Fire planning for care homes and specialised housing

A care home fire statement at planning stage is not the same problem as a fire statement for a block of flats, because the evacuation strategy is different in kind. Residents of a Class C2 care home cannot be expected to leave the building unaided, so the strategy is progressive horizontal evacuation: move people sideways into an adjoining fire compartment on the same floor, and only down the building if that compartment is also threatened. That decision shapes the floor plan, which is why the fire engineer has to be appointed before the plan form is fixed rather than after permission is granted.

Use class first, because everything follows from it

A residential care home with registered nursing or personal care is a Class C2 residential institution. Extra care and assisted living schemes are harder, and the classification turns on the level of care actually provided, the degree of self containment of the units, and whether residents have their own front doors and tenancies.

The distinction is not academic. Class C3 brings in affordable housing policy, the nationally described space standard, residential parking standards and a different fire regime. Class C2 brings a care needs assessment, a different parking and servicing profile, and in most authorities no affordable housing requirement or a bespoke one.

Decide it early, evidence it in the application, and expect the authority to test it. A scheme described as C2 with self contained flats, no care provision on site at night and assured tenancies will be treated as C3 by any competent officer.

Whether a care home is a relevant building

Here the two regimes do not line up, and developers get caught in the gap.

The planning fire statement requirement is framed around buildings containing two or more dwellings or educational accommodation, at a height of at least 18 m or seven or more storeys. A care home's bedrooms are not dwellings, so a tall care home may fall outside that specific planning requirement.

The building control side is wider. The higher-risk building definitions that drive the design and construction gateways under the Building Safety Act 2022 framework capture buildings at the same height threshold that are care homes or hospitals, as well as those containing residential units, although the occupation phase duties are framed differently.

Two further points close the gap in practice. In Greater London, London Plan Policy D12 requires fire safety to be addressed in all development proposals and a fire statement for major development whatever the height. And fire safety is a material consideration regardless of any statutory trigger, so an authority can and will ask for the evidence.

So the practical answer is to confirm the position with the authority at pre-application stage and to prepare the document either way. A Fire Statement has to be prepared by someone with the necessary fire engineering competence, because it sits within the Building Safety Act framework and Article 9A of the Development Management Procedure Order 2015, and an AI-assisted draft is a starting point for that professional rather than a substitute for them.

Progressive horizontal evacuation and what it needs in plan

The strategy requires that every floor can be divided into compartments, and that each compartment can temporarily accommodate the occupants of the one next to it.

That produces a set of plan requirements which are hard to retrofit.

• At least two, and usually more, sub-compartments per floor, with compartment walls running to the underside of the floor above and through any ceiling void
• Cross corridor fire doors at each compartment line, wide enough for a bed or an evacuation chair, with hold open devices on a fire alarm interface
• A refuge or holding area within each compartment with enough circulation space for the transferred residents
• Corridor widths that allow two people to pass a wheeled bed
• Protected stairs sized and positioned so that a vertical evacuation remains possible as a fallback
• An evacuation lift where the building has more than a couple of storeys, with its own protected lobby and power supply
• Sprinkler protection to the relevant residential standard, which brings a tank, a pump room and a maintenance regime

The consequence for the design is that bedroom clusters have to be sized to the sub-compartment capacity, and the core has to sit where the compartment lines want it. A plan drawn for daylight and aspect and then divided afterwards usually loses bedrooms. Our note on care home layouts and progressive horizontal evacuation works through the layout consequences in more detail.

Compartment sizes and travel distances

Sleeping risk tightens everything. Travel distances for buildings with sleeping accommodation are shorter than for offices, and the limit where escape is possible in one direction only is the figure that constrains dead end corridors in a care home plan.

The governing documents are Approved Document B and, where a fire engineered approach is taken, the relevant British Standard for residential and non residential fire safety design. Compartment floor and wall resistance, cavity barriers in ceiling voids, and the fire resistance of bedroom doors all follow from the chosen approach.

Do not take the numbers from a previous scheme. Approved Document B has been amended repeatedly and the figures for sprinkler provision, compartmentation and escape have changed with it, so check the current edition.

Where the project involves converting an existing building rather than new build, the structural and fire surveys run together because both need the same opening up, and our note on structural appraisal of a building proposed for retention sets out what that involves.

Staff assumptions and the management dependency

This is the honest weakness in every care home fire strategy, and it is better to name it than to hide it.

Progressive horizontal evacuation depends on staff being present and able to move residents. The strategy therefore assumes a staffing level, usually a minimum number of staff on duty at night with stated training. Planning cannot reliably secure that. A condition requiring the operator to run the home in accordance with an approved fire management plan is sometimes imposed, and its enforceability is limited, because staffing is regulated by the care regulator rather than by the planning authority.

What the design can do is reduce the dependency. More sub-compartments mean fewer residents to move per incident. Sprinklers reduce the likelihood of a fire developing to the point where a transfer is needed. Wider doors and level thresholds make a transfer faster with fewer staff. Those are capital decisions taken at planning stage, and they are the ones a reviewer should press on.

State the assumed staffing in the fire statement explicitly. A strategy with an unstated staffing assumption cannot be reviewed.

Appliance access and water supply on a campus layout

Care schemes are often single storey or low rise wings around courtyards, on a site with landscaped parking and a one way loop. That layout fights the access requirements.

Approved Document B requires fire service vehicle access to within a stated distance of all points within the building footprint for buildings without a fire main, and sets maximum spacings for hydrants relative to building entry points. Check the current figures rather than relying on a remembered one, because they have changed between editions. On a campus plan the usual failures are a courtyard with no vehicle access, an access route with a turning head too small for a pump appliance, and a landscaped swale that renders a route unusable in winter.

Resolve this before the site layout is submitted. A fire service access drawing, with tracking for the relevant appliance and hydrant positions marked, costs very little and prevents a redesign at reserved matters stage.

What the fire statement has to commit to

The document is a commitment, not a description of intent, and it should state the evacuation strategy and the compartmentation principle that supports it, the means of escape with travel distances, the fire service access and water supply arrangements, the external wall construction and the fire performance of the products proposed, the suppression and detection systems, and the management arrangements the strategy relies on.

Where a fire engineered solution departs from the guidance documents, that departure needs setting out with its justification. A Fire Safety Strategy to the relevant British Standard is a fire engineering document and the law treats it as such, so a competent fire engineer must author it and professional review before submission is not optional.

Conditions and a later change of operator

Two things change after permission, and both can undermine the strategy.

The operator changes. A new operator with a different care model may run the building with a different staffing pattern, and nothing in the planning permission prevents that unless a condition ties operation to an approved management plan.

The care model changes. A nursing home converted in practice to an assisted living model, with residents holding tenancies and care provided on a visiting basis, may amount to a material change of use from C2 to C3, which brings the affordable housing, space standard and fire requirements of a residential scheme into play. That is a planning breach as well as a fire risk, and it is one that surfaces during a sale or a refinancing.

Ask for the condition to be drafted around outcomes that can be checked, such as the retention of compartmentation and the maintenance of suppression systems, rather than around a staffing number that the authority has no mechanism to monitor.

If you are scoping the evidence base for a care scheme and want to see which supporting documents the site is likely to need, enter the postcode on PlanScope and work through the constraints first.

This is general guidance, not legal advice, so check the position with your local planning authority or a qualified professional before relying on it. For specialist technical reports, qualified professional input may be required. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.