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Adam Bannister is a contributor to IFSEC Global, having been in the role of Editor from 2014 through to November 2019. Adam also had stints as a journalist at cybersecurity publication, The Daily Swig, and as Managing Editor at Dynamis Online Media Group.
May 10, 2023


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IFSEC Interviews

‘The fire service must enforce existing law’: Elspeth Grant on Personal Emergency Evacuation Plans

‘Fire Safety Order already says that everyone must be able to evacuate the building’ says PEEPs expert, Elspeth Grant, ahead of FIREX presentation.

A means-of-escape expert suggests the government’s resistance to mandating Personal Emergency Evacuation Plans (PEEPs) in high-rise residential buildings is not necessarily the biggest barrier to protecting disabled residents.

According to Elspeth Grant, TripleAConsult CEO and expert PEEPs advisor/trainer, existing legislation already implies the need for PEEPs – it’s enforcement that is wanting.

After chastising the government for neglecting disabled residents of high-rise buildings at FIREX 2022, the former fire safety assessor returns to London ExCeL next week to deliver an update on the topic at this year’s show.

In the following interview Grant previews her talk by discussing the problems with PEEPs enforcement, the potential unforeseen consequences of the second-staircase consultation and the limited merits of evacuation lifts.

Read more: Gove says government should “look again” at position on PEEPs

IFSEC Insider (II): What can FIREX attendees expect from your presentation?


Elspeth Grant, Triple A Solutions

Elspeth Grant (EG): I’m going to focus on the building safety case and safety case reports on emergency arrangements, particularly because the building safety regulator will lead this with regulation – it’s going to be a different ball game, I’d suggest.

I’ve invited three people to help me deliver the presentation.

Samantha Shimmon, Strategic Lead for Housing Services from East Suffolk Council, will talk about rolling out PEEPs across her property portfolio.

And a couple, Joe and Liz, who live on the third floor in an 18.5 metre building, will talk about what it is like to live in a high-risk building with no means of escaping a fire and how they have been fighting to get a PEEP for Joe, who is disabled, since 2021.

Then I will chip in with where we are legislatively, moving into the era of building safety case reports.

And then we’ll wind up with some questions and answers.

Having the other speakers will bring something different to a topic I’ve been talking about since 2009. Having Samantha there will be of particular interest to responsible persons and fire safety professionals who advise housing associations.

II: What’s your view on the government’s refusal so far to mandate PEEPs in the way recommended by the Grenfell Tower Inquiry?

EG: The government has done three consultations on this so far. We had PEEPs rolled in with the general consultation of recommendations and a dedicated PEEPs consultation that appears not to have given the government the results that they wanted, as they then decided to roll out the EEIS [Emergency Evacuation Information Sharing] consultation.

My view is that, actually, you don’t need to change or reinforce the legislation. Articles 14 and 15 of the Fire Safety Order already says that everyone has to be able to move away from immediate danger and evacuate the building. It doesn’t exclude disabled people or general needs. That’s the law.

And we have no guidance that supports that this is unreasonable to achieve.

RegulatoryReform-FireSafety-OrderThe Local Government Association’s ‘Fire safety in purpose-built flats’ [guidance] stated that it was unreasonable to develop PEEPs but this was redacted. BS999 and BS991 gives clear guidance on how to achieve PEEPs. So all that needs to happen now is that Fire and Rescue Services must be more proactive and enforce the existing law.

I delivered a presentation last week, and in the Q&A somebody said: “We’re only doing personal fire safety and risk assessments and I’m working closely with London Fire Brigade.” They’re not actually doing PEEPs.

We have this time and time again: London Fire Brigade support the managing agents not to meet the law.

And it’s not just London Fire Brigade. I submitted FOI [Freedom of Information] requests asking how many enforcement notices the fire service has issued, and how many relate to disabled people, since 2019, when the EHRC [Equality and Human Rights Commission] said that the evidence suggests that the lack of PEEPs breaks the law and the Human Rights Act.

A lot of fire services claimed that they publish this information elsewhere – well good luck if you can find it. Article 31 of the UN Convention on the Rights of Persons with Disabilities clearly states that the public sector has to publish statistics and data to show [evidence of discrimination]. As does the Public Sector Equality Duty.

The results were that of 3,430 notices issued, only 93 – or 2.71% – related to means of escape for disabled people. And those were issued by only six fire and rescue services. How that isn’t discriminative, I will never know.

II: How do you account for the resistance to PEEPs? To what extent is cost a factor?

EG: I calculated using the government figures published with their consultations that it would cost £56.08 to develop a PEEP.

A CD7 evacuation chair – and not [all disabled residents] need one – costs roughly £1,750. If you apply those costings to Grenfell Tower, which had 37 disabled residents, that comes to £55,000.

Applied across the service charges for the 150 flats in Grenfell Tower, that would be roughly an additional £432 or £38 per month [per resident across only one year because it’s a one-off cost].

But instead, 15 disabled people in that building died because they couldn’t get out.

The EHRC have already said that an evacuation device could be seen by the courts as a reasonable adjustment, under the Equality Act.

The reason we are in this situation is the prevailing mantra of ‘stay put’.

I start almost every presentation by asking people if they would stay put if there was a fire in the building. No one ever puts their hands up.

The NFCC [National Fire Chiefs Council] found that between 2019 and 2020 in London alone 8,500 residents self-evacuated – so residents are not listening to the stay-put advice. People just don’t trust the fire industry. They don’t trust the fire brigade.

II: Is prejudice a factor in PEEPs not being more widely championed and implemented?

EG: I did fire risk assessments for general needs, mostly in social housing between 2009-2011, and most people would say to me that residents don’t talk to each other, nobody cares.

Well, quite frankly, anybody who’s learned anything about Grenfell Tower should realise that this claim should have been blown out of the water years ago. Non-disabled people died because they wouldn’t abandon the people who couldn’t evacuate – they stayed put with them. That’s human nature.

RBKC [Royal Borough of Kensington and Chelsea] are facing multimillion pound compensation claims, criminal prosecutions are likely to follow next year, and some of those will be from disabled people and their families.

Another mantra, and referenced in the EEIS consultation, is about asking residents to self-identify [as needing support to evacuate], but the Fire Safety Order doesn’t mention that people have to be able to move away if they self-identified. They have to be able to move away if their flat is on fire.

And there’s research from the University of Leeds and Phil Murphy that shows that, although we always quote a 7.5 minute average response time for fire and rescue, it’s actually a further 20 minutes before they are ready for a primary intervention.

So with a 999 call, a disabled person unable to use the stairs, whose flat is on fire, has to spend, on average, half an hour sat in a corridor with smoke, flames… it’s just daft to expect them to stay put.


II: Are you overall heartened or disappointed by the response of government, the fire safety industry, responsible persons and so on to the myriad lessons of Grenfell?

EG: There has been progress, but I get very frustrated with the second staircase consultation. It’s mixed messages.

Grenfell Tower’s single staircase held for 40 minutes smoke-free, although the lobbies had smoke. In fact, Professor Purser, a worldwide expert in toxicity at evacuation, calculated that every non-disabled person could have evacuated the building within seven minutes even if they’d all entered the single staircase at the same time, which doesn’t happen in residential settings anyway.

II: What are the key arguments for and against mandating second staircases in new high-rise developments?

EG: At the moment, Part B says you can have a single staircase or multiple staircases.

My understanding is that single staircases have to be 7.5 metres from every flat and that’s based on the six-second rule – you can take a big gulp of air and reach the relative safety of another fire compartment in that time. And a single staircase requires an automated vent to draw the smoke out.

But with multiple staircases you can have up to 30 metres – which is a long way to relative safety, particularly if you’re mobility-impaired.

Well, the highest firefighters have managed to do a rescue from was the 12th floor. If you’re on the 18th floor and the compartmentation is compromised, there’s no automatic smoke vent. You’re going to have badly compromised staircases.

And how does a resident know which staircase to go to?

In practise I can imagine people going to the one they always use, finding it’s compromised, and turning back to go to the other staircase – and then you’ll have streams of people going in opposite directions. You could get directional lighting and smoke alarms, but they’re not mandated.

So we’ll see what happens.

Second stairwell stacks also take up tonnes of concrete – which is not terribly environmentally friendly. So you could argue that if it saves lives, it’s a good thing to do. However, if it doesn’t, why are we doing it?

People have also said extra staircases will take up sellable or rentable space, so developers may start to build higher – unintended consequences. These buildings are going to be there for 50, 60, a 100 years or more.

In principle multiple staircases sounds like a good idea – but the devil is in the detail.

II: What’s your view on evacuation lifts?

EG: I can certainly understand evacuation lifts, but the problem there is we have spent decades telling people not to use lifts.

And an evacuation lift is only any good if it’s completely maintained. And certainly, when I talk with ex-firefighters, they often say: “Well I wouldn’t go in an evacuation lift – I’d put my equipment in one but I’ll run up the stairs”.


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