SEEKING CLARITY IN HOLIDAY LETS FIRE SAFETY
Published 22 September 2023
All of us who are involved in the holiday lettings business have as our first priority keeping our guests safe. When it comes to things such as fire safety, the rules should be clear and consistent; that way everyone knows where they stand, writes Louise Hillman, manager of Keys Holiday Cottages.
The publication of the new fire regulations for self-catering accommodation in England and Wales, which come into force on 1st October 2023, was a great opportunity to provide that crystal clear guidance. At first glance, they do offer that clarity – but sadly they also leave some grey areas, which when it comes to something as important as this, is disappointing.
First of all, let’s look at what the new regulations say. The new rules mean that every short-term let property – even if it is only let for only one night – must have a ‘Responsible Person’ (RP): an individual who is responsible for that accommodation complying with the fire regulations.
Incidentally, that RP cannot be the cleaner, although with appropriate training, they can be delegated simpler tasks such as checking smoke alarms at changeover.
That Responsible Person must conduct a Fire Risk Assessment (FRA), to record fire hazards and fire safety arrangements. This is the first time that such assessments have been mandatory, although responsible owners and agents have been doing this for a long time. Certainly the FRA will be nothing new to any of Keys Holiday Cottages’ owners. FRAs must re reviewed annually.
Now you have to make that FRA available to guests, either electronically or on paper. It also has to be available to the local Fire and Rescue Service in the event of an inspection (or, heaven forbid, a fire).
You can conduct your own FRA, but realistically that will only be for smaller and less complex properties. Unless you are suitably qualified, our advice would be to seek the services of a professional Fire Risk Assessor to conduct the FRA. This is an added cost, but compared to the risk of getting it wrong, a relatively small one.
Having assessed the risks, you must provide Fire Protection Measures to mitigate them. These include smoke alarms in every bedroom, sitting/dining rooms, halls and staircases, and a heat alarm in kitchens. These should be hard-wired into the lighting circuit; battery alarms are only acceptable as a temporary solution.
You also need a carbon monoxide alarm wherever there is combustible fuel equipment such as a gas boiler, gas hob or log burner. All alarms should be tested at each changeover or weekly, whichever comes sooner.
You also have to provide a fire blanket. Fire extinguishers are not mandatory, but where provided they should be of the non-powder multi-purpose variety, and regularly maintained.
For most smaller units of accommodation,. You don’t need to provide fire doors, but your doors do have to be ‘notional fire doors’: solid and providing at least 30 minutes fire resistance. Hollow doors are not acceptable, and will need to be replaced.
You must also provide lighting to enable safe evacuation should a fire interrupt the electricity supply. This can be ‘borrowed lighting’ (i.e. exterior street lighting), but in practice it means providing rechargeable torches or night lights in every bedroom.
You must also have an escape plan and display a Fire Action Notice giving instructions to guests on what to do in the case of a fire. Exit routes need to be kept clear of obstructions such as waste materials and guest luggage, and final exit doors must be easy to unlock from the inside, without needing a key.
So far, so clear, and sensible. So why are these new regulations causing so much uncertainty amongst holiday lettings owners? Where are the grey areas?
Well, the main thing is that these regulations do not apply to all holiday lets – only ‘small, non-complex’ accommodation, which means single premises of ground floor or ground floor and first floor, providing sleeping accommodation for a maximum of ten people, with no more than four bedrooms on the first floor; and individual flats, except for ‘unusually large’ flats.
For other types of accommodation, such as those with more than two stories, or more than four bedrooms, or sleeping more than ten people, or with an open-plan ground floor, or with a bedroom accessed through another room (in other words around three in ten of all holiday lets in England and Wales), the ne rules don’t apply at all.
For these premises, the 2006 guidance still applies, until such time as new regulations appear – and there are no signs of that happening any time soon.
For owners of these kinds of accommodation, the promised clarity is sadly lacking. The only suggestion is to recruit a competent and qualified Fire Risk Assessor to assess your property and suggest what mitigations are necessary, ensure you record absolutely everything so that you have an audit trail if anything goes wrong, and if you can, run your plans past the local Fire and Rescue Service to sense check it.
To be honest, self-catering holiday property owners shouldn’t have to be second-guessing how to make their premises fire safe for their guests; they should be receiving clear and unambiguous guidance. The vast majority of owners want to do the right thing. If only it were that simple.
Louise Hillman is manager at Keys Holiday Cottages. www.keysholidaycottages.co.uk
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