Smoke alarms in HMO requirements

[Andy78]

Hi, just looking for a bit of advice for those who do more of this sort of work than myself, which is hardly ever.
I have had a customer today ask me for advice about a house she is preparing to rent as a HMO. 3 bed house, not overly large, over two floors, so not a licenced HMO.

The council have informed her that she needs a minimum of a grade D LD3 system installing, but have not told her what legislation requires this and told her to research it all herself.

I wasn't able on the spot to confirm or deny the actual legal requirements for this action to be taken. Could anyone with more knowledge of HMO rentals help me out ?

I also recall something recently about CO detectors being required in rentals now where solid fuel burning appliances are used, a log burner in this case, yet the council have not mentioned this. If this is required is it required to be interlinked and mains fed or will a battery unit suffice ?

 

[Leesparkykent]

Can I Interconnect Smoke Alarms and Carbon Monoxide (CO) Alarms? - http://www.brkelectronics.com/faqs/oem/can-i-interconnect-smoke-and-co-alarms

What do I fit? Aico - Fire & CO Detection & Fire Protection Specialist - http://www.aico.co.uk/What-do-I-fit.html

Don't know if this helps Andy?

 

[Darkwood]

You don't want both alarms triggering on a common signal as this would cause confusion and even the wrong action taken putting lifes at risk, if you were to employ such a system then it would need to send a unique signal to similar devices thus only smoke or CO sound at the correct time, I dont know the regulations around this but thats my thoughts on the matter, at the cost of a system that uses smart signaling if one exists I assume for domestic at least it may be a bit pricey just to save a few hours on installation.

 

[Dave OCD]

I recently upgraded the alarms in 2 flats being done up for student lets, the existing smoke alarms were about 15 years old ! The new owner also insisted on CO detectors, but the common boiler for both flats is outside in a shed !

 

[Andy78]

Thanks for the info and opinions on CO interconnection guys. This makes perfect sense now.
I had been through my AICO book Lee but was struggling to find exactly which legislation applied to a small HMO, be it the housing act, HASWA, or other.

I have found that since last October, landlords are legally obliged to fit smoke detection to every storey and CO detection in rooms with solid fuel burning appliances. This is under the smoke and carbon monoxide regulations 2015. This specifies no type or grade of alarm system.
All I can find from the likes of AICO and the council is guidance, best practice, and recommendation, but no actual legislation which requires a grade D LD3.

The potential landlord has already fully decorated the house including fitted carpets and battery smoke alarms in every room. She is loathe to suffer the cost and disruption of a mains interlink system if she can avoid it.

 

[Leesparkykent]

Battery Only - RadioLINK AlarmsAico - Fire & CO Detection & Fire Protection Specialist - http://www.aico.co.uk/Battery-Only-RadioLINK-Alarms.html

What about these? battery operated interlinked alarms.

 

[Andy78]

Those look good Lee, in the event of a compromise.
I'm really after current regulatory requirements for landlords with unlicensed HMOs regarding fire detection.
Is Tazz still about ?

 

[Andy78]

Bump !

This one has reared it's head again. The council are now referring to the housing act 2004 as the legislation requiring the action but are non committal as to which part of it. It sounds like a cut and paste request to me.

To recap, does the housing act 2004 legally oblige the landlord of a 2 floor shared house to fit a grade D LD3 interlinked system as asserted by the local council ?

 

[polo1]

Andy, I can't comment about the situation in England, but up here the Council Licensing officers I deal with are happy with LD2 in most HMOs. Battery interconnected is not acceptable, must be mains, interlinked with battery back up. CO (mains or battery) in every room with a gas or solid fuel appliance, don't have to be interlinked.
Our private rentals require similar now too.

 

[Wilko]

Looking at IET guide to fire detection ... BS5839-6 table 1 : existing HMO of 2 stories or less, with floor areas of 200m2 or less - shows as needing grade D category LD3 system. I'm just learning here, but I think the act will give them the right to specify the protection level and looks like they have opted for the recommendations in BS5839-6. Polo reports LD2 required in his patch, which is additional detectors in all rooms that have high fire risk (say kitchen and lounge). This is shown in table 1 against "new or substantially altered dwellings". Hope that helps.

 

[Andy78]

Thanks very much Wilko, makes a lot of sense if what you say about the housing act is right.

 

[NDG Elecs]

Sorry can't help you Andy! I have always found fire detection systems in HMOs a bit of a minefield. The council person probably does too, and may have over-specced to cover themselves (just in case!).

Tazz is definitely your man on this one. I reckon if you rang Aico or similar they would push you in the direction of a more costly system than may be needed.

Would the local fire safety officer have info perhaps... Also is the council in a possible position whereby they could refuse to grant a licence for the property. If yes, then I reckon the landlord will probably have to bite the bullet..

Edit: ignore parts of the above due to scan reading by me!

 

[Andy78]

Sorry can't help you Andy! I have always found fire detection systems in HMOs a bit of a minefield. The council person probably does too, and may have over-specced to cover themselves (just in case!).

Tazz is definitely your man on this one. I reckon if you rang Aico or similar they would push you in the direction of a more costly system than may be needed.

Would the local fire safety officer have info perhaps... Also is the council in a possible position whereby they could refuse to grant a licence for the property. If yes, then I reckon the landlord will probably have to bite the bullet..

Edit: ignore parts of the above due to scan reading by me!

The council is not in a position to grant or refuse a license as one is not needed for a HMO of this size. They are however threatening to prosecute if the action is not carried out, hence wanting to know if the system quoted is legally enforceable or just based on recommendation. When things get to prosecuting for not complying with orders, those orders need to be backed up to the letter with legislation in my opinion.

 

[tazz]

You need to verify if the property is a HMO with more than one family or just being rented out as a home to one family only. So the use of the property is the important key here. If HMO and over move than 2 floors then its a fully grade A alarm is required within the circulation areas and grade D smokes in occupied rooms. If only renting then a grade D will be accepted. Battery only smokes are not allowed here as the only meet Grade F. Interlinking co with smokes is against regs as the the cause of alarm needs to be identified, Aico and others do manufacture a control unit with silences all smokes and co`s apart from the one which has activated, and this is accepted as a form of identification. Hope this helps

 

[Wilko]

Hi - this is the link to the Govt guide booklet on :
The Smoke and Carbon Monoxide Alarm (England) Regulations 2015

https://www.gov.uk/government/uploa...lan_book_Annex_A_LandlordsTenants_REVISED.pdf

The guide stipulates CO alarm in rooms with solid fuel burning appliances. It recommends CO alarms for rooms with gas appliances. And the usual 2 smokes. It does not say the installation method or power supply, leaving that to us (i.e. follow relevant standards and manuf. recommendations) .

They do state there is an update to the Housing Act 2004 relevant to HMO, if I find this I'll attach it.

Another ref to Housing Act in the booklet was :
"Landlords should be aware that the regulations do not contain all the fire safety requirements which their premises may be subject to. There are fire safety requirements under other legislation which may be applicable, such as under Part 1 of the Housing Act 2004 and the Regulatory Reform (Fire Safety) Order 2005. "

 

[Andy78]

You need to verify if the property is a HMO with more than one family or just being rented out as a home to one family only. So the use of the property is the important key here. If HMO and over move than 2 floors then its a fully grade A alarm is required within the circulation areas and grade D smokes in occupied rooms. If only renting then a grade D will be accepted. Battery only smokes are not allowed here as the only meet Grade F. Interlinking co with smokes is against regs as the the cause of alarm needs to be identified, Aico and others do manufacture a control unit with silences all smokes and co`s apart from the one which has activated, and this is accepted as a form of identification. Hope this helps

I think it does come under the definition of a HMO, but not a large/licensed HMO. It is 2 floors only, student house with shared kitchen and bathroom, 3 unrelated occupants one of which is the owner/landlord.
This is not new build but an existing property already in use that has had a council visit and survey carried out.
So grade D LD3 required as laid out in BS5839.

Thanks very much for your help

 

[Andy78]

Hi - this is the link to the Govt guide booklet on :
The Smoke and Carbon Monoxide Alarm (England) Regulations 2015

https://www.gov.uk/government/uploa...lan_book_Annex_A_LandlordsTenants_REVISED.pdf

The guide stipulates CO alarm in rooms with solid fuel burning appliances. It recommends CO alarms for rooms with gas appliances. And the usual 2 smokes. It does not say the installation method or power supply, leaving that to us (i.e. follow relevant standards and manuf. recommendations) .

They do state there is an update to the Housing Act 2004 relevant to HMO, if I find this I'll attach it.

Another ref to Housing Act in the booklet was :
"Landlords should be aware that the regulations do not contain all the fire safety requirements which their premises may be subject to. There are fire safety requirements under other legislation which may be applicable, such as under Part 1 of the Housing Act 2004 and the Regulatory Reform (Fire Safety) Order 2005. "

Yep, I was aware of the smoke and carbon monoxide alarm regulations 2015. The council do not appear to be however as no stipulation for CO alarms has been made despite there being a log burner in the font room.

 

[Wilko]

Hi - adding a smoke for that room and heat for kitchen would be good and probably gets them to LD2 (and lines up with Lee's post #2 which looks like it's Aico doc?)