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Government Consultation - Fire Safety

HAD were recently given the opportunity to comment on the document 'Draft Fire Safety in Purpose Built Blocks of Flats'. This was a consultation held by the Home Office to gather opinions regarding fire safety. Please read our response below.

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Thank you for the opportunity to comment on the document 'Draft Fire Safety in Purpose Built Blocks of Flats'.


This is the response from Harrow Campaigns, a Harrow based campaigns group, and from Harrow Association of Disabled people, a Disabled Peoples´ Organisation led by, and for, disabled people in Harrow.


Unfortunately, our comments on this report have been limited due to the extremely short notice given for commenting which has rendered it impossible to hold a formal consultation, therefore I can only comment on areas where numbers of local Disabled people have already clearly stated their views.


Please note that any consultation which invites comments too late for information to be disseminated and considered, particularly by those who require adaptations to that information for it to be usable, cannot be considered a true engagement exercise. This failure should be made clear on any report of responses, as otherwise the dangerous assumption could be made that Disabled people do not see the need for Personal Emergency Evacuation Plans (PEEPs). And whilst we ask that the views expressed here are taken into account, we only give permission for Harrow Campaigns and HAD to be quoted as taking part if those limitations are described, and no attempt is made to imply that we are in favour of the report, although with greater time to explore it, there are probably many other elements than those noted here that we could support.


The short timescales also made it difficult to do more than skim read the document. This means that there may still be important points to be made which are now not

possible.


The most important point possible for us to address relates to the fact that the report does not advocate that disabled people should have their own Personal Emergency Evacuation plans. This is very alarming to us in the context of the https://www.gov.uk/government/publications/an-in-depth-review-of-fire-related-

fatalities-and-severe-casualties-in-england-2010-to-201819 report (further referred to as the 2010 to 2018/19 report) which clearly states that impaired people are much, much more likely to die in a fire. The report states that 74% of those who die are impaired in at least one, and often in multiple ways.


The 'Draft Fire Safety in Purpose Built Blocks of Flats' report, when looking at whether 'staying put' is safe, states that "it is normally safe for other residents to remain within their own flat. This principle is undoubtedly successful in an overwhelming number of fires in blocks of flats", and goes on to give a percentage of evacuations made with people who have stayed put. This does not make it clear that it is safe. It doesn't even say how many people have been rescued, died, or been seriously injured. In fact, the 2010 to 2018/19 report states that 28% of people who die in fires are care service users. Whilst not all of them will be living in care settings, many will be users of day, residential or supported living services and will have learned the 'stay put' principle from such settings. Considering that only around .65% of people live in care settings at any given point in time, the fact that 28% of deaths arise from this group is surely overwhelming evidence of what a disastrous and dangerous policy it is to have a one size fits all 'stay put' policy rather than looking at personal emergency evacuation plans?


We are also concerned that the report implies that 'staying put' is not just intended for Disabled people, which looks like an attempt to avoid this policy being seen as the indirect disability discrimination it is. Evacuation signs, all fire training etc tells people to simply get out when there is a fire. None of those consulted have seen a sign which states that people should just stay in their home (or care home) and wait to be rescued. Nor have we heard of any legislation which states that disabled people (or anyone else) should stay in burning buildings awaiting rescue, whilst everyone who can, seek to escape the fire.


In reality, refusal to accept the need for PEEPs is a discriminatory procedure which devalues the lives of Disabled people.


One respondent reported that when managing care homes some 20 years ago, the policy was 'stay put' but it needs to be noted that even at the time nobody involved, neither the homes´ management teams, the residents or their families, the local fire service nor the organisation as a whole were ever in favour of this policy, and it was clear that although it may have been endorsed by the higher echelons of the fire brigade, those most affected by it never felt that it was a workable policy.


Managing agents should not only provide a PEEP, but pay for mitigation measures. Evacuation equipment should not be paid for by the Disabled person. The financial burden should not fall on the tenant. Paying for evacuation equipment is cheaper than paying for waking watch to assist. Some of the hardest hit people in society should not be forced to cover this cost. 


You can have a PEEP by training family members and friends, but where there are costs, this should be paid for by the government and not the individual, similar to the access to work scheme. You cannot have systematic change if it's solely based on voluntary actions. There needs to be a list of mandatory actions for landlords.


Building managers should identify vulnerable individuals by working with residents. There must be proactive identification of Disabled people. Disabled people are more than just wheelchair users, blind people, d/Deaf people, neurodiverse people, those with sensory issues. Not every impairment is visible.


The tragedy at Grenfell showed that evacuation processes are not always correct. Risk assessments were wrong. Even in 'stay put' buildings which are deemed to be safer, if the fire enters your flat you have to get out, and without a PEEP in place this

could be more challenging. 


The government talk about costs however some people may only need a small prompt, but the information given by landlords to tenants needs to be in a suitable format for each tenant. Easy read, large print, Braille for tenants with visual impairments, d/Deaf people need access to the information in BSL. PEEPs seem to be for mobility impairments, but the need is far greater. 


Personal Emergency Evacuation Plans are a prime example of the Social Model of Disability. Society can impact how Disabled someone is. Society seems to be neglecting physical/mental impairments and leaving those people severely Disabled and at risk of death. Due to the managing agents/landlords´ lack of care. Due to the government's lack of intervention.


We agree with the report's comments that there is a common misconception that those living on the higher levels of a high rise block of flats are at greater risk from fire, in fact every single person in any building must be able to escape from fire. For many disabled people, escape from the 1st floor without a clear plan may well be just as impossible as escaping from the 22nd floor.


We absolutely do not agree with part 16.13, which says that it "impracticable to make special provision retrospectively, with regard to fire safety design in existing blocks of flats, to address the nature of the occupants". For many local people, a one size fits all stay put plan is disastrous, whilst a clear escape plan would be very possible, very practical and would possibly save their lives. The same used to be said of care provision when Disabled people were locked away in long stay hospitals, and it was later found that when individuals themselves were involved in the process of personalised care planning, actually it wasn't that difficult to achieve what most people needed. Access to live independently and safely are fundamental human rights.


We would also like to ask what the situation is regarding possible Corporate manslaughter charges following an act of disability discrimination where a managing organisation, developer or fire service advocates stay put, and states that no

individual plan is needed, against the expressed wishes of the disabled person, and it is subsequently proved that staying put could never have been the right plan for an individual.


The only other comment is that in the 2010 to 2018/19 report, it was noted that in over 90% of fires where someone died, a working smoke alarm was in place. This indicates that the activity which might be expected to follow, eg. calling the fire service etc, arrival of the fire service, preparation to get in and rescue people etc (if the fire service even knows who is in various compartments, and if they don't the lives of fire fighters are also surely at higher risk?) cannot be relied upon to work, so in reality compartmentalisation timescales cannot be the lifesavers they might be intended to be. Whereas with personalised plans, all parties would know their role, and be clear about the actions they must take.


I would appreciate if you could keep a record of my email address, and directly send me any future planning documents in time for me to consult more fully with local people for their views.


Thank you

Angela Dias

Development Leader

(on behalf of Harrow Campaigns and HAD)

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