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

On 30th March 2023, the Home Office published three new fire safety guides to help responsible persons and building owners better understand their legal duties concerning small non-domestic premises and blocks of flats.

The guides, designed to offer "simple and practical advice", aim to support responsible persons in meeting their legal duties under Article 50 of the Regulatory Reform (Fire Safety) Order 2005 (FSO). They include information on what a responsible must do to comply with fire safety law, how to carry out and review a fire risk assessment, and how to identify and maintain general fire precautions. Each one includes a fire risk assessment checklist.

Photo of a line of holiday cottages by Yaopey Yong on Unsplash

Published by the Home Office, the guides were drafted by C.S Todd and Associates Ltd following engagement with stakeholders in the fire, business and housing sectors plus the general public. They relate to Phase 3 of the Home Office's fire safety reform programme, which is expected to come into force on 1 October 2023.

The guides cover:

  1. Making your small block of flats safe from fire
  2. Making your small paying guest accommodation safe from fire
  3. Making your small non-domestic premises safe from fire

The guide we are going to focus on in this article concerns small paying self-catering holiday accommodation, which is a topic we covered last month when we looked at the subject of holiday let fire risk assessments.

A Guide To Making Your Small Paying Guest Accommodation Safe From Fire was put together with assistance from VisitEngland, and supersedes the previous 'Do You Have Paying Guests' guide.

The aim of the new fire safety guidance for holiday lets is to assist those responsible for fire safety in paying guest accommodation that has simple layouts, limited fire risk, and a small number of bedrooms. This includes guest sleeping accommodation for short-term lets, such as small bed and breakfasts, guest houses, and self-catering accommodation.

The guidance is limited to single premises consisting only of a ground floor, or of a ground and first floor, providing sleeping accommodation for a maximum of 10 persons, with no more than four bedrooms on the first floor. These may be houses, cottages, chalets or individual flats (whether within a purpose-built block of flats or a house that has been converted into flats), but not unusually large flats (such as those found in mansion blocks in London).

The fire safety principles and recommendations contained in the guide can also be applied to smaller types of outdoor accommodation, such as holiday caravans, camping and glamping pods, bothies, lodges, shepherds' huts, tents, tree houses and yurts. Although the fire risks associated with this type of accommodation are usually low, some units may have dedicated electricity supplies, log burners and cooking facilities that will increase the risk.

For paying guest accommodation that falls outside the scope of the new guide, fire precautions and the fire risk assessment should instead be based on the guidance in Fire Safety Risk assessment: Sleeping Accommodation

How has fire safety guidance for holiday lets changed?

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


Changes to holiday let fire extinguisher regulations

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


Changes to legislation on fire escape routes

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Do you need to review your holiday let fire risk assessment in Cumbria, Penrith, Kendal or Carlisle in light of the new guidance?

Many owners will no doubt be confused by the new fire safety guidance for self-catering holiday lets and wondering how to approach the issue of fire escape routes.

At BPW Fire Safety, our experienced and qualified fire safety specialists are on hand to help ensure your Cumbria self-catering holiday let is safe and compliant with the latest fire safety guidance.

With BPW, you can rest assured that our competent assessors will help you navigate your way towards compliance, whilst making sure your guests continue to enjoy their time at your property, in complete safety.

For a tailored quote at competitive rates for holiday let fire risk assessments Cumbria, Penrith, Kendal and Carlisle wide, contact BPW Fire Safety today.


Ash Grove, Alexandra Road
Penrith, Cumbria, CA11 9AN

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