Managing a House in Multiple Occupation brings fire safety duties that exceed standard residential landlord requirements. The Regulatory Reform (Fire Safety) Order 2005 designates the responsible person, who must arrange a suitable and sufficient fire risk assessment for the property. Shared communal areas and unrelated tenants living under one roof create specific hazards that the assessment needs to identify and address.
Understanding Your Role as the Responsible Person
In an HMO, the responsible person is typically the landlord, property manager, or managing agent who has control of the premises. Under the RRO, you have a legal duty to identify fire hazards, evaluate the risk to occupants, and implement appropriate fire safety measures.
It is important to remember that local housing authorities also enforce specific HMO licensing conditions under housing legislation, which often include strict fire safety requirements. However, the RRO remains the primary legislation governing fire risk assessments and ongoing fire safety management for the communal areas of residential properties.
What Makes an HMO Higher Risk?
HMOs present distinct fire safety challenges compared to single-family dwellings. Because tenants live independently behind their own locked doors, a fire can start in one room and go unnoticed by others. The shared nature of the building means that escape routes—such as hallways, staircases, and landings—can easily become compromised.
Key factors that increase fire risk in an HMO include:
- Multiple ignition sources: More kitchens and electrical appliances across the property increase the likelihood of a fire starting.
- Shared escape routes: A single fire in a communal area can block the only exit for multiple tenants.
- Unrelated occupants: Tenants may not be familiar with one another's routines, making it harder to account for everyone during an evacuation.
- Varied tenant behaviour: Factors such as cooking habits, smoking, or the use of portable heaters can introduce unpredictable risks.
- Higher turnover: Frequent changes in tenancy mean fire safety information and escape route discipline must be continually reinforced.
Key Elements of an HMO Fire Risk Assessment
A thorough HMO fire risk assessment must evaluate the entire premises, focusing on how a fire might start and how tenants will escape. While the RRO does not prescribe a rigid format, following recognised guidance such as PAS 79 provides a robust framework for the assessment.
The assessment should carefully consider:
- Means of escape: Are the escape routes adequately protected? Fire doors with self-closing devices are essential to prevent smoke and flames from spreading into stairwells and hallways.
- Fire detection and warning systems: An interlinked fire alarm system is usually required so that a fire in one part of the building alerts all occupants.
- Emergency lighting: In the event of a power cut or a fire causing dense smoke, emergency lighting must illuminate the escape routes to ensure safe evacuation.
- Firefighting equipment: Appropriate fire extinguishers and fire blankets must be provided and maintained in line with BS 5306 standards.
- Hazard management: The assessment must identify combustible materials in communal areas, such as rubbish, furniture, or storage, and recommend their removal to keep escape routes clear.
Competency and Record-Keeping
The RRO requires the fire risk assessment to be conducted by a competent person. For complex HMOs—particularly large, multi-storey buildings or those with mixed commercial and residential use—landlords often lack the specialist knowledge required to evaluate structural fire protection and alarm system adequacy. If you are unsure about your ability to assess these risks accurately, it is highly recommended to seek professional support.
Furthermore, while the RRO does not explicitly state that every responsible person must record the findings of their assessment, you are legally required to record the significant findings if you employ five or more people, or if the premises are subject to licensing (which most HMOs are). Keeping a written record is always best practice and serves as vital proof of compliance during local authority or fire service inspections.
Ongoing Review and Maintenance
A fire risk assessment is not a one-off exercise. The RRO requires that the assessment be kept up to date and reviewed regularly. You must review your assessment whenever significant changes occur, such as:
- A change in the number of tenants or the layout of the property
- The installation of new furniture or electrical appliances in communal areas
- Following a near-miss or actual fire incident
- Any structural alterations to the building
Even if no changes occur, it is good practice to formally review the assessment annually to ensure all fire doors, alarms, and emergency lighting remain fully operational.
How HawkSwift Can Help
Navigating HMO fire safety duties can be complex, but ensuring compliance protects both your tenants and your investment. At HawkSwift Ltd, our NEBOSH-qualified assessors provide comprehensive fire risk assessments from £199 + VAT, delivering detailed, easy-to-understand reports within 48 hours. To ensure your property meets the requirements of the RRO, book a fire risk assessment with our team today.
Quick answers
Q: Who is responsible for doing a fire risk assessment on an HMO?
Under the Regulatory Reform (Fire Safety) Order 2005, the responsible person—typically the landlord, property manager, or managing agent who has control of the premises—must ensure a suitable and sufficient fire risk assessment is carried out.
Q: Why do HMOs need a special fire risk assessment?
HMOs present higher fire risks because unrelated tenants live independently behind locked doors and share communal escape routes. A fire can easily go unnoticed by other occupants and quickly compromise the shared hallways and staircases that serve as the only exits.
Q: What should be included in an HMO fire risk assessment?
Following recognised guidance like PAS 79, the assessment must evaluate means of escape, interlinked fire detection systems, emergency lighting, and firefighting equipment. It must also identify and manage combustible materials in communal areas to ensure tenants can safely evacuate.
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