The RPEEPs Regulation guidance clarifies, in paragraphs 7.10 and 7.11, that the Regulations only apply to the common areas of in-scope buildings, not to the flats. This reflects the position set out in the Regulatory Reform (Fire Safety) Order 2005, which is the legal vehicle for the Regulations and specifically excludes domestic premises (flats) from its scope.
It is important to note that Person-centred Fire Risk Assessment (PcFRA) in the common parts will be primarily focused on means of escape and related life-safety measures rather than the wider range of hazards normally covered in a PcFRA undertaken for an individual flat. The guidance also fails to clarify the difference between a PEEP, an industry accepted term, and “an emergency evacuation statement”, which risks creating uncertainty for both landlords and residents.
In parallel, Awaab’s Law requires a person-centred approach to the 29 hazard categories covered by the Housing Health and Safety Rating System (HHSRS), including fire safety and electrical hazards, across all social housing (houses and flats). Awaab’s Law is already in force ensuring that individual resident hazards are identified and addressed promptly in domestic premises through PcFRAs and wider housing inspections.
The guidance also notes that the Regulations are expected to be extended in future to cover domestic premises. Any extension of the RPEEPs Regulations into domestic premises risks duplicating work already being carried out under Awaab’s Law, without providing any additional benefit, and will add additional administrative burden rather than improving real-world safety outcomes.
Any future extension of the Regulations will therefore need to be carefully aligned with existing legislative frameworks to avoid overlap and keep the focus on what most effectively protects disabled and vulnerable residents.
