HHSRS fire safety assessments

Local authorities have a duty to keep housing conditions in their area under review.

Following the fire at Grenfell Tower, the Ministry of Housing, Communities and Local Government (MHCLG) issued a direction requiring that authorities identify potential risks from unsafe cladding in high rise residential blocks.

A fire hazard may also become apparent because of a complaint by a tenant, during the process of licensing a house in multiple occupation (HMO) or for another reason.

A full inspection and assessment may be necessary if the review results in particular properties being identified as potentially unsafe.

When inspecting a property under the Housing Health and Safety Rating System, the environmental health officer considers the likelihood of a fire that could cause harm occurring, and the severity of the harm.

The inspector looks at factors including:[1]

• heater /cooker position – inappropriate position and/or close proximity of flammable materials

• space heating – whether it is inadequate for the whole of the dwelling and thus encourages the use of supplemental heaters

• defects to heating – defects or disrepair to appliances or system

• clothes drying facilities – lack of indoor facilities

• number/position of sockets – insufficient and/or inappropriately sited electric socket outlets

• electrical installation – defects to the supply, meters, fuses, wiring, sockets or switches

• non- fire resistant fabric – allowing fire to spread

• smoke permeable fabric – allowing smoke to spread

• fire stops to cavities – lack of, allowing fire to spread

• disrepair to fabric – walls, ceilings and/or floors may allow smoke, fumes and/or fire to spread

• internal doors – insufficient doors, doors of inappropriate materials, or ill-fitting doors

• self- closers (the mechanisms which make doors close automatically) – lack of effective self-closers where appropriate

• smoke /heat detectors – lack of, or defective, smoke and/or heat detectors with alarms or of detection and alarm system

• fire fighting equipment – lack of adequate and appropriate means of primary fire fighting

• lightning protection system – lack of a system where appropriate

Matters relevant to the severity of the outcome should a fire occur include:[2]

• smoke /heat detectors – lack of or defective smoke and/or heat detectors with alarms or of a detection and alarm system

• means of escape – inadequate safe means of escape in case of fire

• combustible furnishings – including furniture and furnishings

• fire fighting equipment – lack of adequate and appropriate means of primary fire fighting

• lightning protection system – lack of a system where appropriate

Assessment of the conditions within homes and the common parts of buildings can be carried out by means of the Housing Health and Safety Rating System

The local authority can use any of the powers under Part 1 of the Housing Act to reduce any fire risks identified in an inspection.

A local authority cannot take enforcement action against itself under the system.[3]

In November 2018, MHCLG published an Addendum for the profile for the hazard of fire and in relation to cladding systems on high rise residential buildings. The document was issued to provide guidance for local authorities on the assessment of high-rise residential buildings with unsafe cladding. It is meant to be read and used in conjunction with the hazard profile for fire as set out in Annex D of the Housing Health and Safety Rating System Operating Guidance.

In 2011 the Local Government Association published fire safety guidance for housing providers and enforcing authorities on how to undertake fire risk assessments and how to understand the relevant legislative requirements relating to blocks of flats (regardless of tenure). The guidance is being revised at the moment and an updated version is expected to be published later in 2021.[4]