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

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?

Thanks.

Rob

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