Fire Safety in Houses of Multiple Occupation

What This Requirement Covers

Houses in Multiple Occupation (HMOs) present a higher fire risk than single-household dwellings because multiple unrelated occupants share circulation spaces, cooking facilities, and escape routes. Fire safety in HMOs is governed by a combination of the Housing Act 2004, the Regulatory Reform (Fire Safety) Order 2005, and the LACORS Housing Fire Safety guidance.

Where an HMO is created through conversion, Building Regulations (Approved Document B) also apply to the building works.

Key Requirements

Fire Detection and Alarm

The level of fire detection depends on the building size, layout, and risk

1. Small HMOs (up to 2 storeys, shared house): Grade D1 LD3 system minimum - interlinked mains-powered smoke alarms in circulation spaces, plus heat alarm in kitchen
2. Medium HMOs (3 storeys, or bedsit accommodation): Grade A LD2 system - interlinked alarms with a control panel, detection in escape routes, kitchens, and high-risk rooms
3. Large HMOs (4+ storeys, or high-risk): Grade A LD1 system - full automatic detection in all rooms and circulation spaces, with a conventional or addressable fire alarm panel

Means of Escape

1. Every letting room must have a route of escape that does not pass through another letting room or a high-risk area (kitchen)
2. Protected escape routes: Walls and ceilings of hallways, landings, and stairways must achieve at least 30 minutes fire resistance
3. Dead-end corridors should not exceed 7.5 metres to the nearest alternative escape route or stairway
4. An inner room arrangement (where escape from one room is only through another) is generally not acceptable in HMOs

Fire Doors

1. FD30S fire doors are required to all letting rooms, kitchens, and any room opening onto the escape route
2. All fire doors must have self-closing devices, intumescent strips, and cold smoke seals
3. Kitchen doors must be fitted with a self-closing device that can maintain the door in the closed position
4. Existing panel doors may be upgraded with fire-resisting sheet material, but must be confirmed by a fire door assessor

Emergency Lighting and Signage

1. Emergency lighting to BS 5266-1 is required in all common escape routes in HMOs of three or more storeys
2. Fire exit signage complying with BS 5499 (or BS EN ISO 7010) is required where the escape route is not obvious
3. Emergency lighting must provide a minimum of 1 lux on the centre line of the escape route for at least 3 hours

Fire-Fighting Equipment

1. A fire blanket compliant with BS EN 1869 should be provided in or near each shared kitchen
2. Portable fire extinguishers may be required by the fire risk assessment but are not mandatory in all HMOs
3. The LACORS guidance recommends a 13A-rated extinguisher on each floor in larger HMOs

Licensing Requirements

1. Mandatory licensing applies to HMOs of 5 or more occupants forming 2 or more households, regardless of storeys (since October 2018)
2. The licence conditions typically include fire safety requirements as set out in the LACORS guidance
3. Local authorities may impose additional licensing schemes covering smaller HMOs in their area
4. Failure to licence an HMO can result in unlimited fines and rent repayment orders

Practical Compliance Tips

1. Obtain a fire risk assessment before letting the property; this is a legal requirement under the Fire Safety Order
2. Use the LACORS guidance as the benchmark for fire safety standards; most local authority inspectors will assess against it
3. Ensure all fire doors are third-party certified and installed by competent persons
4. Test the fire alarm system weekly and keep a log book
5. Provide fire safety information to all tenants at the start of their tenancy
6. Do not use wedges or hooks to hold fire doors open; if hold-open devices are required, use electromagnetic holders linked to the fire alarm
7. Review the fire risk assessment annually and after any change in the building or its occupants