Fire safety for HMOs at the planning stage

Planning does not regulate fire safety, and HMO fire safety planning still decides the floor plan. The escape route fixes where the stairs go, which rooms can be let, how wide the hall has to be and whether the loft room works at all. Draw the layout for the letting schedule first and you will redraw it twice, once for building control and once for the licensing officer.

The three regimes that matter are the Building Regulations, the Housing Act 2004 and the licence conditions your council attaches. Planning sits alongside them, controlling the use rather than the construction.

Where fire safety enters an HMO planning application

The planning question is the use. A house occupied by three to six unrelated sharers falls in Class C4, and the change from a family dwelling in Class C3 to C4 is permitted development under the General Permitted Development Order unless an Article 4 direction has removed it. Seven or more sharers is a large HMO, which is sui generis and always needs permission.

Fire safety enters indirectly. The floor plans submitted with the application show room sizes, door positions, stair enclosures and window openings, and those drawings become the approved plans. If the escape strategy later needs a lobby where you drew an open hall, you are applying to amend a permission you have already used.

Officers also read the plans for amenity. Room sizes below the licensing minimum, a kitchen that cannot serve the number of occupants proposed, or no usable outdoor space all attract refusal reasons in authorities with an HMO policy. Put the schedule of accommodation on the drawing.

Escape route layout and its effect on the floor plan

Most shared houses rely on a protected escape route: a stairway and hall enclosed in fire resisting construction, with fire doors to every room opening onto it, leading to a final exit.

That single requirement produces most of the layout consequences.

• Every bedroom needs a door onto the protected route, so a bedroom reached through a living room, kitchen or another bedroom does not work
• Open plan arrangements where the stair rises out of a living space have to be closed in, or an alternative strategy has to be engineered
• Understairs cupboards become fire resisting enclosures or disappear
• Glazing within the enclosure has to be fire rated, which changes the look of an internal screen
• The final exit door must be openable without a key from the inside

Conversions of terraced houses run into this at the ground floor front room, which is often the room the owner wants to let and which frequently has the only door to the street.

Where the strategy cannot follow the standard guidance, you need a fire engineered approach, and that means a Fire Safety Strategy written by someone with fire engineering competence. This is not a document to draft and submit unreviewed. PlanScope can produce the draft structure and the policy framing, and a qualified fire engineer has to own the content.

Compartmentation and door specifications

Fire doors to the escape route are generally 30 minute doors with intumescent strips and cold smoke seals, fitted with self-closing devices. Floors between storeys provide fire resistance, which usually means upgrading a Victorian lath and plaster ceiling rather than leaving it.

Kitchens get particular attention because that is where fires start. A kitchen opening directly onto the only escape stair is the arrangement that most often forces a redesign, and the answers are a lobby, a relocated kitchen or a suppression system.

Cellars are the other recurring problem. A basement below a protected stair puts smoke into the escape route, so the cellar door needs the same treatment as everything else, and a basement bedroom usually needs its own escape.

Alarm systems and detection grades

Detection in shared housing is specified by system grade and coverage category under the British Standard for fire detection in domestic premises. The grade rises with the size and layout of the house, from battery-backed mains units in a small two storey conversion up to a panel-based system with a control unit in larger properties.

What matters at the planning stage is the space the equipment needs. A control panel by the front door, sounders in every room and interlinked heat detection in kitchens are all things to place on the drawing rather than discover later.

Landlords converting several houses to the same template often specify a single system grade across the portfolio. That is fine as a purchasing decision and it does not remove the need to check each house against its own layout.

Emergency lighting comes with it in larger properties, and it needs a position on the drawing too. So does the fire blanket and extinguisher provision that most licence conditions require in shared kitchens.

One practical warning. Detection in a bedsit-style HMO where each room has cooking facilities is specified differently from a shared house with a single communal kitchen, because the fire load sits inside the rooms rather than in one place. Landlords who convert a shared house into self-contained studios part way through a project often discover this after the first fix.

How licensing and building control overlap with planning

Three separate consents, three separate sets of paperwork.

Building control deals with the construction and is engaged by a building notice or full plans application. HMO licensing under the Housing Act 2004 is mandatory where the property is occupied by five or more people forming two or more households, and many councils operate additional licensing schemes that catch smaller properties. Licence conditions commonly cover fire precautions, alarm testing, room sizes and the maximum number of occupants.

National minimum room sizes for licensed HMOs are set in regulations, with a floor area for one adult, a larger figure for two adults sharing and a smaller figure for a child under ten. Check the current figures before drawing anything, because a room a few hundred millimetres short cannot be let however good the escape route is.

The common parts of an HMO also fall under the Regulatory Reform (Fire Safety) Order 2005, which requires a fire risk assessment by the responsible person.

Basement and top floor rooms in shared houses

Adding a third storey changes the rules. A protected stairway running the full height of the house becomes the baseline, and where the layout cannot deliver it, the alternatives are a sprinkler or misting system, an alternative escape route, or dropping the room.

The sprinkler route has planning consequences of its own, from tank and pump space to external water connections, which the note on sprinklers and the planning consequences of the choice works through.

Escape windows in loft rooms have minimum dimensions and a maximum cill height, and they have to open onto somewhere a person can wait to be rescued. That drives rooflight size and position, which in turn interacts with whatever the roof plan can carry. Design the rooflight to the escape dimension first and check the planning appearance second, because the reverse order produces a rooflight that looks right and does not comply.

Designing the layout once rather than three times

Work in this order. Establish the use class position and whether an Article 4 direction applies. Sketch the escape strategy against Approved Document B. Check every proposed bedroom against the licensing floor areas. Only then produce the planning drawings.

Doing it this way costs a few days at the start. Doing it the other way costs an amended application, a second set of drawings and, on the schemes that go badly, a bedroom that cannot be let.

Where a scheme is large enough to be a relevant building under the fire statement rules, a Fire Statement is required at Planning Gateway One under Article 9A of the Development Management Procedure Order. Converted houses do not reach that threshold. If you are deciding which fire document your scheme needs, the comparison of BS 9991 and BS 9999 strategies sets out where each applies.

This is general guidance, not legal advice. 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.