Disabled evacuation planning and PEEPs
“I’ve spent three years fighting for the right to escape from a burning building”
Personal Emergency Evacuation Plans – or PEEPs – have been high on the fire safety and evacuation agenda for several years now. At FIREX, attendees heard what bad practice and good practice looks like in reality, and where the debate is destined to go next.
Towards the end of the chapter, we also hear the perspective of expert PEEPs advisor, Elspeth Grant, in an interview carried out by IFSEC Insider earlier this year.
Private leaseholders Liz Kimber and Joe Dowd explained their struggle to get their managing agent to put a PEEP in place.
Liz Kimber and Joe Dowd are private leaseholders of a new-build flat in West London since 2002.
They rented their flat out while working overseas between 2005-2013. On their return Joe had a life-changing injury but where they were living adhered to what was required at the time in terms of fire safety, compartmentation and a stay-put policy.
After Grenfell, a cladding issue was identified and a fire risk assessment (FRA) in 2020 identified a high-risk rating. A request for a PEEP was raised in October 2020.
Six months later, the managing agent replied to say that they had no responsibility for PEEPs, quoting that LGA Fire Safety in Purpose Built Blocks of Flats, 2011 that “expecting MAs and Freeholders to carry out PEEPs is usually unrealistic”.
This wording was redacted the same year, but the managing agent of Liz and Joe continued to use it as a get out clause, even when it changed the fire evacuation advice for residents to “if in doubt get out!”
The managing agent changed in 2022, but after a positive start, Liz and Joe were met with “continual excuses” about the level of obstruction an evacuation chair would cause.
A third-party FRA in August 2022 confirmed Joe would need an evacuation chair, at a cost of £1500.
After the managing agent offered to carry out the PEEP for £850+ VAT, Joe and Liz commissioned their own PEEP assessment, which was submitted in March this year, along with LFB recommendations about floor signage and an accessible exit door. There has yet to be a response.
Liz made the point that the cost of an evacuation chair would be £40 per leaseholder in their block of flats, a small cost compared to others they have had to bear.
Joe, meanwhile, expressed how grateful he is to have an advocate and spoke of the “unnecessary stress” he has experienced for “three years and counting to fight for the right to escape a burning building.”
Joe feels like his treatment is prejudiced because of his health difficulties and fears being “cremated alive” and is angry that a “fair and reasonable solution” can’t be reached.
The presentation that followed from Samantha Shimmon from East Suffolk Council was a stark contrast to the frustrating story of Joe and Liz.
While admittedly a small social housing portfolio of 4,500 properties, PEEPs have now been rolled out across all of them, including high rise blocks, a temporary accommodation block, house flats and bungalows.
Council staff underwent a one-day course in PEEPs, which Shimmon admits was probably more suited to two or three days.
However, from the training the council prioritised their Category 1s (evacuation by three or more persons/firefighters) and 2s (evacuation by two or more persons/firefighters with no additional equipment).
Using a one-sheet overview of each building, a sliding-scale of priority was constructed from highest to lowest, with the order of: high-risk blocks, retired living schemes and then temporary accommodation and general needs.
Through introducing PEEPs the team learned that regular reviews and updates would be required.
Meanwhile, from the tenant point-of-view, older residents felt reassured, though some had to face the reality that they needed to move.
Outcome for residents within three months:
Vibration pads and flashing light alarms for residents with hearing impairments;
Evacuation chairs for those identified as needing one and had a suitable buddy;
Evacuation chairs for each floor above ground in Retired Living Schemes;
Under mattress sheets supplied for bedbound residents;
Personal sprinkler/misting system provided for bedbound residents;
A programme of evacuation drills was started.
Medium-term outcomes (three to nine months):
Work with alarm out of hours contractor to develop plans for messaging to be pushed out via the alarm system in the event of an emergency
Redecoration of stairwells with yellow walls or strips of yellow behind handrails, and replace handrails with blue ones.
Handrails supplied to both sides of stairwells.
Longer-term outcomes (within two years):
Investigate installing sprinkler systems to all Retired Living schemes and Temporary Accommodation blocks
Investigate installing emergency refuges with emergency voice control in High-Rise, Retired Living and Temporary Accommodation blocks
Investigate increased compartmentalisation in sections of any buildings with a high number of residents unable to self-evacuate.
Rounding off the session, Elspeth Grant, CEO Specialist PEEPS Advisor and Trainer, reminded everyone that PEEPs – if planned logically and sensibly – were “not rocket science.”
She highlighted a few golden rules about reports noting the profile of the residents, including their ability to self-evacuate, whether there is a cognitive impairment and if a resident’s language is not English.
Finally, it’s imperative to ensure that arrangements have been communicated to residents and to the Fire Rescue Service.
Turn the page for Part 3 of this chapter…
‘Fire Safety Order already says that everyone must be able to evacuate the building’ says PEEPs expert, Elspeth Grant, who IFSEC Insider interviewed shortly before FIREX.
Elspeth also spoke at FIREX with Liz, Joe and Samantha, having been the driver in arranging the presentations.
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 returned to London ExCeL and delivered an update on the topic at this year’s show.
In the following interview Grant discussed the problems with PEEPs enforcement, the potential unforeseen consequences of the second-staircase consultation and the limited merits of evacuation lifts.
Elspeth Grant, Specialist PEEPs advisor
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.
The 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.
"The reason we are in this situation is the prevailing mantra of ‘stay put’."
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.
