Staying Safe:
Disability, Fire and the Law
Colin Todd, Managing Director
C. S. Todd & Associates Ltd
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Fire Risk in Hotels

Fires in UK hotels 2002 - 2008
1200
1000
800
600
400
200
0
2002
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2003
2004
2005
2006
2007
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2008
Fire Risk in Hotels

Fires in UK hotel bedrooms 2002 - 2008
250
200
150
100
50
0
2002
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2003
2004
2005
2006
2007
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2008
Fire Risk in Hotels

UK hotel bedroom fires that spread
beyond room 2002 - 2008
20
18
16
14
12
10
8
6
4
2
0
2002
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2003
2004
2005
2006
2007
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2008
Interfacing Legislative Regimes
Fire Safety
Legislation
Building
Regulations
Equality
Act
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Building Regulations
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
England and Wales

Building Regulations 2010 supported by
AD B

Scotland

Building (Scotland) Regulations 2004 (as
amended) supported by the Tech
Handbooks

Northern Ireland

Building Regulations (Northern Ireland)
2000 supported by TB E
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Interfacing Legislative Regimes
Fire Safety
Legislation
Building
Regulations
Equality
Act
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Fire Safety Legislation

England and Wales

Regulatory Reform (Fire Safety) Order 2005

Scotland


Fire (Scotland) Act 2005
Fire Safety (Scotland) Regulations 2006

Northern Ireland

Fire and Rescue Services (Northern Ireland)
Order 2006
Fire Safety Regulations (Northern Ireland)
2010

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Interfacing Legislative Regimes
Fire Safety
Legislation
Building
Regulations
Equality
Act
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Equality Act 2010
Applies in Great Britain
 Does not override other legislation
 Reasonable adjustments for substantial
disadvantage due to disability
 Direct discrimination cannot be justified
 Indirect discrimination justified subject to
proportionate means of achieving
legitimate aim
 Breach affords right of action in civil law

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Disability
Defined by later speaker
 In a hotel, need to consider:

 Mobility impairment
 Deaf and hard of hearing people
 Blind and partially sighted people
 People with cognitive impairment
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Requirements for Access
and Amenity

Part M of Building Regulations 2010
Reasonable provision for people to gain access
and to use the building and its facilities
Same requirement for disabled people in Part R
of the Building Regulations (Northern Ireland)
2000
 Functional Standard 4.2 in Scotland

Safe, unassisted and convenient means of access
throughout the building plus accessible bedrooms
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Key Points of Interpretation
of Building Regulations
Access for mobility impaired and blind
and partially sighted people
 Proportion of hotel bedrooms accessible
for wheelchair users
 Visual fire alarm devices in bedrooms
and toilets (less specific in Scotland)

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Fire Safety Legislation
Where necessary, in the event of danger, it
must be possible for persons to evacuate
the premises as quickly and as safely as
possible
 Where necessary, the premises must be, to
the extent that it is appropriate, equipped
with appropriate fire detectors and alarms
 An offence is committed only if a breach
puts relevant persons at risk of death or
serious injury in case of fire

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Potential Conflicts
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Access versus egress
Amenity versus safety
Staff evacuation versus staff assistance for
disabled people
Affordable accommodation versus adequate
assistance for evacuation
Space utilization versus provision of refuges
Provision of refuges versus unobstructed escape
routes
Alarm audibility versus refuge communication
Fire doors!
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Misconceptions and
Misunderstandings
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The fire and rescue service evacuate
disabled people
Evacuation lifts should be used by
disabled people without staff supervision
or control
One staircase or evacuation lift is
always sufficient
Disabled evacuation is about hardware
and physical measures
Use of stock solutions, not tailor-made
to building
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Two Main Issues
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Evacuation of disabled people from
upper floors

Warning of deaf and hard of hearing
people
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Evacuation Problems
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Provision of refuges (TWS)
How many refuges
Communication with disabled people in
refuges
Availability of staff
Single manning at night
Unstaffed buildings
External paths
Logistics and training in use of equipment
Separation of family groups
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Warning Problems

Visibility of visual alarm devices (VADs)

No code for location and siting of VADs

Are vibrating devices necessary?
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Philosophy
EQUIVALENCE:
The basis of all solutions
 Leads inexorably to correct answers
 Think it! Commit to it!

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Menu of Solutions
(Management)
Management commitment
 Identification of special needs
 Sufficient staff with proper training
 Instructions to guests

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Menu of Solutions
(Physical Measures)
Siting of disabled rooms
 Early warning (smoke detectors in
disabled bedrooms)
 Protection of corridors
 Refuges (? bedrooms)
 Communication within refuges (BS
5839-9)
 Evacuation lifts

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Final Thought
“The only disability in life
is a bad attitude”
Scott Hamilton
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