Response
to Emergency Evacuation Sharing Information Consultation
17
August 2022
Summary
The
Mayor of London reiterates his view that legislating for Personal Emergency
Evacuation Plans (PEEPs) in all buildings of any height covered by
the Fire Safety Order, and providing central funding, is the only way to ensure there is
comprehensive and consistent implementation across the entire country.
The
proposals set out in this consultation on Emergency Evacuation Sharing
Information (EEIS) amount to little more than a watered-down version
of PEEPs. The Mayor has identified several of limitations to the EEIS proposals and has
detailed them below.
Government’s
ongoing failure to implement this recommendation from Grenfell Tower Inquiry is disappointing and
concerning. Government must ensure that the recommendations from the Grenfell Tower Inquiry
do not become a missed opportunity for change, as was the case after the Lakanal House fire.
Five
years on from the Grenfell fire, the Mayor pays tribute to the bereaved and
survivors who are campaigning for change so that a disaster like
Grenfell never happens again.
Response
to consultation
Following
the tragic loss of life in the fire at Grenfell Tower, in which 41 per cent of residents
with disabilities
died, the Grenfell Tower Inquiry recommended that owners and managers of every high-rise residential
building be required by law to prepare PEEPs for all residents whose ability toself-evacuate
may be compromised (such as persons with reduced mobility or cognition).
Given
that 83 per cent of respondents to the original PEEPs consultation in 2021
supported the proposal,
it is clear that there is significant demand for this recommendation to be
implemented in full.
The
Mayor is pleased to read that a working group of disabled groups and housing
providers is being
set up by government and would stress that the group membership must be diverse
and reflect
all views, including those who would benefit from PEEPs. It is vital that the working
group considers
and establishes the best way to implement PEEPs in practice.
While
the call for evidence on PEEPs is welcome, government should also be conducting
pilot schemes
and undertaking research to make a more informed assessment of PEEPs in
residential housing.
The Mayor hopes that this would lead government to reconsider its latest
position.
Following
a commitment to implement PEEPS fully, the evidence collected from this process
could then
inform a nationwide protocol, guidance and training on how the housing and
development sector
could implement the requirements of any legislation on PEEPs.
The
Emergency Evacuation Information Sharing (EEIS) consultation released on 18 May
2022 proposes
alternative measures to protect the fire safety of residents who would need
support to evacuate
in an emergency. This proposal differs from PEEPs in a number of key ways.
First, it only focuses on residents who are mobility impaired as
opposed to those with other physical or cognitive
impairments. Second, it only applies to buildings with a simultaneous
evacuation strategy and not buildings with a stay put strategy. Third,
it proposes five steps that involve conducting a Person Centred Fire Risk Assessment (PCFRA)
as opposed to a PEEP, and then sharing information with the local Fire and
Rescue Service (FRS). Fourth, it relies on the FRS to conduct rescues of those who would be unable to
self-evacuate.
1.
Scope
The
Mayor is concerned that EEIS only focuses on residents that are mobility
impaired and urges government to take a more inclusive approach.
People who may be unable to self-evacuate include those with mobility issues but also those
with other physical and cognitive impairments which may be permanent or
temporary.
2.
Building fire strategy
The
Grenfell Tower Inquiry recommended PEEPs for all high-rise residential
buildings and government
consulted on that proposal on 8 June 2021. Government is now proposing to
introduce EEIS –
a watered down version of PEEPs – only for buildings with a simultaneous
evacuation strategy
in place. Under these proposals, those buildings with a stay put policy in place
would not be
required to provide EEISs for relevant residents. It is welcomed that
government has moved away from using height as a distinguishing factor,
but the new categorisation of fire strategy cannot be the correct approach
either. A resident affected by smoke or fire must have a plan and means to get to a place of
safety, regardless of whether the building has a stay put or simultaneous evacuation
policy. Grenfell
Tower was a building with a stay put policy and 72 people lost their lives. The
Grenfell Tower
Inquiry Phase 1 report recommended government develop national guidelines for evacuation of high-rise
buildings as a result. It is clear that stay put cannot be the only strategy
and all
buildings must have a Plan B so that residents can evacuate to a place of
safety if stay put is no longer viable.
Since
Grenfell, countless buildings have been found to have fire safety defects and
have therefore been forced to change their fire strategy to
simultaneous evacuation until remediation is complete.
Linking
EEIS to buildings with simultaneous evacuation risks suggesting building owners
can retire EEISs
once the building has been remediated. That was never the intention of the
Grenfell Tower Inquiry recommendation around PEEPs.
3.
Person Centred Fire Risk Assessments (PCFRAs)
A
PCFRA is a risk assessment that helps identify residents who are at higher risk
from fire in their own flat. It differs from a PEEP in that it is not
a bespoke escape plan to assist residents who may have difficulties in evacuating a building
unaided during an emergency.
The
EEIS consultation proposes a process whereby the Responsible Person (RP) offers
a PCFRA to residents
who self-identify as requiring assistance to self-evacuate and then connects
them with the
local FRS to arrange a home fire safety visit.
The
Mayor is content with the proposed reliance on self-identification but notes
that its success relies on proactive communications from the RP.
These communications should encourage residents to consider whether they need
support and inform them of their rights.
PCFRAs
will help identify residents who are at higher risk from fire in their own
accommodation and measures such as fire-retardant bedding and fire
safe ashtrays can be put in place for them in their homes. While PCFRAs are
welcome and indeed already being undertaken now by some RPs, they focus
on reducing the probability of fire inside someone’s flat and, unlike a PEEP,
they do not incorporate
an evacuation plan.
4.
Reliance on FRS conducted rescue
The
consultation makes the following argument against PEEPs: ‘the time between a
fire being reported
and the FRS mounting their operational response at the scene is the period in
which a PEEP
would be enacted. In a residential setting, there will inevitably be a limit as
to what could be safely achieved by a single staff member or even a
small team regarding support to mobility impaired
residents in advance of the FRS attending with a greater number of competent,
trained personnel.’
In other words, government is claiming there is insufficient time for a PEEP to
add value and
that FRS conducted rescue is always preferable.
The
Mayor does not agree with this view for two reasons. First, the time that FRS
takes to arrive at an emergency may be quick, but the time taken to
actually set up a bridgehead, hoses and get into a position to fight fire and rescue residents
in tall buildings is far greater. In reality there is more time
for a PEEP to be effective than government is suggesting.
Second,
expert evidence in the Inquiry has underscored the importance of timely
evacuation to avoid
serious and potentially fatal smoke inhalation. This highlights the risk
inherent in the EEIS approach which relies solely on FRS conducted rescue
instead of supporting self-evacuation.
