hmo Archives – Safelincs Blog

Wednesday 27th March 2024

What is an HMO?

HMOs are typically large houses that have been converted into flats or bedsits, such as student housing. ‘Houses in multiple occupation’ are defined by gov.uk as follows:

Your home is a house in multiple occupation (HMO) if both of the following apply:

at least 3 tenants live there, forming more than 1 household
you share toilet, bathroom or kitchen facilities with other tenants

It is important to note that the requirements for sheltered housing, such as supported living facilities, and self-catered rentals, such as holiday cottages are different, and not covered in this blog.

Kitchen facilities are often shared in HMOs — Shared kitchen spaces are a fire risk in HMOs

What grade of smoke alarm system is required for HMOs?

Within most HMOs, there are several acceptable options available for compliance with the Standard, depending on its size and configuration.

The first option is to have Grade A fire alarm system installed throughout the building. This type of system consists of a conventional or addressable fire alarm panel, and then fire alarm detectors, call points, sounders and beacons are specified according to the layout and requirements of the property and manufactured to BS EN 54. It also requires a power supply to BS EN 54-4, and installation to BS 5839 Part 1.

However, in most cases, this level of coverage is not a requirement. In some small HMOs, for example, it may be acceptable to install a Grade D1 system. This is defined as a system incorporating one or more interlinked mains-powered smoke alarms (and heat alarms if required), each with an integral stand-by supply. They can be hardwire-interlinked or radio-interlinked, meaning that fire alarm panels are not required. The stand-by supply must be tamper-proof and last the full life of the alarm.

The final option, suitable for many medium and even large HMOs, is a mixed system. This involves the installation of Grade A components in communal areas, and any other high-risk areas identified by the risk assessment. Elsewhere in the premises, a separate Grade D1 system can be installed. This has become the preference, as it is likely to reduce the impact of nuisance alarms from individual flats on other occupants.

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Fire detection categories

The coverage within the building by the detection system is divided into three distinct categories. These are described with the following codes:

LD1 (highest level of coverage): Covers all circulation spaces that form part of escape routes plus all rooms in which a fire could start

LD2 (middle level of coverage): Covers all circulation spaces that form part of escape routes plus all rooms and areas that present a high fire risk to occupants

LD3 (lowest level of coverage): Covers circulation spaces that form part of the escape routes

Diagram showing levels of fire detection systems in HMOs

Any room which a building user must pass through, from another, in order to exit the premises would need detectors installed to satisfy these Categories. For example, if all rooms in a bungalow open onto a hallway which leads outside, only the hallway is considered a circulation space forming part of the escape route; if the only exit from the kitchen is into the dining room which then opens onto a hallway, the dining room would also need a detector under LD3 minimum protection as it is part of the escape route.

What category of fire detection is required within my HMO?

Different levels of coverage are needed in different areas of the building due to the risk of fire. This includes different Grades of fire detection system, as well as different configurations of components. For example, communal areas in HMOs are required to have Grade A systems, as they have particularly high levels of risk. This is due to the shared, and therefore often neglected responsibility for safety and housekeeping in HMOs. Moreover, the exact installation requirements within your HMO will depend upon the configuration and size of the premises. For more advice for landlords about fire safety in HMO’s, visit our help guide.

Messy kitchens are a health risk, and a fire hazard. — Responsibility for housekeeping can be neglected in HMOs. This is a fire risk,

Minimum levels of requirements for fire detection systems in HMOs:

The following is general guidance on the minimum levels of installation required in different scenarios.

One or two storey HMOs, where the area of each floor is less than 200sqm:

A Grade D1, category LD1 configuration should be installed in a new, or materially altered HMO. In an existing premises of this size, category LD2 is acceptable if it is already installed, but an LD3 system must be upgraded to comply with the Standard.

Areas within HMOs with more than 3 floors, or where the area of at least one floor is greater than 200sqm

Individual, one-room dwellings, with or without cooking facilities:

A Grade D1, category LD1 configuration should be installed. This is required in a new and existing HMO premises.

Individual dwellings comprising two or more rooms:

A Grade D1, category LD2 configuration should be installed. This is required in a new and existing HMO premises.

Communal areas

A Grade A, category LD2 configuration should be installed. This is required in a new and existing HMO premises.

Suitable Fire Detection Systems in HMOs

Always ensure that a comprehensive fire risk assessment has been carried out in your property by a competent person, to determine the risks specific to your premises. This is essential to protect the occupants, particularly as many tenants of HMOs are young and / or vulnerable renters. The Responsible Person for the building may be prosecuted if they cannot demonstrate that they have made every reasonable effort to comply with fire safety requirements enforced by their local council, particularly if a fire breaks out. Compliance with the Standards is the best way to ensure that this compliance can be achieved and evidenced.

For additional guidance, please visit our Smoke Alarm Help and Information and BS 5839 summary page.

Tuesday 6th December 2011

Occasionally, a heated discussion flares up when a housing association or landlord removes extinguishers from a HMO or from flats with the argument that the extinguishers would do more harm than good in the hands of untrained tenants. Their decision is based on the fear that people might risk their lives fighting a fire rather than leaving the building and that the tenants might injure themselves by incorrect use of an extinguisher. Fear of vandalism and the difficulty of maintaining and assuring the working order of the extinguishers between the yearly services is of course also a consideration.

The latest case was in Richmond:

‘Residents in Richmond have been told that portable fire extinguishers have been removed from the common parts of their housing blocks for their own safety, following the findings of a fire risk assessment.’ (info4fire 16/11/2011)

However, this case was not unique, already in 2008 a similar occurance happened in Bournemouth:

‘An independent fire risk assessment ruled the extinguishers were a hazard to untrained users and may encourage people to fight a blaze. People in flats at Avon House in West Cliff Road, Bournemouth, received letters asking to remove the equipment.’ (BBC 11/03/2008)

In both cases the recommendation was based on fire risk assessments carried out by external fire risk assessors.

The reaction by the fire safety industry and the general public was instant and sometimes fierce. Typical reactions were:

‘Surely the sensible option would be to inform residents about the practical use of handling a fire extinguisher, rather than removing them altogether’ (IFEDA Nov 2011)

‘Now burn to death in safety. Here’s another couple of examples of elf’n’safety idiocy.’ (Daily Mail Nov 2011)

What is the legal situation?

It is right and correct that Fire Risk Assessments, either carried out by the landlords or by external specialist companies, work out what the risks are in a building and what protection is appropriate for the building and its occupants; and the fire risk assessor must balance the building’s construction, its inhabitants and other factors when deciding how to achieve fire safety for the tenants. The fire risk assessment can lead to certain fire protection measures to be reduced if on the other hand other fire protection measures are strengthened, eg the type of fire alarm system might be downgraded if a sprinkler system is installed etc. However, there are guidelines which, while fairly loose, describe general recommendations which must be taken into consideration. The fire risk assessment guides created for the different type of businesses/buildings help assessors and owners to come to a reasonable conclusion.

For landlords the fire risk assessment guide ‘sleeping accomodation’ is relevant. The guide states that in cases where the main risk stems from fires involving wood, paper and textiles (not kitchen areas):

‘Typically (..) the provision of one water-based extinguisher for approximately every 200 suare meters of floor space, with a minimum of two extinguishers per floor, will normally be adequate. (..) ideally no one should have to travel more than 30m to reach a fire extinguisher.’

For landlords and HMOs specifically, there is also a useful fire safety guide from LACoRS, which brings together the main rules regarding fire safety in HMOs and let properties into one easy-to-understand guide.

This guide states on page 28:

‘The provision of fire blankets and simple fire extinguishers can be useful in restricting the development and spread of small fires in their early stages. However, unless a fire is very small, the best advice is to evacuate the building (..) This is because for larger fires people need training to know what type of fire extinguisher can safely be used on, how to tackle a fire safely, and when to give up and get out. The installation of extinguishers can also lead to problems if they are not properly maintained or where equipment is discharged through malice or horseplay. For these reasons extinguishers are not recommended inside units of accomodation unless there are resident staff who are trained in their use (a caretaker, housekeeper, warden or similar)’

Although this sounds as if LACoRS is advising against installation of extinguishers, it carries on in the next paragraph:

‘In order to provide a facility for extinguishing small fires in their early stages, a simple multi-purpose extinguisher is recommended on each floor in the common parts of HMOs and buildings containing flats. It will not usually be practical to train tenants in the use of them, but basic advice should be offered at the start of each new tenancy.’

This positive confirmation of the need for extinguishers was later on re-emphasised in an update to the LACoRS guide in December 2008:

‘The positioning of portable fire extinguishers in the communal areas is deemed appropriate in order to help occupiers deal with small scale fires in their early stages and to aid their escape from the building.’

This time the guide clearly accepts the use of extinguishers by occupiers rather than just resident staff!

The LACoRS guide is unclear about the type of extinguisher to be installed. From our own experience, however, we would advise against powder extinguishers in communal areas, although powder extinguishers are of course the most general extinguisher commercially available. Water (with additives to avoid self-electrocution) or foam extinguishers are more suitable, as the damage in case of misuse and the risk of inhalation is substantially lower than with powder extinguishers.

Whilst there are confusing signals and guides out there, the consensus appears to be that fire extinguishers are very valuable when dealing with small fires at an early stage. As to the question ‘are they required in the communal areas to meet legislation’ there is still no clear answer. It would appear that this recommendation is subjective and the outcome is dependant from the individual assessor. The new register for fire risk assessors may influence this in the future. The register will provide those wishing to outsource their fire risk assessment to a third party with a database of qualified assessors.

Tag: hmo

Requirements for Fire Detection Systems in HMOs