Staying Safe: Disability, Fire and the Law Colin Todd, Managing Director C. S. Todd & Associates Ltd C.S. TODD & ASSOCIATES LTD C S T A

Fire Risk in Hotels  Fires in UK hotels C.S. TODD & ASSOCIATES LTD C S T A

Fire Risk in Hotels  Fires in UK hotel bedrooms C.S. TODD & ASSOCIATES LTD C S T A

Fire Risk in Hotels  UK hotel bedroom fires that spread beyond room C.S. TODD & ASSOCIATES LTD C S T A

Interfacing Legislative Regimes C.S. TODD & ASSOCIATES LTD C S T A Building Regulations Fire Safety Legislation Equality Act

Building Regulations  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 C.S. TODD & ASSOCIATES LTD C S T A

Interfacing Legislative Regimes C.S. TODD & ASSOCIATES LTD C S T A Building Regulations Fire Safety Legislation Equality Act

Fire Safety Legislation C.S. TODD & ASSOCIATES LTD C S T A  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

Interfacing Legislative Regimes C.S. TODD & ASSOCIATES LTD C S T A Building Regulations Fire Safety Legislation Equality Act

Equality Act 2010 C.S. TODD & ASSOCIATES LTD  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 C S T A

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 C.S. TODD & ASSOCIATES LTD C S T A

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 C.S. TODD & ASSOCIATES LTD C S T A

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) C.S. TODD & ASSOCIATES LTD C S T A

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 C.S. TODD & ASSOCIATES LTD C S T A

Potential Conflicts  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! C.S. TODD & ASSOCIATES LTD C S T A

Misconceptions and Misunderstandings  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 C.S. TODD & ASSOCIATES LTD C S T A

Two Main Issues  Evacuation of disabled people from upper floors  Warning of deaf and hard of hearing people C.S. TODD & ASSOCIATES LTD C S T A

Evacuation Problems  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 C.S. TODD & ASSOCIATES LTD C S T A

Warning Problems  Visibility of visual alarm devices (VADs)  No code for location and siting of VADs  Are vibrating devices necessary? C.S. TODD & ASSOCIATES LTD C S T A

Philosophy EQUIVALENCE:  The basis of all solutions  Leads inexorably to correct answers  Think it! Commit to it! C.S. TODD & ASSOCIATES LTD C S T A

Menu of Solutions (Management)  Management commitment  Identification of special needs  Sufficient staff with proper training  Instructions to guests C.S. TODD & ASSOCIATES LTD C S T A

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 )  Evacuation lifts C.S. TODD & ASSOCIATES LTD C S T A

Final Thought “The only disability in life is a bad attitude” Scott Hamilton C.S. TODD & ASSOCIATES LTD C S T A