The LWF Blog

Fire Risk Assessment for Healthcare Premises – FSO and Enforcement – Part 83

April 11, 2022 12:15 pm

LWF’s blog series for healthcare professionals aims to give information on best practice of fire safety in hospitals and other healthcare premises. In part 82 of Fire Risk Assessments for Healthcare Premises, LWF looked at the requirements for fire detection in healthcare premises. In part 83, we discuss staircases and enforcement action.

Staircase provision in older hospital premises

Approved Document B and HTM documents contain standards relating to the number and width of staircases in hospital premises. However, in older hospitals, the staircase provision in place may not meet those standards.

It may also be the case that the cost of adding new staircases to replace the ones which have insufficient width or in providing additional staircases to supplement the number available could be disproportionate to the benefits it would afford.

A fire risk assessment should be undertaken for the individual premises which may show the addition of certain fire protection measures could supplement and mitigate the level of fire risk. For example, it may be that fire protected sub-compartmentation to larger areas would help slow the spread of fire from one sub-compartment to another and allow additional time for evacuation using the existing staircase provision. Other measures that may be employed are sprinkler systems, additional staff and staff training to provide an equivalent level of safety for the building occupants.

Enforcement Action by the Fire Authorities

Should a fire authority deem it is necessary to take enforcement action against hospital premises, the preferred method is by an agreed action plan. This is, of course, assuming that the Responsible Person is cooperative and willing to make reasonable efforts to comply.

In some circumstances, however, the residual risk is too great and the FA may issue a formal enforcement notice.

The FA will discuss enforcement action with the responsible person and take into account the RP’s views and attitudes prior to doing so.  Where a formal enforcement notice is issued and a technical solution cannot be agreed upon, the RP may seek a determination from the Secretary of State. Further details on this process can be found in Article 36 of the Regulatory Reform (Fire Safety) Order 2005. (

If the RP or the FA do not think a determination is an appropriate route of appeal, a formal appeal may be lodged with a magistrate within 21 days of the issue of the enforcement notice.

In Part 84 of LWF’s blog series, LWF will continue to look at the process of enforcement and appeals. In the meantime, if you have any questions about this blog, or wish to discuss your own project with one of our fire engineers, please contact us.

Lawrence Webster Forrest has been working with their clients for over 25 years to produce innovative and exciting building projects. If you would like further information on how LWF and fire strategies could assist you, please contact LWF on freephone 0800 410 1130.

While care has been taken to ensure that information contained in LWF’s publications is true and correct at the time of publication, changes in circumstances after the time of publication may impact on the accuracy of this information.

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