In our first webinar of 2025, Ventro was delighted to welcome Elspeth Grant from Triple A Solutions, a leading expert in fire safety legislation and PEEPs, to discuss some of the most critical updates shaping the industry.
Elspeth’s presentation covered key topics, including the Government’s response to the EEIS+ consultation, fire and rescue service response and intervention times, and the latest developments on residential PEEPs. While we addressed many important questions during the live event, there wasn’t enough time to cover everything in detail.
To ensure you get the information you need, we’ve gathered Elspeth’s responses to your most pressing questions below.
CEO/Specialist PEEPs Advisor & Trainer
Elspeth has over 18 years of experience focusing on fire safety for disabled people. Over this time, she has collaborated with fire engineers, architects on social housing renovations, and developed personal emergency evacuation plans (PEEPs) for disabled.
A regular speaker at prominent forums since 2009, Elspeth regularly shares her expertise on legislative compliance and evacuation strategies for disabled people from residential buildings. She is a member of the Building Advisory Committee and has developed Triple A Solutions’ IFE-accredited, role-based PEEPs training programme.
While there are a number of example Personal Emergency Evacuation Plans (PEEPs) available
online, none of those that Triple A Solutions have reviewed meet our standards for providing
adequate information and evidence of due diligence.
As part of our training, Triple A Solutions provides fillable forms tailored for PEEPS in General
Needs and Specialised Housing, in addition to a variety of other downloadable fillable forms.
These forms are designed to demonstrate due diligence and swiftly capture essential
information. Access to these forms is contingent upon the completion of the corresponding
training course, ensuring that learners can effectively use them in their work environment.
Additionally, the forms can be published on an organisation's portal, provided there is a
contractual agreement in place.
For more details on Triple A Solutions training visit: https://www.ventrogroup.com/peeps-training
In the workplace, it is essential to appoint multiple volunteers as buddies, as individuals may
be unavailable due to being out of the office, on a lunch break, or attending a meeting in
another building. A similar strategy applies to residential buildings, where identifying as many
people to provide assistance as possible is crucial in an emergency.
Note: Many disabled individuals already receive support from their social networks, as evidenced in the Grenfell Tower Inquiry (GTI).
Absolute safety is unattainable; the purpose of the PEEP is to demonstrate due diligence in minimising risks as much as possible for the person and serve as a defence in the event of legal action. For instance, when we get into a car and fasten our seatbelt, we acknowledge the possibility of injury or even death in an accident. However, we expect that the manufacturer has implemented all reasonable safety measures to protect us - if not, there would be a case to answer.
It is true that there is currently a lack of case law addressing discrimination for means of escape under the Equality Act 2010. However, the Building Safety Regulator (BSR) has clearly stated that they expect service providers, landlords, and responsible persons to take "due regard" of their duties under equality and fire safety laws.
See “Principles for engaging with residents, Section 5”
One of the most significant factors driving improvements in means of escape for disabled
residents is the ability for anyone to file a complaint relating to a residential building over
18m directly with the (BSR). This mechanism ensures that concerns about inadequate
evacuation arrangements or fire safety failures are formally addressed.
Once a complaint is submitted, the BSR is obligated to investigate the issue, assessing
whether the responsible person, such as building owners, landlords, or management
companies, have taken appropriate measures to provide safe evacuation options for
residents. This includes reviewing compliance with legal obligations, fire safety provisions,
and whether PEEPs or other reasonable adjustments have been implemented if the complaint
involves a relevant disabled person.
If deficiencies are found, the BSR can take enforcement action, which may include requiring
remedial measures, imposing penalties, or referring the matter to other regulatory bodies.
This process creates accountability and incentivises building owners and responsible persons
to proactively ensure that proper escape plans and accommodations for disabled residents
are in place before issues arise.
There is no legal requirement for assistance to be provided by employees/staff. The
Government finally recognised this in their Conclusion 9 of the EEIS+ Consultation Response:
“It is recognised that some residents have family members, friends or neighbours who are
willing and able to offer assistance with evacuating them. Consultation responses showed strong support from some stakeholders for including such volunteer assistance, where
available, in the PCFRA consideration.”
The NFCC Temporary Change to a Simultaneous Evacuation Strategy 4th edition, Sections 9
and 10, also endorses residents taking an active role in managing evacuation:
“10.1: Where a fire occurs, every occupant of the building should have the means to start
their evacuation before the FRS arrive. Some residents may require assistance to do this,
whilst other vulnerable residents may identify that they are able to self-evacuate. Detailed
information about the principles of the evacuation of vulnerable persons can be found in
the Fire safety risk assessment: means of escape for disabled people guide, and also within
the Fire safety risk assessment: sleeping accommodation guide.
10.2. The Responsible Person should make and record reasonable endeavours, through a
range of methods, to identify anyone who may need assistance to evacuate their flat and
the building in the event of a fire in the resident’s flat or elsewhere in the building. The
Responsible Person should, with the engagement of the individual, develop a Personal
Emergency Evacuation Plan (PEEP) that, as a minimum, should include how the individual
is made aware of a fire in the building and their route, facilities, and options to support
their evacuation.”
See: https://nfcc.org.uk/wp-content/uploads/2023/07/SEG_-_4th_Edition_-_FINAL_17082022.pdf
While the guidance is specifically aimed at temporary changes to a simultaneous evacuation
policy, it would be illogical not to extend the same approach to all residential buildings.
Apologies for not being clear about Triple A Solutions rational on this and I’m very happy to
have a discussion if others have an alternative view.
Disabled individuals, like their non-disabled counterparts, are reluctant to use a lift during a
fire unless firefighters are present, regardless of whether it is designated as an evacuation lift.
For insights into the potential consequences of uncontrolled lift usage by residents during a
fire, refer to Chapter 6 of the Grenfell Tower Inquiry (GTI) Phase 2 Report, and search for ‘lift’ in:
https://www.grenfelltowerinquiry.org.uk/sites/default/files/CCS0923434692-004_GTI%20Phase%202%20Volume%206_BOOKMARKED.pdf
Following extensive discussions with industry expert and Fire and Rescue Services, our
position is that, in most situations, residents should not independently operate an evacuation
lift during an emergency without oversight or involvement from the FRS.
While enabling residents, particularly those with mobility impairments, to use evacuation lifts
might seem beneficial, there are substantial risks in an unmanned residential setting.
Ensuring that the lift remains safe and operational throughout an emergency presents
significant challenges:
While residents play a role in ensuring their needs are communicated, it is the responsibility of
the building's management to ensure that that they have taken all reasonable steps to ensure
a resident can safely evacuate to a place of total safety evacuation in line with legal
requirements.
See Section 1.1 Legal Overview of: https://assets.publishing.service.gov.uk/media/5ec5401ee90e0754d1dedf20/9446_Means_of_Escape_v2_.pdf
Actions any disabled resident can take if they are not provided with a PEEP includes:
Actions relating residential buildings over 18 metres:
As detailed in Q3, anyone can contact the BSR concerning building safety issues including
emergency planning, in a residential building: https://www.contact-building-safety-regulator.service.gov.uk/
The BSR will then contact the appropriate person as defined in the building registration
form and investigate.
The Government has stated that the total number of leasehold dwellings in residential
buildings over 11m in England is estimated at 1.51 milion dwellings. Personally, I have no idea
how the Government expects FRS to undertake the duty of care for millions of disabled
residents living in these buildings, particularly given the evidence of the intervention times
identified in the research undertaken by the University of Leeds and Phil Murphy (refer to the
relevant presentation slide). Additionally, this approach is clearly outside the core functions
defined in the Fire Services Act 2004, which would require amending as would the Fire Safety
Order (FSO) and Equality Act to exclude disabled residents from the legal requirements.
The LGA EEIS+ Consultation Response states:
“The absence of this requirement means that the occupants of the building are told it is so
dangerous that if there is a fire they should evacuate immediately, but disabled residents
are told to wait to be rescued. This is transferring responsibility from the duty-holder to
the fire service and disabled individuals; while rescue is a back-up option, which is
facilitated by EEIS; it cannot be the first and only option in a block with simultaneous
evacuation. In addition, this policy would in our view be unlawful under the Equality Act if
adopted by a local authority.”
Read the LGA Response in full: https://www.local.gov.uk/parliament/briefings-and-responses/lga-eeis-consultation-response
Annex A, Section 1.8 of the NFCC Premises Information Box also provides guidance on the
numbers of firefighters to implement a safe evacuation:
“Annex A, Section 1.8 of the guidance outlines the categorisation of residents requiring
assistance in an emergency. Category 1 (Red) individuals may require evacuation by three or more firefighters with additional equipment (e.g., bariatric individuals, wheelchair
users). Category 2 (Amber) individuals may need assistance from two or fewer firefighters
with no extra equipment (e.g., mobility-impaired individuals, those with sensory or
cognitive impairments).”
Notes:
The CD7 tracked evacuation aid is the device.
While we don't officially endorse any suppliers, we have collaborated with Evaccess for many
years, and they provide these types of devices here.
Please refer to Q2, which discusses the involvement of family, friends, and neighbours in
PEEPs.
Triple A Solutions offers over 18 hours of IFE-accredited training, focusing on the practical
implementation of PEEPs in unmanned residential buildings since 2009. Based on these
experiences, the training includes fillable PEEP and PcFRA forms, along with worked
examples, enabling organisations to develop cost-effective PEEPs and PcFRAs while
demonstrating due diligence in legal compliance.
For more details visit: https://www.ventrogroup.com/peeps-training
Sarah was not required to purchase the device herself. Once her RMO became aware that she could not evacuate without assistance, they acknowledged their legal responsibilities and covered the costs for both the commissioning of the PEEP and the auxiliary aid. This was done in accordance with the FSO and the Equality Act, which ensures that disabled individuals are not required to bear the cost of a reasonable adjustment to remove discrimination.
The requirement in the draft regulation that suggests that a resident should be expected to
pay for an AED shows that the Government is unaware:
Thank you for your comments. Although many disabled people do not have the same level of
care as Sarah, many do have support from family, friends or neighbours, all of whom can be
trained to assist in their evacuation - please also refer to the answer to Q2.
In order to protect both the organisation and those with responsibility for legal compliance,
the following should be in place to provide evidence of compliance in the event of any
investigation:
Thank you for your comments—I completely agree that the draft regulation creates
confusion. If accurate, the draft regulation neither aligns with the Grenfell Tower Inquiry
recommendations nor complies with the FSO or the Equality Act 2010, which are primary
legislation, both of which will require amendment to exclude disabled people from the legal
requirements.
It is worth reading Enforcement and Sanctions for Non-Compliance with the Fire Safety Order,
Section 10 as this documents the personal liabilities of those managing fire safety buildings
covered by the FSO here.
Triple A Solutions offers training courses to support the implementation of PEEPs in
residential buildings. For more details, visit: https://www.ventrogroup.com/peeps-training to
download the training brochure.
Thank you for your comments and please also refer to my comments about the costs for
Sarah’s PEEP etc in my answer to Q10 & Q11.
Regarding the expectation of employing 24-hour staff in a high-rise block, I do not believe
that this would be deemed reasonable as the cost of employing staff would be unreasonable
as compared with the development of a PEEP and provision of an AED if assistance can be
provided by friends, family and neighbours.
In the minority of cases, no assistance might be available. In which case there are the options
of re-location to a more suitable property (subject to the resident’s agreement and
availability of housing stock) and implementing additional fire protection/suppression in the
person’s flat to reduce the likelihood of fire. In this case, is essential to have evidence of a
strategy, policy, procedures and PEEPs in place.
Please refer to answers to Q10, Q11 and Q14. Regarding training, reputable suppliers of
AEDs will demonstrate the AED in the physical environment and provide training as part of
their product provision.
Building a relationship with a reputable supplier who has a wide range of AEDs suitable for
different physical environments and individual impairments, and agreeing a ‘call-off’ contract,
will reduce costs through the power of purchasing large quantities.
The FSO applies to the common parts of buildings containing two or more domestic premises,
irrespective of their height but explicitly excluding individual domestic dwellings from its
scope.
While the FSO covers all residents in the vicinity of the building, this raises the legal question
about how a Fire Safety (England) Regulation, which introduces new duties relating to the
FSO, could mandate a Person-Centred Fire Risk Assessment (PcFRA) within private domestic
premises, given that these fall outside the FSO’s legal framework.
68% of disabled people become disabled during their lifetime so relocating vast numbers of
residents who have lived in their home for many years and have an ongoing support network
in the building is not a holistic approach or practical.
Regarding AEDs, residents unable to evacuate to a place of total safety do not always need an
AED:
The short answer is “Yes”. Organisations should have policies and procedures in place for
visitors and General Emergency Evacuation Plans (GEEPs) in place as there are no exclusions
from the statements in the FSO:
Agreed and this also applies to any firefighter who has not been trained on how to safely evacuate a person using he AED. Please refer to my answer to Q2, Q & Q14. It is not about kindness but about practicalities. The evidence presented to the GTI, proved that family, friends and, in some cases, neighbours refused to abandon disabled residents increasing fatalities and injuries.
See 8th June 2021 PEEP Impact Assessment here.
We’d like to extend our sincere thanks to each of our key speakers for their insights during the webinar, and a special thank you to Elspeth for taking the time to respond to all the unanswered questions.
Be sure to sign up for updates on our upcoming webinars here, and if you have any questions about the topics covered in this Q&A, feel free to reach out below. One of our fire safety consultants will be happy to assist you.