mistaken assumptions, costs have been underestimated or certain costs have not been taken into account. Some said that the cost of EEIS+ and PCFRAs, and the need to administer and resource these by both FRSs and landlords, has been underestimated by the Impact Assessment. Others said that the Impact Assessment did not recognise the range of impairments which may impact a resident’s ability to evacuate without assistance, with one response saying that the Impact Assessment’s estimated number of residents likely to be impacted is fundamentally flawed because it depends on a limited definition of impairment as mobility impairment. Responses also said that the Impact Assessment does not consider the costs of suppression and prevention measures and so does not account for the additional funding burdens for social housing that is required to carry out such measures. Responses argued that the Impact Assessment does not provide realistic costs for housing associations, does not demonstrate an understanding of the arrangements in privately owned buildings and does not recognise that disabled residents are more likely to be in social housing. One response argued that, when it comes to providing a PEEP or otherwise an independent means of escape for disabled people, such proposals should not be disregarded due to costs; that is, they should not be disregarded because the benefits of making the necessary changes cannot be monetised in the Impact Assessment.

Clarifications

Residents who may require assistance

Some responses (44) said that the scope of the consultation is too narrow in its consideration of disabilities potentially impacting an individual’s ability to evacuate. These responses said that language throughout the consultation emphasises mobility impairments, but other types of impairment can also affect one’s ability to evacuate. Visual and auditory impairments, mental health conditions, and neurodiverse and cognitive impairments were given as other examples of reasons why someone may need assistance. One comment also said that pregnant women and children are groups whose ability to self-evacuate may be compromised, and therefore should be considered.

The EEIS+ consultation explained that, when RPs in simultaneous evacuation buildings are required to ask residents to make themselves known to the RP if they self-identify as needing support to evacuate in the event of a fire: ‘this would include not only those with mobility issues, but also, for example, those with hearing, sight and cognitive impairments’.^{[footnote 11]} This clarifies that the EEIS+ proposals apply not only to residents who are mobility impaired due to a physical condition but also to residents with any condition that would affect an individual’s ability to evacuate in the event of a fire. This is also repeated in footnote 3 on page 4 of this consultation response.

Consultation workshops

During the consultation, the Home Office held four stakeholder engagement workshops to seek in-depth views on and further exploration of the Emergency Evacuation Information Sharing Plus proposals. These workshops were held between 21 June and 27 July 2022 with representatives from FRSs across various regions, the NFCC, Local Government, fire safety experts, leaseholders, housing associations, disability groups, those who considered themselves to be mobility impaired residents, and concerned citizens. The Home Office approached these individuals and organisations in order to obtain views from a wide range of stakeholders, with varied and sometimes opposing views on the proposals and how they would work in practice.

The workshops were chaired by a Home Office official who provided a detailed description of the proposals in detail at the beginning of each session, before asking for views from participants. The workshops gave participants the opportunity to provide detailed comments and discuss the themes together, including where there were strongly differing views. In contrast to the consultation responses, where the number of respondents who held a certain view can often be quantified, numbers for those in a workshop who may have supported any particular view cannot be given as these views were expressed solely by those who chose to speak on the topic and there was no attempt to formally count the number of those who supported a stated view. In addition to the workshops, follow-up calls were made to a selection of individuals to gain a deeper insight into the issues they raised in the workshops and to further engage with disability groups.

A summary of the key areas of interest discussed are summarised below:

Scope of the proposals

Definition of higher risk –

There was some criticism of how the Home Office is defining ‘higher risk’ buildings as equating to any simultaneous evacuation building. One participant pointed out that the Home Office’s definition of a ‘higher risk’ building for the purposes of EEIS+ did not match the Grenfell Tower Inquiry’s definition of ‘higher risk’ and argued that EEIS+ therefore could not meet any Grenfell recommendations. Another participant suggested that the Department for Levelling Up, Housing and Communities uses a different definition of ‘higher risk’ and that Grenfell Tower was not under a simultaneous evacuation strategy and therefore it would not have been considered a ‘higher risk’ building under the proposals. It was also suggested that the differing departmental definitions of ‘higher risk’ buildings is due to the relevant policy being split across departments.

Limiting the scope to simultaneous evacuation buildings –

There was criticism of limiting the scope of the proposals solely to simultaneous evacuation buildings, with concerns about the status of disabled residents in other buildings. Some participants suggested that EEIS+ should be considered regardless of a building’s evacuation strategy – one participant made this suggestion on the basis that, in their view, some RPs would only do the bare minimum and therefore the minimum standard should be set quite high by having EEIS+ in place for all buildings.

Conversely, some felt that the ‘risk-based approach’ laid out in the proposals was correct; in their view, a building under a simultaneous evacuation strategy was evidently a higher risk building in comparison to those under a stay put strategy because, if appropriate measures are in place and done correctly, there should be no need to evacuate an entire stay put building. One participant argued that the scope of EEIS+ only applying to just buildings under simultaneous evacuation would not be compatible with requirements in the Building Safety Act 2022, because under that Act there is a potential requirement to evacuate a purpose-built block of flats for other emergencies, not just fires.

Whether building height should be a risk factor to consider –

While there were mixed views as to whether building height should be a risk factor to consider as part of the EEIS+ scope, few argued the case that the scope of the proposals should be determined solely by building height.

Stay Put

Some participants, in criticising the scope of EEIS+ being limited to buildings under simultaneous evacuation, felt that the scope should be widened to include all buildings (and therefore include stay put buildings) and concerns were raised about disabled residents in buildings beyond the scope and the safety of buildings outside the scope. A participant felt that, while the EEIS+ scope was correct in focusing on buildings under simultaneous evacuation, it raised the question as to what disabled residents in stay put buildings should do in the event of a fire, saying that Stay Put in some cases was not the correct strategy and did not offer disabled residents a sense of safety. Some said that building compartmentation cannot always be guaranteed; this, as well as the fact that fire spread could occur in buildings which have a stay put strategy, means that Stay Put is not always the correct evacuation strategy to take and can actually be a dangerous approach. One participant suggested that there was no evidence Stay Put worked as an evacuation strategy, or that it was necessarily the right strategy for buildings which could in fact be at risk of fire, and the very concept of Stay Put as an evacuation strategy was flawed; Another participant rebutted this latter criticism. Another participant said that, after the Grenfell fire, the general public had lost trust in policies concerning safety, and that many residents in stay put buildings do not trust Stay Put and instead have evacuated buildings in the event of fires. It was suggested that it cannot therefore be assumed following on from Grenfell that residents will follow a stay put strategy. Another view was that the stay put policies within buildings were on the instructions of FRSs.

Volunteers/neighbours and resident associations

The idea of relying on neighbours (or others such as family members, carers etc.) to help the evacuation of disabled residents was discussed, with a range of views expressed. Some argued that it was not possible to rely on neighbours to help evacuate disabled residents in all instances. Others expressed concern about how the use of neighbours would work practically as neighbours are not always available or, in some real-life cases, carers have refused to help with evacuations. One participant, who was disabled, explained that while they would be content for a neighbour to help with evacuation, they would understand that neighbours may not always be available. One participant who had been engaged in the management of their building said that they had struggled to get neighbours to volunteer to help with evacuations, and consequently found it difficult to imagine PEEPs working in practice without on-site staff to support evacuations. Neighbours might not want the responsibility or the potential liability when it comes to evacuating disabled residents.

There was some discussion regarding liability, and that a neighbour may feel they have become liable by volunteering, with another participant arguing that neighbours should not be considered liable but cases would need to be determined by the courts. Some argued that, while relying on volunteers/neighbours would not eliminate risk, it would reduce risk. One participant argued that the RP would be carrying out their due diligence in asking for volunteers/neighbours to help with evacuations. This participant said that many PEEPs use family and friends. Another participant said that local FRSs were refusing to sign off on PEEPs that include the use of family members or friends. It was said that there was ample evidence of neighbours helping one another in emergency situations and that the EEIS+ consultation has disregarded the use of neighbours as a way of reducing risk on the basis that neighbours are not always available. One participant raised the option of resident associations having a role to play in evacuations. While resident association members might support disabled residents evacuating in a more informal, ad-hoc manner, the association could have a more formal role e.g. liaising with the FRS. Views were expressed that any neighbour involvement would probably need to be voluntary rather than compulsory and resident associations’ ability to work in terms of evacuations and liaising with FRSs may depend on a case-by-case basis.

On-site staff

The workshops discussed whether on-site staff could be installed to provide assistance in the event of a fire but not to evacuate residents, which had previously been raised with the Home Office and included as a question in the consultation. Given the number of staff required, the level of training needed and the fact that costs would most likely be passed on to leaseholders, the option of having on-site staff was broadly not viewed as practical, affordable or proportionate. Participants at the workshops noted that residential buildings normally were not staffed and so there would likely be no personnel who could be deployed to support the evacuation of those who needed assistance. One exception to this was detailed by a participant associated with specialised housing for disabled residents. They explained that, in this case, there were on-site staff who would evacuate residents on a phased approach based on the mobility of the resident.

On the issue of on-site staff costs being passed to leaseholders, it was said that the proposed role of the Building Safety Manager was ultimately removed from the Building Safety Act 2022 because it was not seen as acceptable to pass the costs of this role on to leaseholders. It would therefore be unlikely that on-site staff in this instance would be supported given the associated costs to leaseholders. It was pointed out to participants that in general terms there were other potential options as to who could cover the costs – the RP, the taxpayer or the resident. One participant gave an example where, after exhausting other options such as asking neighbours to help with evacuations, the idea of on-site staff was raised but this was rejected by the RP as being too costly and impractical. Another participant said that there are practical elements to consider with installing on-site staff, such as the work involved in modifying buildings to provide the necessary space and facilities for these on-site staff, which had not been included in the consultation’s Impact Assessment. There are also operational and HR issues to consider when managing on-site staff across multiple sites. It was also questioned whether the duties listed for the suggested on-site staff were necessary. Although one disability group welcomed the idea of on-site staff, accepting the cost implications, other participants who spoke at the workshops did not support having on-site staff to support evacuation.

Person-Centred Fire Risk Assessments (PCFRASs) and Home Fire Safety Visits (HFSVs)

PCFRAs were criticised for focusing on in-flat measures and it was argued that the fire risk posed by communal areas needed to be considered for evacuation purposes. One resident said it was appropriate for the RP to conduct PCFRAs as it is important for the RP to be aware of their residents’ needs, while others questioned the capability of RPs to do so and the idea that a PEEP could be put in place on a voluntary basis following a PCFRA. One participant wanted to know how RPs could be enforced against if they fail to properly conduct PCFRAs and act on them. Conversely, another participant said that little training was needed to carry out a PCFRA as most disabled residents could be trusted to know and describe their own needs and limitations. Another participant wanted to know how the determination of what is ‘reasonable’ plays out when it comes to PCFRAs, asking how interventions following a PCFRA could be deemed unreasonable if the disabled resident considers the intervention necessary. Clarity was sought as to who would pay the costs of implementing the measures identified via the PCFRA. It was explained that, as the proposals stood, costs could be paid by the RP, the disabled resident (potentially supported by a Disabled Facilities Grant) and/or all the leaseholders in the building.

Participants who spoke on the issue of PCFRAs generally supported an annual review of information to ensure it was up to date. Some participants were concerned that RPs could turn this into a tick box exercise and therefore miss making recommendations for reasonable adjustments. Issues with resident engagement, as discussed under ‘engaging with residents and relevant third parties’, were also raised. A disability group highlighted the possibility of gaining updates from their members, whose conditions deteriorate over time and so would differ from when information was first collected, by way of asking them to make known their latest needs through a quarterly newsletter. One participant felt the information sharing aspect of the PCFRA proposals was rushed by going straight to the FRS rather than to the RP, although doing so ensures the local FRS are aware of residents unable to self-evacuate. On the subject of HFSVs, it was suggested that the implementation of these following on from a PCFRA should be formalised. Another participant argued against mandating HFSVs on the basis that the nature of the visits varies according to the FRS and that, in their view, HFSVs are not to the same standard as PCFRAs. It was suggested that HFSVs should not be considered a substitute for PCFRAs and that, rather than a PCFRA leading to a HFSV, it was typically the case that a HFSV would signpost the resident towards a PCFRA.

Engaging with residents and relevant third parties

Participants with experience in obtaining information from residents provided different views on collecting information. Participants said that some residents might not want to engage in the EEIS+ process and that RPs need to consider what should be done if this happens. Examples given as to non-engagement from residents included residents who had ongoing unrelated issues with their RP e.g. they might want to avoid discussions with their landlord due to being in rent arrears or because they mistakenly do not think they require additional help in evacuating (an example was cited regarding an older resident with dementia). In certain cases, such as subletting, the subletting resident and the RP would most likely be unaware of one another and so there would be no engagement process.

One participant said that residents were complacent and consequently rarely responded when asked to provide information as to their evacuation needs; possible language barriers were also noted. It was suggested that, in the case of residents unwilling to engage, it was the responsibility of RPs to build trust with residents and explain the reasons why engagement would be beneficial. A further participant said that RPs need to have conversations with disabled residents in which they discuss their needs and collect relevant information from them; they argued that suitable RP engagement with disabled residents is key. Some RPs and resident groups said they would actively find the information through house calls and engaging with residents. Another participant argued that only a minority of residents would be unwilling to engage with RPs and relevant processes. A view was expressed that the RP should have a legal duty to compel residents to provide the information.

In addition to engaging with residents, some participants highlighted that there would be value in engaging or sharing data with relevant third parties as part of the EEIS+ process, such as the Care Quality Commission and care providers, as they would be able to provide further support to disabled residents. In the case of the social housing sector, one participant argued that some relevant third parties such as social services and occupational therapists are already assessing disabled residents’ needs, so it would be sensible again to link to these third parties as part of the EEIS+ process.

Burden of responsibility

There were some concerns among participants as to where the burden of responsibility would lie, and consequently where any liability would fall and where enforcement would be needed in the EEIS+ process. It was suggested that RPs are given many more responsibilities under EEIS+, with one participant saying that this would make the RP more criminally liable – which may in turn result in RPs taking a more risk-averse approach. One participant, who was an RP, felt that it was more practical for the responsibility to evacuate disabled residents to be assumed by FRSs rather than RPs; another participant argued that it was dangerous for complete responsibility for evacuation to be put on FRSs alone and that under EEIS+ it was still being expected that the responsibility of evacuating disabled residents fell to FRSs. An FRS representative who participated argued that, while FRSs are there to save and preserve life and will help where needed, ultimately evacuation should be the RP’s responsibility. A participant said that clarity would be needed as to how FRSs could enforce against RPs failing to meet their duties under EEIS+ and what legal recourse there would be in such circumstances. One participant felt that EEIS+ would undermine RPs’ compliance with their responsibilities regarding evacuation under the Fire Safety Order. Another viewed EEIS+ as a means of passing liability from RPs to FRSs or other third parties.

Participants were asked for views on the role of the FRS in delivering the EEIS+ steps. FRS participants said that their primary purpose was to respond to the fire and not to evacuate residents. Although the FRS would help evacuate residents where needed, there were resource concerns about evacuating a mobility impaired resident, which may take more than a single firefighter over a period of time. Evacuating residents in the first instance, therefore, would limit FRSs’ effectiveness in tackling and controlling the fire. Discussion in one of the workshops raised the point that the FRSs could use equipment in the building to evacuate disabled residents, for instance an evacuation chair. One FRS, however, said that they would expect to use their own equipment for resident evacuations when they are called to attend a building with a fire.

FRS resources

Participants said that adequate resources would be needed for FRSs to evacuate disabled residents. It was said that FRSs’ first priority is to tackle fires; if FRSs are expected to take on the additional priority of evacuating people as routine, this would: have an impact on FRS resources; result in resources being diverted away from other parts of the building towards those residents in need of assistance; and result in FRSs needing to change their operational approach.

Costs and reasonableness

During the workshops, various costs (e.g. possible costs involved in: employing on-site staff; getting equipment; training staff to carry out PCFRAs; increasing FRS resources) were raised. A widely raised concern was the possibility of costs being passed on to residents, with participants broadly feeling that this should be avoided where possible. The possibility of costs being passed on to residents was seen as aggravated by the fact that costs could be caused by implementing disproportionate or impracticable measures (this was in reference to on-site staff and staff recruited to be a Waking Watch). That some residents may be on low or fixed incomes was another reason cited as to why passing costs to leaseholders would be contentious. In addition, a concern was raised that there is an unfairness in asking current leaseholders to pay for measures that would benefit future leaseholders, who in contrast would not have to pay any of the costs. Some participants, however, were concerned that RPs would use costs (and the extent to which the costs are proportionate/reasonable) as a factor to refuse to implement measures which could support the evacuation of disabled residents.

While some felt that residents potentially having to take collective responsibility for such costs would be unfair, it was argued that under leaseholder protection legislation it was unlikely that all residents could be charged for the costs for implementing measures that would only benefit one disabled resident as this would be considered unreasonable. It was pointed out that charging any costs to all residents would need to be compliant with existing regulations on what can reasonably be charged to leaseholders. To determine whether costs passed on to leaseholders are reasonable, the case could be taken to the First-Tier Tribunal (Property Chamber). It was suggested that managing agents could make efficiency savings elsewhere rather than pass on the costs to leaseholders via their service charge. It was also said that the Disabled Facilities Grant scheme could cover some of the costs depending on the circumstance and mitigation being considered. The Chair noted that, in the general sense, the options as to who would pay were the RP, the resident, the taxpayer or a combination of these groups. Discussions about costs also raised questions about how the reasonableness of a cost is determined.

Security of information and digital solutions

The issue of ensuring the security of an individual’s personal information was raised and discussed in all sessions, with concerns expressed about the security of information boxes. Some participants supported the use of digital means for sharing the information with FRSs as it was perceived to be safer and could be directly accessed by the FRS in advance of attending an incident. One resident was comfortable keeping their information in the box as they felt their building was secure. If they lived in a less secure building and area, however, then it may be more likely that the box could be broken into and information taken. There would then be less appeal to hold information in this way. Participants discussed that collecting and completing the information would need to be by competent and trained people. There was broad agreement among those who spoke that the information should be simple and without reems of personal details. There were issues raised by RPs on receiving relevant information from individuals, such as language barriers and self-denial by some residents that they would need assistance. A disability group participant said there should be simple information recorded on the disability (e.g. deaf and/or blind) that would indicate they need assistance to evacuate. An internationally recognised symbol for deaf-blind people should be known by FRSs so they can communicate with deaf-blind residents and let them know they are there to evacuate them, instead of asking them questions which they could not understand, which could cause anxiety to the individual and delay evacuation.

Terminology used in the consultation and workshop discussions: ‘mobility impairment’ and ‘reasonableness’

There was criticism of the term ‘mobility impaired’ or ‘mobility impairment’ to describe the residents receiving support under the proposals. Participants said that other types of impairment can also affect someone’s ability to evacuate, such as cognitive impairments. Home Office stated that the intent expressed in the consultation document was to cover all those who would have difficulty self-evacuating, and the proposals were not confined solely to residents with physical impairments impacting their mobility. Participants also queried the meaning of the term ‘reasonable’ when discussing whether implementing certain measures, and/or the costs associated with implementing such measures, is ‘reasonable’. It was noted, for example, that what might be deemed reasonable by the resident in question may not be viewed as reasonable by the RP, which consequently raises the question as to who has precedence in such circumstances.

Criticisms of the concept of Emergency Evacuation Information Sharing Plus

Some participants criticised the concept of EEIS+, arguing that it would not resolve evacuation problems, failed to meet the Grenfell Tower Inquiry recommendations and was essentially a bureaucratic exercise. Other participants felt that EEIS+ did not address the root cause behind fires and the fitness of housing for vulnerable people – namely, poor building construction.

Evacuation and Fire Safety Working Group

Overview

In the EEIS+ consultation, at the suggestion of the Local Government Association, we made a commitment to explore (with them and other stakeholders) the possibility of neighbours or volunteers offering assistance in the evacuation of residents whose ability to self-evacuate may be compromised. The Home Office established a short-term Working Group whose membership comprised of the Local Government Association itself, housing providers, groups representing disabled stakeholders and other key participants. The Working Group held three meetings and ultimately arrived at two different potential models by which assistance for evacuation could be sought from neighbours/volunteers. One model is resident-centred, with it being the resident’s responsibility to use their own network to identify if there is someone who could assist, and to own the relationship with the volunteer. The other model is RP-centred, requiring the RP to seek volunteers and have a level of responsibility for its working.

From the consultation responses, and more anecdotally, examples have been given of the resident-centred approach, but there have not been examples of the RP-centred approach being applied in the UK. It was suggested by the Working Group (and from responses to the consultation) that practices in other countries might garner examples of the RP-centred approach. Therefore, on behalf of the Working Group, international guidance documents brought to the Home Office’s attention were surveyed. Overall, cases were found where the building owner/manager [the broad equivalent of English RPs] is advised to encourage residents to consider finding a ‘buddy’ or a similar variation of the resident-centred approach. Cases where there is any requirement for an RP-centred approach were not found, and it was not possible to estimate the rate of take-up or success of the approaches in place.

Members of the Working Group were not able to reach a consensus as to the best model to take forward, with sharp differences of view, but their work has fed into the broader thinking as to how neighbours/volunteers could be involved with the EEIS+ proposals. The use of neighbours/volunteers is discussed in Conclusion 9.

Impact Assessment and Equalities

Impact Assessment

An Impact Assessment^{[footnote 12]} was completed and published alongside the consultation. It identified those groups whose members were likely to be impacted by the proposals, including:

• Residents in high-rise buildings and other multi-occupied residential buildings;

• Building Owners, Managers and RPs and their representative groups;

• FRSs, the NFCC and fire safety professionals.

Where appropriate, comments and data provided in response to Question 18 will be used to inform potential future Impact Assessments.

Equalities

In line with our Public Sector Equality Duty responsibilities, government considered the impact that the proposals might have on those with protected characteristics. Consideration was also given as to how any detrimental or discriminatory impact could be mitigated. As such, all this was laid out in an Equality Impact Assessment^{[footnote 13]} which was published alongside the consultation.

This document has now been updated in light of the consultation responses (including the comments from responses laid out on page 60) to consider likely impacts on people with protected characteristics: disability, race, sex, gender reassignment, age, religion or belief, sexual orientation, pregnancy and maternity, marriage, and civil partnership.

Conclusion and moving to regulations

This consultation response draws on a major national evidence-gathering exercise stretching over more than two years. Since the Fire Safety Consultation in 2020, which consulted across the board on the Grenfell Tower Inquiry Phase 1 recommendations aimed at government, the Home Office has held two public consultations on the specific measures to support the fire safety and evacuation of those whose ability to self-evacuate may be compromised.

Over these two consultations, the Home Office has received more than 500 responses from residents, disability groups, FRSs and the wider fire sector, local authorities, housing associations and other housing providers, academics, and numerous professional bodies. The Home Office has also held two series of large-scale stakeholder workshops and held numerous other meetings with individual stakeholders to make sure the Department heard as diverse a range of views as possible.

Additionally, Home Office has engaged with specific groups to look at the potential use of neighbours/volunteers, as proposed by the Local Government Association, and to discuss the potential for a toolkit for RPs. Home Office has also considered a wide range of evidence regarding the use of PEEPs, evidence gathered through the calls for evidence in the Emergency Evacuation Information Sharing Plus consultation and through engagement with all RPs identified to the Department as potentially already undertaking PEEPs. In setting out the conclusions below, Home Office has also reviewed the Inquiry’s further evidence relating to PEEPs and the fire safety / evacuation of vulnerable residents in its recently published final report.

The following conclusions have been drawn to improve fire safety for vulnerable residents.^{[footnote 14]}

Conclusion 1: There is widespread support among stakeholders for specific measures to support vulnerable residents of high-rise and higher risk buildings.

The responses to the consultation, and to the 2021 PEEPs consultation, expressed a wide range of views and perspectives, including some areas of strong disagreement. However, there is widespread recognition that vulnerable individuals, who would have difficulty self-evacuating, should have specific measures to augment the existing generic measures supporting the safety of residents of high-rise and higher risk buildings.

Conclusion 2: The proposed five-step process in the consultation is deliverable.

The consultation garnered a large number of views on each of the five steps, covered throughout the ‘Summary of Responses’ section above. Overall, there was more positive support than disagreement with most of the steps and, while there were many detailed comments, including calls to go further, no major barrier was identified that would mean the process could not be put in place. Government therefore broadly concludes that the measures as set out in this five-step process are practical, proportionate and safe.

Conclusion 3: There is no evidence that RPs have been able to broadly implement workplace-type^{[footnote 15]} PEEPs that are practical, proportionate or safe, in a way that allows a person to evacuate a building unassisted in a residential setting.

RPs have demonstrated that they are taking a wide variety of approaches to improve the fire safety of their vulnerable residents.

However, based on the evidence received, there are no clear examples of workplace-type PEEPs within a residential setting which are practical and deliverable at scale in a proportionate and safe manner. The evidence from the consultation is covered in the calls for evidence (Questions 13 and 15, pages 44-47 and pages 49-50 above). One of the calls for evidence asked for any examples of PEEPs implemented in residential buildings which fully or partially avoid the concerns over safety, proportionality and practicality. The examples received were limited in number; of these, a very small number were able to demonstrate that they fully or partially addressed the concerns over safety, proportionality and practicality, and then only within a very specific scenario, for example, where the resident had existing care structures in place to enact their PEEP.

It would be contrary to the public interest to mandate workplace-type PEEPs within a residential setting where the evidence does not demonstrate that they are universally practical, proportionate or safe for RPs to implement, save perhaps in very limited specific circumstances which are unlikely to be of wider application.

In addition, our calls for evidence set out our interest in, and openness to, new thinking regarding workplace-type PEEPs, and consultation responses demonstrated the commitment of some stakeholders to develop their applicability in the residential setting. We remain open to all new evidence in this respect, and encourages any RP who does develop practical, proportionate and safe workplace-type PEEPs to contact the Home Office. Government can then consider these for potential inclusion in the RP toolkit, covered in Questions 2 and 3 on pages 20-25 and in Conclusion 6 below.

Conclusion 4: Legislation will be introduced to deliver a version of the five-step process. This will deliver a distinct type of PEEP for residential settings which will be known as a ‘Residential PEEP’.

The Emergency Evacuation Information Sharing Plus (EEIS+) terminology was adopted as a work-in-progress name while consulting on the proposals. A number of RPs and residents term their local processes, some very close to the processes which will now be taken forward in Regulation, as ‘PEEPs’. While not workplace-type PEEPs, government recognises that many are familiar with the term ‘PEEP’ as an engagement between the vulnerable resident and RP to support fire safety and evacuation, and equally that these PEEPs in residential settings will generally be different in some aspects from workplace-type PEEPs.

Given the familiarity of the terminology, as well as the fact that workplace-type PEEPs have not been evidenced in residential settings, the term ‘Residential PEEP’ will therefore be used to describe the new process which will be established through Regulation. This will maintain a clear distinction from the traditional workplace-type PEEPs used in some premises while marking it as a complementary model for residential settings.

Conclusion 5: The scope of Residential PEEPs will go beyond that of the consultation. Regulations will mandate Residential PEEPs for all high-rise residential buildings and for residential buildings between 11 metres and 18 metres with simultaneous evacuation strategies in place.

Views on scope (Step 1) are discussed in Question 1 on pages 17-20 above. The 2021 PEEPs consultation responses showed support for a risk-based approach. That consultation proposed that RPs should be required to prepare a PEEP for every resident in a high-rise residential building who self-identified to them as unable to self-evacuate. Some responses objected to the height threshold imposed by this proposal, arguing that this could create a two-tier level of safety, leaving vulnerable people who are living in buildings under 18 metres at risk. Such responses argued that, where possible, residents need to be able to safely evacuate from multi-occupancy buildings regardless of their height.

These responses were listened to and the EEIS+ consultation proposed that scope should be the buildings whose greater fire safety risk mean they had simultaneous evacuation strategies in place. It is clear from the quantitative analysis of the EEIS+ consultation responses that the majority agreed with the scope of the proposals, namely, that the initial change in legislation should be focussed on simultaneous evacuation buildings.

The point was also made, however, that high-rise residential buildings intrinsically limit opportunities for evacuation. Accordingly, in a change from the EEIS+ consultation proposals, and taking on board these views, the scope will be extended to cover all high-rise residential buildings and all other residential buildings between 11 metres and 18 metres with simultaneous evacuation strategies in place. The requirement in Regulation will be supported by further information in Article 50 guidance.

While the PEEPs related Grenfell Tower Inquiry recommendations were specific to high-rise residential buildings, there have been some calls for the scope to be expanded to all residential premises. The consultation Impact Assessment shows the potential for high costs if the mandated requirement was extended beyond high-rise buildings, and costs would significantly increase if all 1.7 million multi-occupied residential buildings covered under the Fire Safety Order were in scope. At this stage, the additional costs are considered to be disproportionate. As with other new requirements in fire safety legislation, the impact of the Regulations will be monitored, which will allow consideration of whether there is a proportionate case to extend coverage to certain other classes of building in the future.

Conclusion 6: There is support but also a desire for the toolkit as proposed in the consultation to be developed further, and we will work with RPs and other stakeholders to put this developed toolkit in place.

Views on the toolkit (Questions 2 and 3 under Step 1) are discussed on pages 20-25 above. The majority of responses said they were aware of fire safety initiatives that could be included in a proposed toolkit for RPs and many saw the toolkit as a potentially valuable resource. A similar number of consultation responses raised concerns about the toolkit, primarily about how the toolkit would be used and how effective it would be, rather than whether a toolkit should be introduced.

We will therefore develop and publish a toolkit. It will not be Article 50 guidance and will not impact Article 50 obligations but will provide practical examples to assist RPs. The intent is that, as well as providing a valuable resource for all RPs, the toolkit can be added to as the new Residential PEEPs measures bed in and RPs and residents establish new procedures. As noted in Conclusion 3, the toolkit would be able to include workplace-type PEEPs, if practical, proportionate and safe routes to do this are identified and put in place by RPs. We are interested more generally in residents using volunteers to support their evacuation and consequently will encourage any RPs who establish local schemes involving volunteers to put these schemes forward as case studies for the toolkit.

The Article 50 guidance accompanying the Regulations will be clear on the purpose and use of the toolkit, to address comments about this in the consultation responses noted above.

Conclusion 7: There are a wide range of well-practised measures by which RPs already identify and engage with their vulnerable residents which can be used to encourage them to participate in the Person-Centred Fire Risk Assessment process. We will therefore mandate RPs to undertake reasonable steps to identify vulnerable residents and take a ‘reasonable endeavours’ approach to follow through with that identification if contact is not easily established, while leaving the final decision on whether to come forward with the residents themselves.

Views on the identification process for vulnerable residents (Step 2) are set out on pages 25-27 above, with the majority of responses agreeing that the proposed identification process laid out in the consultation (that is, the RP asking residents to self-identify) strikes the right balance of responsibilities between an RP and an individual resident. Although many responses said there were potential difficulties in maintaining information accuracy regarding vulnerable residents, which could result in some vulnerable residents not being identified and engaged, it must remain the vulnerable resident’s choice as to whether they want to self-identify and engage.

We will therefore legislate through the Regulations to require RPs to undertake reasonable steps to identify vulnerable residents and take a ‘reasonable endeavours’ approach to follow through with this identification and engagement if contact is not easily established. This requirement will be for the purpose of carrying out the PCFRA step of the Residential PEEPs process and will be supported by Article 50 guidance.

Conclusion 8: The Person-Centred Fire Risk Assessment process offers a well-established route for RPs to identify fire risks to vulnerable residents, and to identify potential mitigations that are practical, proportionate and safe. We will mandate the Person-Centred Fire Risk Assessment process in Regulation, while allowing RPs the flexibility to continue with existing processes as appropriate and adapted for their local circumstances and resident populations.

Views on PCFRAs (Step 3) are set out on pages 28-34 above. The majority of responses agreed that, for those who self-identify as needing support to evacuate, the RP should be required to offer a PCFRA and connect them with a Home Fire Safety Visit from the local FRS if required.

We found that a range of PCFRAs and PCFRA-equivalent risk assessments, sometimes incorporated within wider risk assessments, have already been developed by different RPs. We do not wish to cut across existing, well-established processes, so will set in Regulation a high-level requirement for PCFRAs, to incorporate the following elements:

a) Consideration of the fire safety risks present in the resident’s flat;

b) Consideration as to the ability of the resident to self-evacuate;

c) Consideration of the fire safety risks present in the building’s common areas, including those that might hinder the resident’s ability to self-evacuate;

d) Taking steps a) to c) into account, implementation of reasonable and proportionate measures to support the fire safety and evacuation of the resident, noting the limitations in Conclusion 11 below – this could include the use of family members, neighbours or other volunteers where the resident themselves can make the arrangement; and

e) A written Residential PEEP statement on what the resident should do in the event of a fire that reflects the outputs from steps a) to d), including consideration of the risks related to the evacuation strategy of the building – see Conclusion 12.

We will augment this approach with Article 50 guidance and through examples in the RP toolkit referenced in Conclusion 6.

Conclusion 9: The use of volunteers to support evacuation, e.g. neighbours or family, should be considered as part of the Person-Centred Fire Risk Assessment, and it would be for the resident to source and get their agreement to help.

It is recognised that some residents have family members, friends or neighbours who are willing and able to offer assistance with evacuating them. Consultation responses showed strong support from some stakeholders for including such volunteer assistance, where available, in the PCFRA consideration.

This is not straightforward, and concerns were raised regarding the use of volunteers – as noted on pages 64-65. A particular concern was how far a resident or RP could reasonably rely on a volunteer, and it is notable that the relatively few examples identified through the consultation calls for evidence are all resident-determined rather than involving the RP.

Residential PEEPs need to allow for these informal, resident-determined arrangements, and Article 50 guidance will encourage residents to consider whether they are able to and wish to source volunteers to support their evacuation under element (d) of the PCFRA process (‘implementation of reasonable and proportionate measures’) above.

The use of volunteers in the evacuation of residents may also help to foster friendlier and closer relations between residents with affected protected characteristics and those who do not.

Conclusion 10: The RP and resident will discuss which measures, identified through the Person-Centred Fire Risk Assessment, can be implemented. The Fire Safety Order approach that the RP is ultimately responsible and that the decision on which measures will be implemented remains with them, excepting that in the general case a resident will make the decision whether or not to implement a measure within their flat which it has been determined is for them to pay for.

Views on identifying measures (Step 3) are discussed on pages 28-34 above. The majority of responses agreed that this approach is sufficient to identify suitable measures to mitigate against fire safety risks, including barriers to evacuation. This will be set out in Regulations supported by Article 50 guidance. Views on how this will be mandated are discussed in Conclusion 11.

Conclusion 11: Home Office will set out in Article 50 guidance that costs to implement measures will usually be charged to the individual where they are the only beneficiary, across all leaseholders in the building (where appropriate and where leases allow), or by the Responsible Person themselves paying for measures. Article 50 guidance will also explain how leaseholders can challenge costs they deem unreasonable.

While many agreed that PCFRAs would provide an effective way of identifying suitable mitigation measures, a prevalent concern raised was whether such measures would be implemented – and how they could be enforced – if RPs are not legally required to implement all measures identified. Conversely, placing a legal requirement to implement all measures identified raised concerns about disproportionate costs being passed on to other residents, whether directly e.g. through service charges or indirectly through raising the cost of providing housing.

If the RP determines that a measure is for the resident to fund, it will be a matter for the resident to decide whether to implement the measure. There will therefore be no risk that, having put themselves forward for a Residential PEEP, a resident will end up being obliged to pay a bill if they choose not to. Some measures for example adjustments to the resident’s flat, may also be eligible for the means-tested Disabled Facilities Grant, if they meet the conditions.

As mentioned in the Minister for Housing, Communities and Local Government’s 2 September 2024 written ministerial statement, for 2025/26, government has committed funding to support social housing providers to deliver Residential PEEPs for their renters. Future years’ funding to continue supporting social housing providers will be confirmed at the upcoming Spending Review.

In some cases, the decision as to which measures will be implemented will likely be a subject of discussion: the PCFRA will identify potential appropriate, proportionate measures; where the RP determines the cost of a measure should lie with the individual resident, that person will need to take a view as to whether they are willing to pay (or determine if they have access to Disabled Facilities Grant for adjustments required to the resident’s flat); if the resident decides not to implement the measure, the RP would be expected to remove that mitigation from the list in the PCFRA of those that will be implemented.

Where the RP determines that it is appropriate for all leaseholders to fund a measure (for example, a common-area measure of benefit to many residents), those leaseholders will have the opportunity to challenge costs they deem unreasonable via existing leaseholder law mechanisms.

The consultation identified a range of RPs who already pay for certain measures themselves, and this is always an option for them to follow.

Home Office will provide Article 50 guidance to support the RP and resident in their considerations, and to note that residents and RPs should record the outcome of the PCFRA and what has been agreed, in line with established practice for other tenant-RP arrangements.

Conclusion 12: At the end of the Person-Centred Fire Risk Assessment process, the resident and RP need to be clear on what the resident would do in the event of a fire affecting them, which the RP will be responsible for recording in a Residential PEEP statement.

The requirement on the RP to record a Residential PEEP statement will be included in the Regulations, supported by Article 50 guidance, and give clarity to the resident. The Residential PEEP statement would also include, for example, any arrangement the resident makes with a neighbour to provide support and consideration of the risks related to the building’s evacuation strategy.

Conclusion 13: In the event of a fire, the FRS will fight the fire, and undertake the evacuation and rescue of vulnerable residents. To support FRSs in carrying out these emergency evacuations, we will require, in Regulation, specific information on all vulnerable residents in in-scope buildings to be made available by RPs to their local FRS. This will be supported by Article 50 guidance.

Views on the provision of information to the FRS (Step 4) are set out on pages 34-36 above. The majority of responses disagreed that the method laid out in the consultation for an RP to share information on vulnerable residents with their local FRS would be sufficient to allow the FRS to execute an emergency evacuation, if required. The most common concern raised was that additional information would be needed to allow the FRS to execute an emergency evacuation. Other views proposed the standardisation of the format for recording information and raised the challenges of information sharing between the RP and the FRS, especially the challenge that FRSs may not have the capability to manage digital information.

In the event of a fire, the FRS will fight the fire, and undertake the evacuation and rescue of vulnerable residents, and should be supported to do so by having access to relevant information. On balance, there is a strong case for RPs to make available a limited set of information, brief enough so that it can be assimilated immediately by FRSs in an emergency situation. Given the short amount of time FRSs may have to mount an operational response on arrival at an incident, a limited but accessible and useful set of information is more practical and sensible than a mass of information that would require significant time for FRSs to work through. The case for any larger set of information, which the FRS would need time to assimilate, is linked to the technical capabilities of RPs to record/produce information digitally, and the technical capabilities of FRSs to receive information digitally – and these technical capabilities vary across RPs and FRSs. However, government accepts the case made in some consultation responses for including one further piece of information which is an indicative level as to the nature/degree of the resident’s condition.

Accordingly, government will mandate that the floor number and the flat number of vulnerable residents identified through the steps above are provided to the local FRS and, in a change from the consultation proposals, an indicative level as to the nature/degree of the resident’s condition (and therefore an indication of how much and what type of help an individual may need) will be included in the Regulation.

In a further change from the consultation proposal, we are persuaded by the argument that, with their consent, all residents with Residential PEEPs should have the information noted above made available to their local FRS. The consultation proposed that, following the completion of Step 3 (conducting the PCFRA), only those vulnerable residents without implemented measures to support their evacuation should have their information made available. This change from will provide additional assurance to those residents who put in place an evacuation measure or plan which may not work on the day (e.g. identifying a neighbour who could help, but who is away during the emergency).

The Regulation will also include that local FRSs will determine whether the RPs in their area should provide the information digitally or by placing it in a secure information box on site. We will set out in Article 50 guidance that digital information is preferred. This is because more consultation responses were in favour of digital rather than physical information, arguing that digital information sharing is better because it is easier and quicker to update than physical information in a secure information box. More consultation responses also said that there are security risks associated with storing information in a secure information box. Furthermore, we will set out in Article 50 guidance that, while this decision sits with FRSs, the expectation is that FRSs not currently receiving digital information will consider how they can move to accepting digital information in the future. In the absence of all FRSs being able to receive digital information, and the identified concerns over placing personal information in any physical box, we will set out in Article 50 guidance that FRSs may consider asking for further information (above what has been prescribed above) digitally from RPs in their area where they consider this would help with the evacuation of vulnerable residents. There will not be a requirement for RPs to share digitally extra information beyond that set out in the Regulation: it will be a matter for discussion between the RP and the local FRS, in line with the provisions of the Data Protection Act 1998 and UK GDPR, but RPs will be expected to take reasonable steps to comply with these requests for further information. Government will work with NFCC to monitor the use of this provision.

Conclusion 14: Employing paid staff with the primary purpose of supporting evacuation is likely to be disproportionate in most cases. Consultation responses overwhelmingly rejected the idea of employing on-site staff (such as a ‘concierge’) and, more broadly, subsequent conversations with disabled stakeholder groups and RPs did not support the staffing up of residential buildings as an effective way to evacuate vulnerable residents.

Views on whether the employment of additional staff on site would add enough value to justify the costs, a proposal put forward by FRSs (Question 12 under Step 5), are on pages 42-44 above. Discussions at the Evacuation and Fire Safety Working Group and individual discussions with disabled stakeholder groups and RPs found widespread concerns with ‘employing someone to sit outside the vulnerable person’s door’, and that staffing up of buildings to physically support evacuation would be impracticable and disproportionately costly. We will reflect this in the regulations and/or Article 50 guidance.

Conclusion 15: Building level evacuation plans will be produced for all high-rise residential buildings and for residential buildings between 11 metres and 18 metres with simultaneous evacuation strategies in place.

Views on the evacuation plans proposal (Question 17), in response to Grenfell recommendation 33.22(c), are discussed on pages 52-54 above. The majority of responses disagreed that the production of separate building level evacuation plans should be focussed just on the buildings with simultaneous evacuation strategies in place.

Aligning with Conclusion 5, we will therefore – in a change from the consultation proposal – mandate that building level evacuation plans be produced and provided to FRSs for both medium-rise residential buildings with simultaneous evacuation strategies in place and all high-rise residential buildings. A building level evacuation plan should include the Instructions to Residents (required under the Fire Safety (England) Regulations 2022), any arrangements implemented for vulnerable residents under Residential PEEPs, and any other special arrangements for that building, for example if an Evacuation Alert System has been included (as recommended for new buildings that are 18 metres or more in height under building control ‘Approved Document B’) or if an evacuation lift is available.

Government will work with a variety of stakeholder and representative bodies on developing the operational detail of the policy and Regulations, the guidance and the RP toolkit.

Subject to parliamentary approval, the government will then proceed to draft and lay Regulations to enact the above consultation outcomes on Residential PEEPs and building level evacuation plans as quickly as the parliamentary timetable allows.

Consultation principles

The principles that government departments and other public bodies should adopt for engaging stakeholders when developing policy and legislation are set out in the Cabinet Office Consultation Principles 2018.

Any enquiries regarding this publication should be sent to us at FireSafetyUnitconsultations@homeoffice.gov.uk or sent to:

Fire Safety Unit
Home Office, 2 Marsham Street,
Fry Building
London
SW1P 4DF

1. https://assets.grenfelltowerinquiry.org.uk/GTI - Phase 1 full report - volume 4.pdf, p.777. ↩

2. The Responsible Person (RP) is generally the building owner or manager. In the case of a building that it a workplace, the RP is specifically defined under article 3 of the Regulatory Reform (Fire Safety) Order 2005 as ‘the employer, if the workplace is to any extent under his control’. Otherwise, the RP is either: ‘the person who has control of the premises (as occupier or otherwise) in connection with the carrying on by him of a trade, business or other undertaking (for profit or not); or the owner, where the person in control of the premises does not have control in connection with the carrying on by that person of a trade, business or other undertaking’. ↩

3. All references to ‘mobility impaired residents’ in both the consultation and in this response include any condition that would affect an individual’s ability to evacuate in the event of a fire and would include, for example, those with hearing, sight and cognitive conditions. ↩

4. The PEEPs consultation, which ran from 8 June 2021 and closed on 19 July 2021, consulted on four proposals which aimed at addressing Grenfell recommendations 33.22(e) and (f). The consultation responses made clear the substantial difficulties of mandating PEEPs in high-rise residential buildings. These difficulties - focussed on practicality, proportionality and safety concerns – are set out in the response to the PEEPs consultation (published on 18 May 2022). Given these difficulties, it was decided not to mandate PEEPs in high-rise residential buildings at this time. ↩

5. Thematic update on progress against the Grenfell Tower Inquiry Phase 1 recommendations - GOV.UK (www.gov.uk) ↩

6. 2021 PEEPs consultation response (publishing.service.gov.uk); a version accessible for users of assistive technology is also available here: Response document (accessible) - GOV.UK (www.gov.uk) ↩

7. Home Fire Safe Visits (HFSVs) and Safe and Well Visits (S&WVs) were used to make similar points in responses, and both terms refer to visits that are carried out by the local FRS where they provide fire safety advice on, e.g. home fire prevention and how to escape a fire in the home. The visit may also include the local FRS installing smoke alarms or recommending other local services that may provide further health and safety advice. HFSVs and S&WVs, which are in common use by FRSs, are not statutory and the specifics of what a visit may entail are determined by the local FRS. HSFV is used to refer to both HFSVs and S&WVs in this consultation response. ↩

8. Although not named, this may be referring to the ‘Improving disabled people’s access to let residential premises: reasonable adjustments to common parts, a new duty’ consultation, a consultation on proposals to fully commence section 36 of the Equality Act 2010 and its associated schedule paragraphs, launched by the Government Equalities Office and which ran from 9 June 2022 to 18 August 2022. ↩

9. The definition of ‘mobility impairment’ as used in the EEIS+ consultation and this response has been given earlier in footnote 3 on page 4. ↩

10. https://www.gov.uk/government/consultations/emergency-evacuation-information-sharing/eeis-consultation-document ↩

11. https://www.gov.uk/government/consultations/emergency-evacuation-information-sharing/eeis-consultation-document ↩

12. Impact Assessment (publishing.service.gov.uk) ↩

13. Equality Impact Assessment - GOV.UK (www.gov.uk) ↩

14. Some responses to the consultation indicated confusion or misapprehension as to the meaning of ‘mobility impaired residents’ used in the consultation (although the consultation did define the term as including ‘not only those with mobility issues, but also, for example, those with hearing, sight and cognitive impairments’). Consequently, moving forward, the term ‘vulnerable residents’ will be used as synonymous with this definition and will be used instead of ‘mobility impaired residents’. ↩

15. By ‘workplace-type PEEPs’ we are referring to PEEPs commonly found in UK workplaces. These are plans to facilitate evacuation ahead of FRS arrival often with the help of on-site staff. ↩