PFD report

Ashlie Timms · Prevention of Future Deaths report

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Issued 26 Apr 2022•East London

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

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Concerns
7

Raised in this report

Recipients
4

Named on the report

Responses found
4

Of 4 recipients

Stated actions
36

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised7

  1. Non-compliant fire alarms lacking automatic links to an Alarm Receiving Centre
    Part of recurring concern: Inadequate fire detection and emergency notification for vulnerable people in housing
  2. Lack of clear practical guidance for managing high-risk electrical devices in specialist housing
    Part of recurring concern: Failure to ensure clear and followed instructions for safe equipment use
  3. Insufficient emphasis on British Standard recommendations for automatic fire alarm connections to Alarm Receiving Centres
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.20

  1. Action

    Lead the review of the competency framework for Fire Safety Regulators and the enforcement toolkit for high-rise buildings.

    Stated by National Fire Chiefs CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 April 2022.
  2. Action

    Influence the content of new or amended fire protection and safety standards.

    Stated by National Fire Chiefs CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 April 2022.
  3. Action

    Report the staff competency concern to relevant committees to encourage debate and pursue improved outcomes.

    Stated by National Fire Chiefs CouncilStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.15

  1. Position

    Enforcement of fire safety regulations is outside the organisation’s functions because it is not an enforcing authority and has no regulatory functions.

    Stated by National Fire Chiefs CouncilOutside remitThe respondent said that this matter was outside its role or authority.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Non-compliant fire alarms lacking automatic links to an Alarm Receiving Centre

Wider context from the report

“2. Fire Alarms in three units operated Sequence Care Group remain non-compliant with the 2013 British Standard Guidance, which recommends that they should have a link to an Alarm Receiving Centre (“ARC”) which automatically contacts the emergency services when a fire alarm is activated. ”

Is this part of a recurring concern?

Yes — Inadequate fire detection and emergency notification for vulnerable people in housing.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of clear practical guidance for managing high-risk electrical devices in specialist housing

Wider context from the report

“4. No clear and practical guidance exists on how specialist housing operators should manage the use of high-risk electrical devices such as portable electric fan heaters. ”

Is this part of a recurring concern?

Yes — Failure to ensure clear and followed instructions for safe equipment use.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient emphasis on British Standard recommendations for automatic fire alarm connections to Alarm Receiving Centres

Wider context from the report

“6. Insufficient emphasis is placed upon recommendations contained within British Standards regarding automatic connections to ARCs in fire alarms fitted in specialist accommodation. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Incomplete fire safety audit processes

Wider context from the report

“3. The London Fire Brigade conducted fire safety audits at the premises which assessed the unit as displaying the highest standard of fire safety compliance. These findings were found to be entirely incongruent with procedures, equipment and staff training in place before and at the time of the fire. The London Fire Brigade have reviewed and changed processes since 2018 but they remain incomplete. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of clear guidance on fitting digital key-pad locks in specialist housing

Wider context from the report

“5. No clear guidance exists regarding the fitting of digital key-pad locks on doors in specialist housing. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of fire safety audits to accurately assess compliance

Wider context from the report

“3. The London Fire Brigade conducted fire safety audits at the premises which assessed the unit as displaying the highest standard of fire safety compliance. These findings were found to be entirely incongruent with procedures, equipment and staff training in place before and at the time of the fire. The London Fire Brigade have reviewed and changed processes since 2018 but they remain incomplete. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to ensure staff competence in fire evacuation procedures

Wider context from the report

“1. The operator of the premises failed to ensure that staff on duty were competent to carry out a fire evacuation. Despite reflection and remediation in policies, processes and training, multiple staff members who gave evidence to the inquest, remained unable to describe the proper action to take in the event of a fire alarm. ”

Is this part of a recurring concern?

Yes — Failure to ensure staff competence in fire safety and evacuation.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Lead the review of the competency framework for Fire Safety Regulators and the enforcement toolkit for high-rise buildings.

Verbatim wording from the response

“1. The NFCC will redouble its efforts in progressing such work mentioned above and that it is responsible for. This extends to influencing the content of new or amended fire protection and safety standards. The NFCC is also currently leading the review of the competency framework for Fire Safety Regulators (which includes FRS inspecting and enforcement officers) and enforcement toolkit for high rise buildings and have in the past year launched a third-party professional accreditation scheme for Fire Safety Regulators and a national learning platform to underwrite the continual professional development of such officers.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Influence the content of new or amended fire protection and safety standards.

Verbatim wording from the response

“1. The NFCC will redouble its efforts in progressing such work mentioned above and that it is responsible for. This extends to influencing the content of new or amended fire protection and safety standards. The NFCC is also currently leading the review of the competency framework for Fire Safety Regulators (which includes FRS inspecting and enforcement officers) and enforcement toolkit for high rise buildings and have in the past year launched a third-party professional accreditation scheme for Fire Safety Regulators and a national learning platform to underwrite the continual professional development of such officers.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Report the staff competency concern to relevant committees to encourage debate and pursue improved outcomes.

Verbatim wording from the response

“The NFCC represent FRS on various British Standards Institute (BSI) committees and other groups such as National Social Housing Fire Safety Group.”

Source location

Response from National Fire Chiefs Council
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Work with the Home Office on guidance review and revision to address risks concerning high-risk electrical devices and digital keypad locks.

Verbatim wording from the response

“Pursuant to Article 50 of the Order,¹¹ the Secretary of State must ensure that guidance (Guidance) is issued to assist those responsible for fire protection and fire safety within premises to which the Order applies. A full review and improvement of the Guidance is in progress and is being superintended by the Home Office.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Report the alarm connection concern to relevant British Standards committees to encourage debate and pursue improved outcomes.

Verbatim wording from the response

“The NFCC represent FRS on BSI committees including the overarching committees for fire detection and alarm systems (FSH12) and fire precautions in buildings (FSH14).”

Source location

Response from National Fire Chiefs Council
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Amend fire safety audit forms to require improved justification for overall and article-level compliance scores.

Verbatim wording from the response

“sleeping accommodation regardless of the audit outcome. We have now undertaken a review of that element of policy and concluded that due to the ordering of paragraphs in the policy document a potential degree of ambiguity may have remained. That drafting has been addressed to place the matter beyond doubt and this has been promulgated to all staff working in the technical fire safety function. We have also amended our audit form to ensure improved justifications are stated for the overall scoring of an audit and for each article. This should better ensure there are records setting out exactly why the FSO has deemed it to have been complied with (or not).”

Source location

Response from London Fire Brigade
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue advocating with government, regulators and the sector for legislative change enabling enforcement of relevant British Standard requirements.

Verbatim wording from the response

“The issue appears to be a lack of a direct enforcement mechanism for British Standards. That is a matter my officers have previously raised through the coronial system and with government. If a specific requirement is to be enforceable it will require legislative change. We will continue to advocate for this in appropriate cases as part of our ongoing work with government, other regulators and the sector itself.”

Source location

Response from London Fire Brigade
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Apply third-party accreditation to fire safety inspectors auditing or advising higher-risk premises, beginning with an initial assessment tranche.

Verbatim wording from the response

“LFB is also committed to applying the new national scheme of third-party accreditation of the competency of fire safety inspecting officers whose work involves the audit or provision of advice to higher risk premises. All such staff have achieved or are working towards an NVQ level 4 Diploma qualification after which they will be assessed though a new scheme operated by the Institution of Fire Engineers in conjunction with the Engineering Council. Achieving this level of accreditation for all Fire Safety Inspectors will take some time, potentially four to five years as there is currently a lack of approved assessors across the country. We expect the first tranche of Inspectors to be assessed over the coming 18 months.”

Source location

Response from London Fire Brigade
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Attend the premises and conduct a regulatory audit under the Fire Safety Order after the 56-day reply period.

Verbatim wording from the response

“This raises a concern that premises management is not compliant with duties under the FSO, in particular the duty in Article 15 concerning appropriate procedures to be followed in the event of serious and imminent danger to relevant persons. The FSO is a self-compliance regime with the duty for compliance placed firmly with the responsible person. As the London Fire Commissioner, I have a duty to enforce those regulations. In enforcing the FSO my officers must act in accordance with the requirements of the statutory Regulators Code. LFB Fire Safety Inspecting Officers plan to attend the premises shortly after the end of the 56 day reply period to conduct a regulatory audit under the FSO. This will consider whether there is compliance with the FSO including Article 15.”

Source location

Response from London Fire Brigade
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Add resources and develop and roll out training for staff involved in management vetting of audit forms and Enforcement Notices.

Verbatim wording from the response

“Over the course of the past two years LFB’s Central Regulatory Enforcement Group have been conducting bespoke training for regulatory fire safety team leaders on the management vetting of their team’s audit forms and Enforcement Notices to increase team leaders’ knowledge and skills. LFB has now brought in additional resources to assist with that and develop and roll out a new training package for all staff involved in the management vetting process. We expect to complete this over the course of the next six to twelve months.”

Source location

Response from London Fire Brigade
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Expand manager vetting requirements for fire safety regulatory audits and promulgate the clarified policy to technical fire safety staff.

Verbatim wording from the response

“In the year before the death of Ashliegh Timms, LFB had changed its policy on the vetting/review of fire safety regulatory audits by managers so as to include all audits of sleeping and vulnerable”

Source location

Response from London Fire Brigade
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Review LFB guidance on portable electric fan heaters in specialist housing.

Verbatim wording from the response

“From the London Fire Brigade perspective, use of portable heaters forms part of the considerations under our home fire safety visits and the guidance documents we issue for fire safety in the home for example https://www.london-fire.gov.uk/safety/the-home/portable-heaters-gas-fires-and-open-fires/”

Source location

Response from London Fire Brigade
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Press for guidance on digital keypad fitting that does not inhibit escape from domestic premises during a fire.

Verbatim wording from the response

“Although there is some guidance contained in government approved and National Fire Chief Council guidance, I believe this is a matter that should be expanded on as part of the Government review of guidance to the public. However, the forms of locking devices used on the exit from a flat as a private dwelling is not something that falls to be regulated under the FSO. Therefore, LFB officers cannot enforce against it. This issue does arise from time to time in material and guidance produced in respect of ‘secure by design’. We will continue to press for guidance in that regard which does not adversely, or potentially adversely, inhibit escape from domestic premises in case of a fire emergency.”

Source location

Response from London Fire Brigade
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider strengthening standards commentary on zone plans, including their life-safety importance and potential non-conformity.

Verbatim wording from the response

“2. While BS 5839-1 already details a need for users of the standard to check zones and confirm zone plans, it is proposed that commentary be added to 46.2 and/or 23.1 making the risk to life from a lack of a zone plan very clear. The text could also list the lack of a zone plan as a major non-conformity OR the lack of a zone plan immediately rendering the system non-compliant. This may include the absence of an ARC.”

Source location

Response from British Standards Institution
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider recommending that users establish local fire-and-rescue-service policies for automatic fire-alarm responses and confirm premises coverage.

Verbatim wording from the response

“3. Regarding ARC connections, the committee noted, many Fire & Rescue Service (FRS) are operating a nil-response policy to AFAs (AUTOMATIC FIRE ALARMS). The standard may include a recommendation the user to determine what the policy is for the local FRS and confirm whether the premises are included or exempt.”

Source location

Response from British Standards Institution
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Provide annual face-to-face fire warden training to all employees, including new joiners at the next available session.

Verbatim wording from the response

“26. Face to face fire safety training is now provided to staff. This training is provided annually by Pinnacle and is delivered at each premises. The training covers, amongst other things, evacuation routes and procedures, fire drills and fire safety measures. A copy of the training handbook provided to staff as part of that training is attached.”

Source location

Response from Kennedys
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Provide premises-specific induction training and annual refresher training to permanent and agency staff.

Verbatim wording from the response

“27. Specific induction training, tailored to each of Sequence Care’s premises, is also provided to the permanent and agency staff assigned to work there. This training is delivered to staff by either the registered manager or one of the deputy managers. The training ensures staff are familiar with and have read the following: fire safety policy, accidents and incidents procedure, EMG Response Plan and support plans/risk assessments/PEEPs for service users at that premises. Completion of this training is confirmed in the permanent and agency staff checklists attached...Staff refresher training is also provided annually.”

Source location

Response from Kennedys
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Update two homes’ fire alarm systems and install Alarm Receiving Centre links, with completion scheduled for 24 June 2022.

Verbatim wording from the response

“Sequence Care has now arranged for the fire alarm systems at these homes to be updated so that they are compatible and for an ARC link to be installed.”

Source location

Response from Kennedys
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Complete and activate the Alarm Receiving Centre link for one home’s fire alarm system.

Verbatim wording from the response

“Sequence Care has now arranged for the fire alarm systems at these homes to be updated so that they are compatible and for an ARC link to be installed.”

Source location

Response from Kennedys
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Conduct annual fire-safety competency assessments using the revised checklist and reassess staff against it.

Verbatim wording from the response

“28. In addition, a competency assessment is carried out on an annual basis by either the registered manager or deputy manager (who are also to be trained by SOCOTEC in how to carry out this assessment) in the form of question and answer sessions, on which staff”

Source location

Response from Kennedys
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Enforcement of fire safety regulations is outside the organisation’s functions because it is not an enforcing authority and has no regulatory functions.

Verbatim wording from the response

“For the sake of clarity, the NFCC is not an enforcing authority under the principal fire regulations relevant to the premises in issue; it does not have regulatory functions.”

Source location

Response from National Fire Chiefs Council
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The existing specialised housing guide satisfactorily addresses risks associated with fitting digital keypad locks in specialist housing.

Verbatim wording from the response

“5. No clear guidance exists regarding the fitting of digital key-pad locks on doors in specialist housing.”

Source location

Response from National Fire Chiefs Council
Page 5 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Dynamic sector scrutiny, review and reform prevent providing a definite timetable for completing the proposed standards and competency-related work.

Verbatim wording from the response

“1. The NFCC will redouble its efforts in progressing such work mentioned above and that it is responsible for. This extends to influencing the content of new or amended fire protection and safety standards. The NFCC is also currently leading the review of the competency framework for Fire Safety Regulators (which includes FRS inspecting and enforcement officers) and enforcement toolkit for high rise buildings and have in the past year launched a third-party professional accreditation scheme for Fire Safety Regulators and a national learning platform to underwrite the continual professional development of such officers.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Existing statutory care-home guidance and the specialised housing guide satisfactorily address risks from high-risk electrical devices.

Verbatim wording from the response

“4. No clear and practical guidance exists on how specialist housing operators should manage the use of high-risk electrical devices such as portable electric fan heaters.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

LFB cannot enforce controls on tenants’ portable heaters where lease or tenancy terms limit providers’ options and officers lack enforcement powers.

Verbatim wording from the response

“We also operate a number of primary authority partnerships with housing providers and work with the G15 group of providers. Now that the inquest findings are available officers will highlight the issue to those we work with. However, you will recognise that under existing terms of lease or tenancy, the options for them to act in relation to their tenants may be limited and it is not something that my officers have a power to enforce.”

Source location

Response from London Fire Brigade
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

British Standard recommendations cannot be directly enforced without legislative authority or a demonstrable safety risk arising from non-compliance.

Verbatim wording from the response

“Regulators cannot directly enforce the recommendations of a British Standard unless it is cited as a required standard in relevant legislation or unless the arrangements actually in place can be shown to create a “risk gap” from the level expected by that standard. I understand the suggestion here was that the alarm did not include a link to an ARC because the premises had 24/7 staffing in place. LFB might consider this to be non-compliance with Article 13 of the FSO, although this would have to be considered in the light of the circumstances of an individual premises including the arrangements for staff training and testing of the arrangement. It would then be raised with the responsible person as part of any follow up to the regulatory audit.”

Source location

Response from London Fire Brigade
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

LFB cannot enforce locking devices on exits from private domestic dwellings because they fall outside Fire Safety Order regulation.

Verbatim wording from the response

“Although there is some guidance contained in government approved and National Fire Chief Council guidance, I believe this is a matter that should be expanded on as part of the Government review of guidance to the public. However, the forms of locking devices used on the exit from a flat as a private dwelling is not something that falls to be regulated under the FSO. Therefore, LFB officers cannot enforce against it. This issue does arise from time to time in material and guidance produced in respect of ‘secure by design’. We will continue to press for guidance in that regard which does not adversely, or potentially adversely, inhibit escape from domestic premises in case of a fire emergency.”

Source location

Response from London Fire Brigade
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Where alternative arrangements provide an equivalent safety level, no enforceable risk exists requiring compliance with British Standard ARC recommendations.

Verbatim wording from the response

“The ethos of the FSO is one of risk-based fire safety preventative and protective measures. Under Government guidance that does mean that it is not a prescriptive regime. Alternative means can be used to demonstrate compliance rather than adherence to a British Standard.”

Source location

Response from London Fire Brigade
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

National fire safety guidance matters under the Fire Safety Order should be raised with the Home Office, which has the statutory guidance duty.

Verbatim wording from the response

“It may be helpful to note at the outset, that for matters of concern numbered 4, 5 and 6, the Secretary of State for the Home Office is under a statutory duty in Article 50 of the Regulatory Reform (Fire Safety) Order 2005 (the FSO) to “...ensure that such guidance as he considers appropriate, is available to assist responsible persons in the discharge of their duties...”. Insofar as the matters of concern relate to parts of premises to which the FSO applies, it may be appropriate for these concerns to be drawn to the attention of Home Office ministers. My understanding is that the Home Office are currently engaged in a programme of refreshing national fire safety guidance documents that are used by both responsible persons and the authorities enforcing it.”

Source location

Response from London Fire Brigade
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Housing hazard guidance matters outside the Fire Safety Order should be raised with the Department for Levelling Up, Housing and Communities.

Verbatim wording from the response

“Similarly, the Secretary of State for the Department for Levelling Up, Housing and Communities has responsibility for Housing, Health and Safety Rating System enforced by local authorities and which is applicable to the private domestic areas of many residential properties (where the FSO does”

Source location

Response from London Fire Brigade
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Fire detection installation and servicing issues should be examined by subcommittee FSH/12/1, which is responsible for the relevant standards.

Verbatim wording from the response

“The committee experts believe the committees which should examine the issues more closely are:”

Source location

Response from British Standards Institution
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Key-lock issues may be considered by subcommittee FSH/12/4 through a forthcoming amendment to BS 7273-4.

Verbatim wording from the response

“Regarding the matter of key locks, it was agreed subcommittee FSH/12/4 may consider it as part of a forthcoming amendment to BS 7273-4. It may also be covered as part of the ongoing revision of BS 9991 via the inclusion of an informative note to the effect that “if electronic locking is provided on flat entrance doors of individual units of accommodation it should not be necessary or needed to install a code to exist the flat. Means of electric locking should be simple and easy to use (eg a simple lever handle). It is also important that residents understand how to use the electronic lock.””

Source location

Response from British Standards Institution
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Fire precaution issues should be examined by technical committee FSH/14, which is responsible for relevant building fire-safety standards.

Verbatim wording from the response

“The committee experts believe the committees which should examine the issues more closely are:”

Source location

Response from British Standards Institution
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The three homes did not follow British Standards guidance but were not non-compliant with the applicable requirements.

Verbatim wording from the response

“The Second Statement confirmed that, at that time, there were three homes within the Group which did not have fire alarm systems linked with an ARC as recommended in British Standards BS 5839-1. Whilst the three homes did not adhere to the guidance provided by the British Standards, it is not correct to say that they were non-compliant.”

Source location

Response from Kennedys
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Completion of alarm system upgrades at two homes was delayed because the implementing team was absent due to Covid-19.

Verbatim wording from the response

“ii. ████████ - works due to be completed on 24 June 2022, the delay being due to the implementing team being absent due to Covid-19;”

Source location

Response from Kennedys
Page 3 · response
Published 29 April 2022

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.16

  1. 1

    Operate the third-party professional accreditation scheme for Fire Safety Regulators.

    Stated by National Fire Chiefs CouncilStated completedThe respondent said that this action was complete when they made their response on 29 April 2022.
  2. 2

    Operate the national learning platform supporting continuing professional development for Fire Safety Regulators.

    Stated by National Fire Chiefs CouncilStated completedThe respondent said that this action was complete when they made their response on 29 April 2022.
  3. 3

    Work with the Care Quality Commission to formalise person-centred fire risk assessments within care providers’ care-planning processes.

    Stated by National Fire Chiefs CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 April 2022.
  4. 4

    Send the Report and response to all English fire and rescue services to disseminate the concerns and proposed actions.

    Stated by National Fire Chiefs CouncilStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  5. 5

    Continue supporting the Fire Standards Board in its standards-related work.

    Stated by National Fire Chiefs CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 April 2022.
  6. 6

    Continue supporting HMICFRS in its assessments and improvement-related work.

    Stated by National Fire Chiefs CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 April 2022.
  7. 7

    Develop and roll out refreshed mandatory CPD on risks in care homes, extra-care, sheltered and supported-living premises.

    Stated by London Fire CommissionerStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  8. 8

    Conduct a full review of training and CPD materials for vulnerable sleeping-risk premises.

    Stated by London Fire CommissionerStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  9. 9

    Highlight portable-heater risks to housing providers in primary-authority partnerships and the G15 group.

    Stated by London Fire CommissionerStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  10. 10

    Consider adding guidance that fire alarms must not be reset until the cause of the alarm is resolved.

    Stated by British Standards InstitutionStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  11. 11

    Consider adding guidance for users to request periodic reviews of fire-detector addresses.

    Stated by British Standards InstitutionStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  12. 12

    Review BS 5839-6:2019+A1:2020 against the identified fire-detection and alarm-system safety issues.

    Stated by British Standards InstitutionStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  13. 13

    Consider guidance addressing event-log capacity and the need for additional recording capacity in addressable systems.

    Stated by British Standards InstitutionStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  14. 14

    Consider creating a list of system variations that cannot be accepted as compliant and requiring their justification.

    Stated by British Standards InstitutionStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  15. 15

    Train registered and deputy managers to conduct the annual competency assessments through SOCOTEC.

    Stated by KennedysStated plannedThe respondent said that this action was planned when they made their response on 29 April 2022.
  16. 16

    Carry out additional training sessions to address staff members’ outstanding training needs.

    Stated by KennedysStated in progressThe respondent said that this action was in progress when they made their response on 29 April 2022.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.1

  1. 1

    A code of practice has limits on recommendations, and technical limitations affect increasing fire-alarm event-log capacity.

    Stated by British Standards InstitutionUnable to actThe respondent said that a constraint prevented them from taking the relevant action.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Operate the third-party professional accreditation scheme for Fire Safety Regulators.

Verbatim wording from the response

“1. The NFCC will redouble its efforts in progressing such work mentioned above and that it is responsible for. This extends to influencing the content of new or amended fire protection and safety standards. The NFCC is also currently leading the review of the competency framework for Fire Safety Regulators (which includes FRS inspecting and enforcement officers) and enforcement toolkit for high rise buildings and have in the past year launched a third-party professional accreditation scheme for Fire Safety Regulators and a national learning platform to underwrite the continual professional development of such officers.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Operate the national learning platform supporting continuing professional development for Fire Safety Regulators.

Verbatim wording from the response

“1. The NFCC will redouble its efforts in progressing such work mentioned above and that it is responsible for. This extends to influencing the content of new or amended fire protection and safety standards. The NFCC is also currently leading the review of the competency framework for Fire Safety Regulators (which includes FRS inspecting and enforcement officers) and enforcement toolkit for high rise buildings and have in the past year launched a third-party professional accreditation scheme for Fire Safety Regulators and a national learning platform to underwrite the continual professional development of such officers.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Work with the Care Quality Commission to formalise person-centred fire risk assessments within care providers’ care-planning processes.

Verbatim wording from the response

“1. The NFCC is in the process of carrying out a significant programme of work, much of which is closely aligned and in collaboration with, the Home Office and the Department for Levelling Up, Housing and Communities. It is also working closely with the Care Quality Commission¹³ to formalise the use of ‘Person Centred Fire Risk Assessments’ (PCFRA) by care provider companies as part of care planning processes. Similarly,”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Send the Report and response to all English fire and rescue services to disseminate the concerns and proposed actions.

Verbatim wording from the response

“2. The NFCC will send a copy of your Report annexed to a copy of this response, to all FRS in England to bring your Concerns to their respective attention, and to inform the FRS of the NFCC’s proposed actions. This should provide an excellent opportunity to direct information regarding the Concerns and the NFCC’s response, into the corporate mind and strategic management forums of the FRS.”

Source location

Response from National Fire Chiefs Council
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue supporting the Fire Standards Board in its standards-related work.

Verbatim wording from the response

“The NFCC is heavily involved with the, relatively new, Fire Standards Board (FSB). The FSB was founded to oversee the identification, organisation, development, and maintenance of professional standards for fire and rescue services in England.”

Source location

Response from National Fire Chiefs Council
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue supporting HMICFRS in its assessments and improvement-related work.

Verbatim wording from the response

“Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS)¹⁰ independently assesses and reports on the effectiveness and efficiency of FRS.”

Source location

Response from National Fire Chiefs Council
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Develop and roll out refreshed mandatory CPD on risks in care homes, extra-care, sheltered and supported-living premises.

Verbatim wording from the response

“Deputy Assistant Commissioner Steve Norman drew your attention to work undertaken to educate staff on the risk arising in specialised housing and to our work running a series of external seminars for the managers of care homes. LFB’s Fire Prevention and Protection Department (P&P) are currently developing a new training needs analysis for LFB’s inspecting officers. Over the next six months P&P will conduct a full review of the training and continuous professional development (CPD) material used for all forms of vulnerable sleeping risk premises including care homes, extra care schemes and sheltered housing and supported living schemes. From this, over the next twelve months we will develop and roll out refreshed CPD covering the specific risks arising for these premises types.”

Source location

Response from London Fire Brigade
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Conduct a full review of training and CPD materials for vulnerable sleeping-risk premises.

Verbatim wording from the response

“Deputy Assistant Commissioner Steve Norman drew your attention to work undertaken to educate staff on the risk arising in specialised housing and to our work running a series of external seminars for the managers of care homes. LFB’s Fire Prevention and Protection Department (P&P) are currently developing a new training needs analysis for LFB’s inspecting officers. Over the next six months P&P will conduct a full review of the training and continuous professional development (CPD) material used for all forms of vulnerable sleeping risk premises including care homes, extra care schemes and sheltered housing and supported living schemes. From this, over the next twelve months we will develop and roll out refreshed CPD covering the specific risks arising for these premises types.”

Source location

Response from London Fire Brigade
Page 3 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Highlight portable-heater risks to housing providers in primary-authority partnerships and the G15 group.

Verbatim wording from the response

“We also operate a number of primary authority partnerships with housing providers and work with the G15 group of providers. Now that the inquest findings are available officers will highlight the issue to those we work with. However, you will recognise that under existing terms of lease or tenancy, the options for them to act in relation to their tenants may be limited and it is not something that my officers have a power to enforce.”

Source location

Response from London Fire Brigade
Page 4 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider adding guidance that fire alarms must not be reset until the cause of the alarm is resolved.

Verbatim wording from the response

“5. Whether an informative note be included that states an alarm cannot be reset until the cause of the alarm is resolved. However, it was noted any new wording would be added to clauses pertaining to user operation rather than any new recommendations for manufacturers.”

Source location

Response from British Standards Institution
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider adding guidance for users to request periodic reviews of fire-detector addresses.

Verbatim wording from the response

“1. Whether BS 5839-1 should include under user responsibilities an informative note that the user may wish to request a complete review of the “addresses” of fire detectors at regular intervals, for example, 5 years.”

Source location

Response from British Standards Institution
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Review BS 5839-6:2019+A1:2020 against the identified fire-detection and alarm-system safety issues.

Verbatim wording from the response

“It was also agreed that BS 5839-6:2019+A1:2020 needs to be reviewed against the above list as these changes need to be made there.”

Source location

Response from British Standards Institution
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider guidance addressing event-log capacity and the need for additional recording capacity in addressable systems.

Verbatim wording from the response

“6. The committee is considering including a recommendation that the event log should be larger. However, they noted that one issue is that “event” is very broad. As part 1 is a CoP, there are limits to what can be recommended and a EN 54 product standard may be better placed. There are also technical limitations. It has been proposed that text be added to commentary that points out that maximum number of recordable events is 999 but more may be needed, and thought should be given to providing more capacity for addressable systems.”

Source location

Response from British Standards Institution
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider creating a list of system variations that cannot be accepted as compliant and requiring their justification.

Verbatim wording from the response

“4. Currently the standard allows variations to be made and the system still being considered compliant. The committee has proposed the creation of a list of certain variations that cannot be allowed, and that system still be considered compliant. The need to justify the”

Source location

Response from British Standards Institution
Page 1 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Train registered and deputy managers to conduct the annual competency assessments through SOCOTEC.

Verbatim wording from the response

“28. In addition, a competency assessment is carried out on an annual basis by either the registered manager or deputy manager (who are also to be trained by SOCOTEC in how to carry out this assessment) in the form of question and answer sessions, on which staff”

Source location

Response from Kennedys
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Carry out additional training sessions to address staff members’ outstanding training needs.

Verbatim wording from the response

“Further training sessions are also being carried out to ensure that any remaining staff are provided with outstanding training (see below).”

Source location

Response from Kennedys
Page 2 · response
Published 29 April 2022

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

A code of practice has limits on recommendations, and technical limitations affect increasing fire-alarm event-log capacity.

Verbatim wording from the response

“6. The committee is considering including a recommendation that the event log should be larger. However, they noted that one issue is that “event” is very broad. As part 1 is a CoP, there are limits to what can be recommended and a EN 54 product standard may be better placed. There are also technical limitations. It has been proposed that text be added to commentary that points out that maximum number of recordable events is 999 but more may be needed, and thought should be given to providing more capacity for addressable systems.”

Source location

Response from British Standards Institution
Page 2 · response
Published 29 April 2022

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026