Fire legislation further tightened for vulnerable people
White paper from Assurity Consulting
Assurity will be exhibiting at Stand E4 at the show.
The inquiry into the Grenfell Tower tragedy has already seen significant changes with how in-scope buildings need to manage the risk of fire.
This has continued this month with the introduction of the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025, so we are sharing information on the scope, enforcement and the measures that fall to the duty of the Responsible Person, for these requirements.
So, what does this mean for your business?
- Introduction
The need for improved planning for the evacuation of vulnerable residents were recommended in the Phase 1 Inquiry Report and these were: 33.22(e) and (f) concerning Personal Emergency Evacuation Plans (PEEPs), which said:
“the owner and manager of every high-rise residential building be required by law to prepare personal emergency evacuation plans (PEEPs) for all residents whose ability to self-evacuate may be compromised (such as persons with reduced mobility or cognition)”; and “that the owner and manager of every high-rise residential building be required by law to include up-to-date information about persons with reduced mobility and their associated PEEPs in the premises information box’”
33.22(c) concerning evacuation plans which were to be actioned through legislation, which said:
“the owner and manager of every high-rise residential building be required by law to draw up and keep under regular review evacuation plans, copies of which are to be provided in electronic and paper form to their local fire and rescue service and placed in an information box on the premises”.
The new regulations, according to GOV.UK, addresses these with the aim to “improve the fire safety of disabled and vulnerable people in high rise and higher risk residential buildings.”
2. What are the requirements?
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 were laid on 4th July 2025, will come into force on 6th April 2026, applying in England only.
Their aim is to improve the processes in place to evacuate residents in specified residential buildings in England who would have difficulties evacuating a building by themselves in the event of a fire, whether that be due to a:
- mobility;
- visual;
- hearing;
- or cognitive impairment
The Regulations will also make it mandatory for building evacuation plans to be developed and implemented.
3. Enforcement
The enforcing authorities (e.g. Fire and Rescue Authorities) under the requirements of the Regulatory Reform (Fire Safety) Order (2005), already have the power to enforce compliance, and as such, the Responsible Persons’ duty to follow the Residential PEEPs would be an extension to this.
4. Scope
Within England, the Regulations apply to all buildings that contain two or more sets of domestic premises, and which is either:
a. at least 18 metres above ground level or have at least seven storeys; or
b. is more than 11 metres in height above ground level that has a simultaneous/phased evacuation strategy in place (i.e. evacuation is the priority, rather than to stay put)
The Regulations also refer to the need for PEEPs for ‘relevant residents’ only. These are defined as domestic residents who occupy a building in scope, and it is their only or principal residence; and their ability to evacuate the building without assistance in the event of a fire is compromised because of a cognitive or physical impairment or condition.
5. Responsible Person- Measures
The Residential PEEPs process includes a set of measures which fall to the duty of the Responsible Person:
- The Responsible Person (typically the building owner or manager) must use reasonable endeavours to identify relevant residents who need Residential PEEPs
- A Person-Centred Fire Risk Assessment – a conversation between the Responsible Person and the resident, if one is requested by the resident – to understand their particular risks and identify how their fire safety and evacuation can be improved. The Person-Centred Fire Risk Assessment must include an assessment of the risks relating to the relevant resident and the premises considering that resident’s impairment or condition and consider the resident’s ability to evacuate the building without assistance in the event of a fire
- An emergency evacuation statement documenting what the resident should do in the event of a fire (if agreed between the Responsible Person and the resident)
- Information for the Fire and Rescue Services to help inform any operational response and in case they need to undertake evacuation (but only if the resident explicitly agrees to that information being shared) e.g. flat number, floor number, basic info on degree of assistance and whether an emergency evacuation statement is in place, documented in a premises information box or digitally (determined by the Fire and Rescue Services) but in line with GDPR requirements
- To review the Person-Centred Fire Risk Assessment, documented emergency evacuation statement, and the building emergency evacuation plan at least annually
- Personal Emergency Evacuation Plans (PEEPs) are well understood in the workplace, as they are intended to allow for the evacuation of everyone in advance of the Fire and Rescue Service’s attendance in the event of an emergency.
These types of evacuation plans should be specific to the individual and provide a suitable plan for the safe evacuation of this person whilst not relying upon the intervention of the Fire and Rescue Service to make it work. These are typically implemented using a ‘buddy system’ (on-site staff), designated evacuation lifts, evacuation chairs, and refuge points (where available).
For the Residential PEEPs, the Fire and Rescue Service will support with the evacuation, but typical control measures may include the support of family, friends, neighbours or carers, providing relevant fire safety information in varying formats.
Resident consent is needed throughout every stage of developing a Residential PEEP. For instance:
- The decision as to whether to participate in Residential PEEPs lies with the resident and they cannot be compelled to participate.
- The decision as to whether to agree an emergency evacuation statement lies with
- the resident. This also needs to capture the costs associated with mitigating the risks
- The assessment as to whether a measure is ‘reasonable’ and ‘proportionate’ may differ depending on who is to bear the costs. It may not be deemed reasonable and proportionate if all residents are to bear the costs, and the mitigating measure doesn’t benefit the majority of the building’s residents. If the costs were to fall to the resident, and the resident declines to pay, then they may decline to have the measures or equipment provided.
- The decision as to whether the prescribed information can be shared with the local Fire and Rescue Services lies with the resident; sharing requires the resident’s explicit consent
The Government intends through future primary legislation to introduce further requirements on Responsible Persons. This is to consider the fire safety risks within the relevant resident’s domestic premises (as part of the Person-Centred Fire Risk Assessment in Residential PEEPs). This requirement will also mandate a consideration of reasonable and proportionate measures that the Responsible Persons and resident may take within the domestic premises to mitigate these risks.
While relatively new there is already advice and guidance being produced including “Residential Personal Emergency Evacuation Plans (Residential PEEPs)” from GOV.UK, which includes:
- A Residential PEEPs factsheet;
- A Responsible Person toolkit – including examples of Person-Centred Fire Risk
- Assessments and guidance on how to identify and engage with relevant residents;
- A Responsible Person toolkit – additional resources; and
- A Residential PEEPs impact assessment.