HMO Fire Risk Assessment Duties

Managing a House in Multiple Occupation (HMO) brings specific legal responsibilities regarding fire safety. Because these properties house multiple unrelated people, the risks are higher than in a standard family home. Under the Regulatory Reform (Fire Safety) Order 2005 (RRO), the person responsible for the premises must ensure a suitable and sufficient fire risk assessment is in place.

The Responsible Person

For an HMO, the Responsible Person is usually the landlord, managing agent, or anyone with control over the premises. Under Article 9 of the RRO 2005, this individual must make a fire risk assessment of the premises. In an HMO, the 'premises' generally refers to the common areas—such as hallways, staircases, kitchens, and shared living rooms—rather than the individual private bedrooms.

However, local authorities often enforce higher standards for HMOs under the Housing Act 2004. This means that while the RRO applies to common parts, many fire safety measures, particularly within the individual letting units, are managed through the licensing scheme enforced by the local housing authority. Landlords must navigate both sets of requirements to remain compliant.

Specific Hazards in HMOs

HMOs present unique fire safety challenges due to the density of occupation and the layout of the building. A thorough assessment must consider:

• Cooking facilities: Multiple kitchens or shared cooking facilities increase the likelihood of fires starting.
• Escape routes: Longer escape routes due to the size of the property or the location of bedrooms.
• Smoking: Areas where residents smoke, which must be controlled and separated from combustible materials.
• Waste storage: Accumulation of rubbish in shared areas, which can be a fuel source.
• Furnishings: Ensuring upholstered furniture meets safety standards (e.g., match resistance) to prevent rapid fire spread.

Fire Detection and Warning Systems

Standard domestic smoke alarms are often insufficient for larger HMOs. The assessment must determine if a full fire alarm system is required. This is often dictated by British Standards, specifically BS 5839-6, which provides guidance on fire detection and alarm systems for dwellings.

Depending on the size and layout of the HMO, you may need:

• Mains-powered interlinked smoke detectors.
• Heat detectors in kitchens.
• A manual call point (break glass) at the final exit.
• A fire alarm control panel.

The system must be adequate to warn all residents in time to escape. Regular testing and maintenance are essential to ensure the system works when needed.

Means of Escape

The primary goal of fire safety in an HMO is to ensure residents can escape safely if a fire occurs. The assessment must scrutinise the escape routes. Guidance often references BS 9991, which covers fire safety in the design, management, and use of residential buildings.

Key considerations include:

• Protected routes: Hallways and staircases must be protected by fire-resisting construction (typically 30 minutes) and fire doors to prevent smoke and fire entering the escape route.
• Final exits: Doors leading to the outside must be easily openable without the use of a key.
• Emergency lighting: If the escape route is windowless or complex, emergency lighting may be required to guide residents to safety in the event of a power failure.
• Signage: Clear fire exit signs where the escape route is not immediately obvious.

Fire Safety Equipment and Maintenance

Beyond alarms, HMOs often require specific firefighting equipment. This typically includes fire extinguishers and fire blankets, usually located in the kitchen areas. The type and rating of extinguishers should be appropriate for the risks present (e.g., Class F for cooking oils).

Under the RRO, the Responsible Person must ensure that all fire safety facilities, equipment and devices are maintained in efficient working order and in good repair. This includes:

• Regular testing of the fire alarm system.
• Annual servicing of extinguishers by a competent person.
• Routine checks on emergency lighting.
• Inspection of fire doors to ensure they close correctly and intumescent strips are intact.

Professional Assessment

Given the complexity of HMO regulations, relying on a generic template is rarely sufficient. PAS 79 provides a methodology for fire risk assessment, recommending that the assessor is competent to understand the nature of the risks and the appropriate standards.

At HawkSwift Ltd, we provide fire risk assessments from £199 + VAT. Our NEBOSH-qualified assessors understand the specific demands of HMO legislation and British Standards. We aim to deliver your comprehensive report within 48 hours, giving you clarity on your compliance status.

If you are unsure whether your current assessment meets the necessary legal standards, you can book a fire risk assessment with our team today.

*This article is for general guidance only and does not constitute formal legal advice. Landlords should refer to the specific legislation and consult with their local authority or a fire safety professional where necessary.*