London Mayor Demands Landlords draw up PEEPs

In an open letter the London Mayor Sadiq Khan issued a demand that building owners and managers draw up personal emergency evacuations plans (PEEPs) for disabled residents of all buildings covered by the Fire Safety Order regardless of height.

The need for Personal Emergency Evacuation Plans (PEEPs) has gained extra significance in the wake of the Grenfell fire tragedy in 2017. This culminated in 41 per cent of disabled residents losing their life. As part of his phase one recommendations, Grenfell Inquiry chair Sir Martin Moore-Bick recommended the adoption of Personal Emergency Evacuation Plans (PEEPs) for all those living in high-rise buildings unable to self evacuate.

In a statement as the letter was published, Mr Khan said:

“The Grenfell Tower fire was a devastating tragedy and we will always remember the 72 innocent Londoners who lost their lives.
“We owe it to those who died, those who lost loved ones and those who survived the fire, to do everything we can to ensure nothing like this ever happens again.
“Two years on from the phase one report from the Grenfell Tower Inquiry, London Fire Brigade has been working to put in place all the recommendations made to the fire service as swiftly as possible.
“I’m pleased that the brigade has completed the vast majority of the recommendations – including new training for the 999 control room and the introduction of ‘smoke hoods’, allowing residents to be evacuated from buildings more safely – but there is more work to be done to see the changes fully implemented.”
“I remain deeply concerned that four years on from the Grenfell tragedy those in high-rise building are still living in fear.
Sadiq Khan

Mayor's Key Recommendations

With over 1,000 buildings in London deemed unsafe, Mr Khan said he ‘would not wait for legislation’ where safety improvements can be made now. He urged building owners and manager to make urgent progress to implement three key recommendations immediately. These are :

Floor numbers to be clearly marked on each landing within the stairways of high-rise buildings; in a prominent place in all lobbies to be visible in normal conditions and in low lighting or smoky conditions.

The owner and manager of every residential building containing separate dwellings to carry out an urgent inspection of all fire doors to ensure that they comply with applicable legislative standards.

All buildings to contain a premises information box, the contents of which must include a copy of the up-to-date floor plans and information about the nature of any lift intended for use by the fire and rescue services.

Viability of the Mayor’s demand for PEEPs

The Mayor of London should be applauded for his desire to implement fire safety measures that go beyond building regulations and in advance of additional safety legislation.

However, the demand that building owners and managers implement PEEPs is far from straightforward, and presents several practical challenges.

In a commercial building the Responsible Person is obligated to create, write and subsequently execute any Personal Emergency Evacuation Plan that might be in place. The key point is that someone is employed in a role that includes the execution of a PEEP if required.

By contrast, in most residential buildings there are no building management staff employed on site. Some of the largest and most luxurious blocks have a concierge, but this is the exception. This then poses the question of who will execute any PEEP that is in place?

Who will execute a PEEP in a residential block?

A fire could occur in a building at any time of day or night. The logical conclusion is that one or more residents would have to take on the responsibility of executing a PEEP.

However, this proposition assumes that at the very least one, or more realistically, several people in a block would be prepared to take on this role. This is no small obligation, as it assumes life safety responsibility for a vulnerable person.

Assuming sufficient residents could be found to take on the responsibility, they would need training. This would need to be to a similar standard to that given to a Fire Marshall in a commercial setting. It could possibly include the use of an evacuation chair or other specialist equipment. This latter point brings a further consideration; any volunteer Fire Marshalls would need to be fit and healthy; physical capable of evacuating an individual in an evacuation chair down multiple stories.

Finally, there’s the question of who would have ultimate responsibility should something go wrong whilst executing a PEEP? The Fire Safety Order and emerging Building Safety Bill places onerous legal obligations on the Responsible Person; usually the building owner or manager. Do these responsibilities transfer to the volunteer residents executing PEEPs? If so who then bears responsibility should something go wrong?

So several dutiful, well-built humanitarians per block? With scant regard for their personal safety or the legal consequences of any failure to act? Short of moving firemen in to live in every one of the 1,000 unsafe blocks in London, how will this be achieved?

Conclusion on Mayor's demand for PEEPs

In conclusion, the Mayor’s demands for landlords and building owners to devise evacuation plans for disabled residents is laudable; but it does nothing to address the practical issues of evacuating vulnerable residents and improving fire safety.

The most advantageous solution for a Responsible Person is to ensure their building Fire Risk Assessment (FRA) is current, suitable and sufficient.

A Type 1 FRA carried out by a competent individual should identify whether there is a need for a more detailed Type 4 assessment. This would identify any deficiencies in a building that might overturn a “Stay Put” Evacuation strategy. It is only in these circumstances that building owners and managers would need to draw up PEEPs for vulnerable residents.

Perhaps next time the Mayor might consider the practical nuances before making announcements on Fire Safety.

Contact

To commission a Fire Risk Assessment or EWS1 Survey please call 020 4534 3130.

Also see other related articles including Fire Safety Canges for Upward Extension Permitted Development, and how MPs reject fire safety bill amendment.

For more information on the Mayor's demands for (PEEPs), or advice on your fire safety obligations as a Responsible Person, please contact :

To commission a Fire Risk Appraisal of External Walls survey (FRAEW) or Fire Risk Assessment (FRA) please call 020 4534 3130.

For further information on FRAEW Surveys, PAS9980, EWS1 forms or advice in respect of your obligations as a building owner, developer or manager, please contact :