Kitchen fire doors for two storey HMO’s and LHA requirements?

Kitchen fire doors for two storey HMO’s and LHA requirements?

13:24 PM, 27th November 2018, About 4 years ago 41

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There appears to be a conflict relating to the need for a kitchen fire door in two storey HMO’s. The Lacors Housing Fire Safety Guide, click here to download, and The Licensing and Management of Houses in Multiple Occupation and Other Houses (Miscellaneous Provisions) (England) Regulations 2006 Schedule 3 Article 3 (ix) click here to download.

The 2006 Regs relates to HMO’s of all sizes whether licensed or not. Additionally, it does not distinguish between HMO’s let under a single AST or multiple AST (per bedroom (bedsits).

For two storey HMO’s, the subject of this article, Lacors page 41 (Escape routes) states that there is no need for fire doors, assuming a sound construction standard for the primary escape route. For bedsits, however, 30 minute fire doors are required (page 43). So, under Lacors guidance, two storey HMO’s of sound construction let under a single AST would not require fire doors to any room.

However, the 2006 Regs state that an “appropriate” fire door must be fitted to the kitchen. I am aware that the Lacors definition of a fire door (30 min fire door & frame) does not accept a close fitting solid door. However, does the word “appropriate” in the 2006 Regs imply a solid close fitting door would be ok?

There seems to be confusion between LHA’s licensing standards for HMO’s. Some follow Lacors, where a fire risk assessment will identify additional requirements, and others follow the 2006 Regs where some have defined “appropriate” in different ways (some a fire door as defined by Lacors some  a close fitting solid door.

Insisting on kitchen fire doors (30 minute fire door with frame) will subject many landlords to the unnecessary additional cost of installing a kitchen fire door in situations where it adds not safety value at all. Two storey HMO’s will normally have a secondary means of escape (1st floor windows) and many will have kitchens set well back from the primary escape route. In this case I do not feel that a kitchen fire door (30 min fire door with frame) is necessary (assuming kitchen heat detector is fitted).

Has anyone experienced an LHA insisting on a kitchen fire door as required by 2006 Regs where “appropriate” has been interpreted as a 30 minute rated fire door and not a solid close fitting door? If so, have you challenged the LHA’s definition of “appropriate” and if so what was the conclusion?

Did you go to a Rent Tribunal?




Neil Patterson View Profile

13:26 PM, 27th November 2018, About 4 years ago

Thank you for your question Rob and to assist I have added download links to the regulations you reference.


14:01 PM, 27th November 2018, About 4 years ago

I've just had (and had withdrawn) and Intent to Fine for having no fire doors on a two storey, four person (separate agreements) HMO. The council have called me an 'offender' from the start and tried it on for a 25k fine. they say I broke the law for not having fire doors and smoke alarms in all the rooms. Its been dropped now on a technicality. It was a very scary experience though.

Rob Crawford

15:09 PM, 27th November 2018, About 4 years ago

Reply to the comment left by MARIE ELLIS at 27/11/2018 - 14:01Not sure what "law" was broken, but with bedsits (see Lacors definition for a bedsit) as let under multiple AST's doors on primary escape route needs to be 30 min rated fire doors.


9:07 AM, 28th November 2018, About 4 years ago

I have had a notice from East Herts Council to install 30 min fire doors to all bedrooms and cupboards plus build a wall between the kitchen and diner (all one room) with a 30 min fire door installed otherwise face a fine. Also interlinked smoke detectors in each room and cupboard (at the moment battery operated ones). 2 tenants on the ground floor have their own exits from their rooms into the garden and don’t need to even enter the rest of the house if there’s a fire, and the other 3 are on the first floor with windows. Plus I have to increase plug sockets by 3 in every room bring them up to 6 per room!

It’s a 2 story 5 bed HMO let on individual ASTs and they said that this poses a greater fire risk.

I referred them to the appropriate LACORS sections to no avail. The work is costing near £10k.

I’m a responsible landlord and I just feel this is overkill???

PJB View Profile

9:34 AM, 28th November 2018, About 4 years ago

For a two storey dwelling only, if all habitable rooms on the first floor are equipped with fire escape windows i.e. an escape aperture of at least 450mm x 450mm, the property will have an acceptable alternative escape route. It makes many of the fire safety requirements non-compulsory.

Anne Nixon

10:42 AM, 28th November 2018, About 4 years ago

I am currently living the nightmare of all this after applying for an HMO licence for a 6 bed dormer bungalow with one upstairs room. It already has fire doors everywhere, thumb turn locks and a hard wired fire detection system in every room and I expected it to sail through the inspection but unfortunately not so.
On inspection day the inspector started her visit by informing me that it would not be possible to get a licence for 6 bedrooms it would be for 5 as she had seen the floor plan - that was even before she had looked around and it continued to go downhill from there, the story is far too long for a post like this.
I received a prohibition notice two days ago with the order to install a sprinkler system in the kitchen along with 8 other 'works' by Christmas eve.
Calling a national 'fire safety' installation company yesterday which is based locally to me to order the installation I was told "this can't be right, you have misunderstood, I sell them, it's my business and it's all I do and there is no way a sprinkler system would be needed in this kind of property, call building regs, talk to them and they'll talk you through it".
He concluded the conversation by telling me that he was fully booked until June 2019 but was happy to book my job in after June, just let him know.
The problem is this - the LA housing team have not one clue what they are doing but they are in a position of power and can take the moral high ground by purporting to be working to promote public safety.
Whether their demands make sense or not, whether they are total overkill, whether perfect rooms go unused, whether it costs thousands of pounds to install effectively useless equipment does not matter to them, why would it?
These people have a 'computer says no' mentality and discussion with them is futile. They are out of their depth and covering their own backs and admitted that to me in conversations.
So I WILL install their pointless sprinkler system and the other 8 items, as quickly as possible but maybe by the sound of it not by Christmas eve, just because I want a quiet life and I want to shut them up and move on.


11:10 AM, 28th November 2018, About 4 years ago

Heat Detector in a kitchen - would only go off when half the kitchen is burnt through! what a marvelous early warning device.
Have they tested these in mock up examples?

And Fire Doors in Kitchen! another waste of time because no matter how many times you tell tenants to keep it closed even with self closing devices, tenants use a wedge to keep it open, because they see it as obstruction to move freely! another waste of time gadget. I have given up on my tenants not to use the wedge.

Anne Nixon

11:17 AM, 28th November 2018, About 4 years ago

Sorry, me mid rant here - some other points mentioned on my prohibition notice, the two downstairs bedrooms of the bungalow which already had escape windows fitted when the conversion was done also have need for the requested sprinkler system over the exit route through the kitchen, because 'one would not normally exit through a window into the garden in case of fire' those are two more of my prescribed 8 points to address!!


11:18 AM, 28th November 2018, About 4 years ago

Reply to the comment left by PJB at 28/11/2018 - 09:34
But East Herts council won’t hear of it. They are still insistent that fire doors and linked smoke detectors in all first floor, ground floor, under stairs cupboard, airing cupboard otherwise they won’t grant me my HMO licence. So where do I stand?

Ian Narbeth View Profile

11:57 AM, 28th November 2018, About 4 years ago

Reply to the comment left by Mike at 28/11/2018 - 11:10Hi Mike
You write: "no matter how many times you tell tenants to keep it closed even with self closing devices, tenants use a wedge to keep it open". True, but there is a solution. Use Dorgards: or
These hold the door open but release when there is a continuous noise for 15 seconds (such as the fire alarm going off).
I would also write to the tenants to say that obstructing the fire door is an offence and that they can be prosecuted by the Council.

Mike, fire doors are not a waste of time. A friend of mine had a fire at his HMO and the doors worked and the damage was contained and thankfully nobody was hurt. When politicians, housing charities etc. see landlords calling fire doors a waste of time they don't think "poor landlord".They think the tenants are at risk.

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