Working for tenants and residents

Fire Safety and Evacuation Arrangements in high-rise buildings

TAROE Trust Position Statement 

TAROE Trust is aware that the issue relating to fire safety and evacuation arrangements remains an area of significant concern to tenants. 

A Government review into requirements for establishing Personal Emergency Evacuation Plans (PEEPs) has been paused, and particular concerns exist over information collection requirements around vulnerable residents and where responsibility for the preparation of PEEPs rests. Moreover, the PEEPs consultation as previously issued appears to have been developed and written for managed office buildings and not residential buildings. The latter will often not have staff on-site 24 hours per day, and to do so would involve increasing service charge costs which ultimately have to be borne by the residents of the building. Consequently, it is often unlikely that a building owner would be able to get a member of staff on-site ahead of the fire service in the event of an emergency situation arising. 

We believe that the fire safety regime in a building is analogous to a stack of dominoes, with each element of the safety regime having to work perfectly all of the time for it to be effective. Of course, no system can be 100% perfect. Sprinklers add complexities to the system. 

As such, we believe the following is required: 

  • A pragmatic, resident centred approach is required that recognises that events do not always go according to plan and which takes account of what residents believe is required for their building in the event of an emergency situation arising. 
  • Building owners need to foresee the potential need to evacuate a high-rise building, which may arise for a variety of reasons, some of which may be difficult to foresee in advance and establish plans for such accordingly. In short, a reliance “only” on ‘stay-put’ approaches is flawed and naïve. 
  • Landlords responsible for managing high-rise buildings need to provide information to the fire service in advance on: 
    • The needs of residents within the building and which persons are unable to self-evacuate;
    • The provision of on-site equipment (e.g. evacuation chairs). 
  • In the event that Government legislates to require 24/7 on-site staff in all high-rise buildings, it would be necessary for all building owners to comply. However, this would result in many cases in a significant increase in service charges for residents. Consequently, we believe such requirements should be subject to the individual collective preferences of residents within a given building. 
  • Landlords should not allocate any properties to residents in high-rise buildings where they are unable to self-evacuate. 
  • We acknowledge that the needs of existing residents change over time. Therefore, where the needs of residents living in a high-rise building change so that they are unable to self-evacuate from a high-rise building in the event of an emergency situation arising, they should be offered a top priority by their landlord for re-housing in a property that meets their needs more appropriately. This does not mean that such residents would be “required” to move to a more suitable property, but the option provided. It is acknowledged that in reality, the ability of a landlord to do this in some cases may be constrained by the availability of alternative suitable accommodation. This should not be a bar to operating this policy but it is recognised that the practical implementation of this policy may in some circumstances be difficult to achieve. 
  • It should be mandatory for all high-rise building owners to operate full practice and evacuation drills in partnership with the fire service. Evacuations are not exclusive to fires and may be required in other circumstances. The practice of such drills will highlight the challenges and difficulties to both building owners and residents of this exercise and provide an opportunity to amend plans for the future. 

September 2022

This position statement was developed as a result of discussions held between Trustees of TAROE Trust. This includes representatives of landlords as well as tenants and other experts in the housing field. We would welcome feedback on whether there are difficulties with the position statement outlined so that we may consider and review position if required.