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Fire is a risk in all non-domestic premises. In a care home with vulnerable residents, the risk can be higher, and the consequences can be severe. This is due to the dangers and difficulties in evacuating those with disabilities, mobility issues and other impairments. For this reason, care home businesses must prevent fires from starting on their premises so far as is reasonably practicable. There must also be suitable and sufficient fire protection measures to minimise the risks to life and property if there is an outbreak of fire.
Make no mistake, fires can and do happen in care homes, and there have been many unfortunate cases where residents have perished in fires. An example of where things can go drastically wrong is the fire at Rosepark care home in Uddingston, South Lanarkshire (2004). Fourteen elderly residents lost their lives due to inadequate fire safety management and a lack of reasonable precautions.
The latest Fire and Rescue Services statistics show that between 2019 and 2020, there were:
- 14,308 – total fires in non-domestic premises.
- 28,447 – total fires in homes.
- 243 – fire-related fatalities – 45% of the people who died were aged 65 and over. The main cause of death was gas or smoke inhalation, followed closely by burns.
- 6,910 – non-fatal casualties – 20% of the people who were injured were aged 65 and over.
The Rosepark care home fire, along with numerous other tragic fire incidents, and the above statistics highlight the importance of good fire safety management in care homes.
The responsibility for overall fire safety management within non-domestic premises is that of the responsible person. The responsible person has numerous legal duties to relevant persons under the Regulatory Reform (Fire Safety) Order (RRFSO) 2005. One of these duties is to have fire safety arrangements in place, which is a vital part of a fire safety policy.
A well-thought-out fire safety policy is an essential part of fire safety management and compliance. If there is no policy (or it is inadequate), this can be a sign of poor fire safety management. If there are insufficient fire safety arrangements to implement the policy, this will also indicate poor fire safety management. The business will also be non-compliant with fire safety laws.
A robust fire safety policy is at the heart of good fire safety management, and it can bring many benefits to care home businesses. It can reduce the risk of fires occurring in the first instance, and having suitable and sufficient protection measures in place can save lives and protect company assets.
This article will cover what a fire safety policy is, why it is required, how to write one and what happens after.
What is a fire safety policy?
A policy is “a set of ideas or plans used as a basis for making decisions, especially in politics, economics, or business” (Collins English Dictionary). Employers will have policies for different business areas, such as finance, payroll, human resources, health and safety, and quality. These policies underpin other procedures and systems, and a fire safety policy is no exception.
A fire safety policy sets out a business’s general approach to fire safety. It explains how fire safety risks are managed on their premises and should clearly state who does what, when and how. It is an essential document that sets the direction and vision of fire safety and demonstrates a commitment from business owners to prevent harm to relevant persons (e.g. employees, residents, visitors and contractors).
A fire safety policy includes the business’s fire safety arrangements. In larger companies, these arrangements are often part of a formal fire safety management system or manual.
Do I need a fire safety policy for my care home?
The Regulatory Reform (Fire Safety) Order (RRFSO) 2005 doesn’t specifically mention a fire safety policy. However, the responsible person has a legal duty to have appropriate fire safety arrangements under Article 11 of the Order:
“The responsible person must make and give effect to such arrangements as are appropriate, having regard to the size of their undertaking and the nature of its activities, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures”.
Fire safety arrangements are a vital part of a business’s fire safety policy that detail the preventive and protective measures needed to keep relevant persons safe. Therefore, even if the Order doesn’t state that a fire safety policy is required, it is a legal requirement under Article 11.
A fire safety policy is mentioned in the UK Government guidance, ‘Fire safety risk assessment: residential care premises’ (managing fire safety, p45). It states that an organisation’s fire safety policy should be set out in writing, and it also details some points that should be covered.
All employers are legally required to prepare a health and safety policy and revise it where appropriate under section 2(3) of the Health and Safety at Work, etc. Act (HSWA) 1974. As fire is a safety risk, it can be part of your health and safety policy. However, it is recommended you keep your fire safety policy and procedures separate.
For the fire safety policy to be successfully implemented, an effective management system is necessary. It is at your discretion whether you want to go down the formal management system route. There should be at least a fire safety manual containing the policy and associated procedures, rules and processes.
If the Fire and Rescue Authority visit your care home premises, they will likely ask to see your fire safety policy and arrangements. If you do not have a policy or appropriate fire safety arrangements, or if they are inadequate for your care home business, you could face enforcement action, which may lead to prosecution. Many companies have faced enforcement action under Article 11 (1) & (2) of the RRFSO as there was no fire safety policy document.
Why not sign up for our Fire Safety in Care Homes course to learn more about the fire safety legal requirements specific to care homes.
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How do I write a fire safety policy for care homes?
Writing a fire safety policy may seem like a daunting task, but it is not too difficult once you know the structure and the content that is required. It does not have to be complicated, overly lengthy or time-consuming.
The important thing is to make your policy specific to your care home premises, its size, its activities, staffing, the types of residents you are caring for and supporting, and the level of risk from fire.
Some employers copy and paste their policy from other sources, or use templates without making them specific, which is unacceptable and is likely to be non-compliant with the law. Your fire safety policy must reflect your specific situation.
It is also vital that leadership is involved with the policy. There have been many instances of health and safety practitioners or consultants writing the fire safety policy, and then it is just signed by the person at the top without any involvement whatsoever.
Enforcement authorities are putting more emphasis on leadership from the top of the business. Therefore, senior staff and board members (where applicable), along with other employees, should be involved in some aspects of the policy’s creation.
There is no specific requirement for the policy to be of a certain size, and there are no rules for how it should be set out, but it should be proportionate to the nature of your care home business and its risks.
Most fire safety policies will have the following main sections:
- Policy statement.
- Responsibilities for fire safety.
- Fire safety arrangements.
A fire safety policy should start with a policy statement. This part of the policy should contain your commitment to meeting legal requirements and fire safety management. It should also detail the business’s aims and objectives regarding fire safety.
You must be able to achieve the aims of the policy, and your objectives should be SMART:
This section must not be confused with the fire safety policy. It is part of it, but it is not the policy by itself. Unfortunately, some businesses produce the policy statement and think it is complete. Although this part is of vital importance, there is much more to a fire safety policy.
The policy statement must be signed and dated by the most senior person in the business. In smaller companies, it is usually the managing director (MD). In larger ones, it is often the chief executive officer (CEO). Having a senior person sign the policy will demonstrate your care home’s commitment to fire safety. It will also give authority to the document.
Responsibilities for fire safety in care homes
This part of the policy should detail the names, positions and duties of those who have specific responsibilities for fire safety within the business. It could include those responsible for:
- Policy setting, e.g. directors and senior managers.
- Overall fire safety management, e.g. the responsible person.
- Day-to-day operations and policy compliance, e.g. middle managers and supervisors.
- Fire safety advice, incident investigations, audits and inspections, e.g. fire safety advisers and officers. It may include an external fire safety consultant if one is used by the business.
- Representing employees in fire safety matters, e.g. trade union safety representatives or representatives of employee safety.
- Specialist services, such as fire systems and equipment maintenance.
- Fire preventive and protective measures, e.g. fire wardens.
The above are examples and are not exhaustive. Employees also have responsibilities under fire safety legislation and general health and safety legislation. Therefore, this should also be included in this section.
Some smaller businesses may only have one or a few people with fire safety responsibilities, who can be detailed in the policy as a simple list. Larger organisations may use an organisation chart to demonstrate responsibilities, hierarchies and reporting lines.
It is up to you how you demonstrate who has what responsibilities for fire safety. It is vital that all those who have duties are made aware of what is expected of them. They must also agree to their responsibilities and have the necessary resources to fulfil their duties.
Fire safety arrangements
The last part of the fire safety policy should detail the practical arrangements for managing fire safety risks within your care home business.
These arrangements should show how you will meet the aims of your policy statement. It is, therefore, crucial that they can meet your policy aims and that they are achievable. The arrangements section is the largest part of the policy and should cover relevant fire safety topics under different headings.
Some examples of what to cover in this section include (this list is not exhaustive):
- Fire risk assessments (FRAs), including specific hazards and risks.
- Fire safety precautions, i.e. preventive and protective measures.
- Inspections and testing of systems and equipment.
- Information, instruction and supervision.
- Staff fire safety training.
- Emergency procedures, such as fire emergency evacuation plans (FEEPs) and personal emergency evacuation plans (PEEPs).
- Fire drills.
- Monitoring and review of the policy and arrangements.
The arrangements required will depend on the nature of your care home business, including its complexity, size and risks. You will also need to think about applicable fire safety legislation and how your arrangements will meet your legal obligations.
Larger businesses with higher risks are likely to have a more detailed arrangements section, which may be in a formal management system format. Smaller companies may have specific procedures, systems and processes together in a fire safety manual or logbook. It is at your discretion which format you use.
If you decide on a more formal management system, you could use a recognised standard, e.g. BS 9997 fire risk management system. Having your management system audited and certified can assist with compliance and can also enhance your reputation.
It is better if the fire safety policy is written by a person who works within the business rather than an external company. However, you can use a competent fire safety consultant to assist you if there is insufficient expertise within the business. You should still ensure that you involve those internally in the creation of your policy.
What should I do once I have written it?
Once the fire safety policy has been written, it should be signed and dated by the most senior person in the company, i.e. the individual ultimately responsible for the policy and fire safety.
A fire safety policy is a ‘live document’ and must be visible. There have been many instances where a policy has been written and then it is not seen again until the next review. If the policy is treated in such a manner, this is an indication that fire safety management is poor, which will negatively impact the business at some point.
A fire safety policy should be regularly:
- Reviewed – there is no specified period for a policy review. However, at the very least, an annual review is recommended. It will require a more frequent review if there are any significant changes within the business, e.g. changes to the number/types of people, building layout, processes and activities.
- Monitored – the policy should be monitored so that it remains effective. Monitoring can include audits, inspections, review of incidents and near misses, and spot checks. If there are any issues with the policy’s effectiveness, and you are not meeting your objectives, it should be reviewed.
The policy needs to be brought to the attention of your employees, their representatives, and any other relevant persons who could be affected by fire risks. You may also need to make visitors, contractors and temporary workers aware (where relevant).
It is advisable to display your fire safety policy in a prominent position, e.g. on a staff notice board or shared computer programmes so it can be referred to by relevant persons. If it is a shorter document, you can give employees a copy
It is also good practice to go through the main points of the policy in induction and training. If there are any changes to the policy, these should also be communicated.
A robust fire safety policy that is implemented successfully will prevent an outbreak of fire and mitigate the impacts if one was to occur. It will also keep your care home business on the right side of the law.
The responsible person must legally have appropriate fire safety arrangements in place. Therefore, as a minimum, you must cover the legal requirements when developing and implementing your fire safety policy and arrangements. It is always best to go above the minimum legal requirements, as this will demonstrate your commitment to preventing fires and protecting relevant persons.
You should always consider whether you can achieve the aims of your policy. If you have said that you will do something, then you must be able to carry it out. Otherwise, there may be questions regarding the validity of your policy and management. Your policy should be specific, and your aims achievable.
You can use our template to assist you in creating or reviewing your fire safety policy for your care home. If you use this template, you must ensure that you make it specific to your business.