About PEEPs
The absence of Personal Emergency Evacuation Plans (PEEPs) significantly endangers impaired and disabled individuals and Fire and Rescue Services. This risk is exacerbated by inadequate evacuation strategies during emergencies, which can expose those responsible for fire safety to potential legal liability for non-compliance with existing legislation.
It is crucial to understand the distinction between a PEEP and a Person-centred Fire Risk Assessment (PcFRA) that are often misunderstood.
What is a PEEP?
PEEPs are imperative for impaired individuals. They ensure adherence to the Fire Safety Order’s mandate that all building occupants must be capable of moving away from immediate danger and exiting the premises to a place of total safety. This requirement encompasses all individuals, including those with temporary impairments, in all buildings.
The PEEP is a tailored strategy designed to provide safe evacuation procedures for individuals who may need assistance during an emergency, such as those with disabilities or mobility impairments.
A PEEP also provides evidence of compliance with the Fire Safety Order (FSO) by ensuring that all “relevant persons” have a clear, accessible evacuation plan enabling them to reach a place of total safety without the assistance of the ire and Rescue Services.
What is a PcFRA?
A PCFRA considers the specific needs and vulnerabilities of individuals within the building, addressing factors like mobility, sensory impairments, or cognitive challenges to create a comprehensive, inclusive fire safety strategy.
An assessment process is used to identify, evaluate and mitigate the fire risks faced by an impaired individual. This includes identifying fire safety hazards within the domestic premises, as well as barriers the person may experience when moving through the building and accessing the means of escape. A PcFRA considers the person’s abilities, the building environment, and existing management arrangements, and determines appropriate and proportionate risk reduction measures.
In simple terms, a PcFRA identifies hazards, risks, and suitable controls, including within the home, while a PEEP sets out the agreed emergency evacuation actions informed by that assessment.
A PcFRA on its’ own does not meet the requirements of the FSO if the individual is unable to evacuate as quickly and as safely as possible.
The Local Government Association Legal Advice
The Local Government Association (LGA), upon obtaining legal counsel, highlighted in their response to the EEIS+ Consultation:
“Part 3 of the Equality Act 2010 imposes an anticipatory duty on councils and housing associations regarding the allocation of tenancies and the management of let properties. This necessitates proactively considering disabled residents’ needs without requiring individual requests.”
Furthermore, the LGA emphasised that this obligation extends to all buildings, irrespective of their evacuation strategies and that differentiating the treatment of disabled residents based on building height is likely indefensible under equality law.