Simultaneous Evacuation Guidance: Frequently Asked Questions (FAQs)
We would urge those interested and with questions to fully read the new edition of the guidance and refer to the FAQs listed below. Whilst the Fire and Rescue Service is not responsible for the design, build, sign off, or maintenance of buildings, NFCC and our partners are committed to ensuring that the communities we serve are safe. This non-statutory guidance is intended to support consistent direction and understanding for those responsible for managing buildings that pose a significant and immediate risk to the safety of residents. It is only intended to apply to buildings that cannot support a stay put strategy.
It is important to note that it is the Responsible Person (RP) (such as the building owner, or someone with control over the premises) who makes the decision to change strategy, not the FRS or the NFCC. This is usually done with supporting advice from the RP’s Competent Person, in conjunction with a review of the fire risk assessment. To check if you are an RP under the FSO, the Home Office publishes guidance which can be found here:
Q. What is the Simultaneous Evacuation Guidance for and when should it be used?
A. If a building has been identified as high risk because of an unsuitable external wall system, or other fire safety defects, interim fire safety arrangements can be adopted for the temporary, short-term management and mitigation from the risk of a fire, and the risk to life if a fire occurs. These arrangements can range from simple steps to remove potential ignition sources that might give rise to a fire, through to a change in the evacuation strategy for a building, moving from Stay Put to Simultaneous Evacuation supported by the installation of a common fire alarm and/or a waking watch.
The aim of a waking watch is to ensure there is sufficient warning in the event of fire to support the evacuation strategy and has been utilised in buildings before the Grenfell Tower fire. It is intended for very short periods of time whilst the increased risk is being urgently addressed through either remediation or the installation of a more sustainable means such as a common fire alarm system.
It is important to note that the SEG is intended to be used, only after a decision has been taken to temporarily change the evacuation strategy. It is important that RPs and those advising them understand the decision making process which should be followed before making such a decision.
The document now clearly signposts people to other relevant guidance they should follow, before picking up this guide (such as Publicly Available Specification 9980:2022 Assessing the external wall fire risk in multi-occupied residential buildings (PAS 9980)).
Q. Why is it not the Fire Service’s job to make this decision?
A. Under previous legislation (The Fire Precautions Act 1971) it was the role of the FRS to determine the level of fire safety, and issue fire certificates for certain premises. In 2005, Parliament made the Regulatory Reform (Fire Safety) Order 2005 (“The FSO”). It came into force in 2006.
Regulatory reform agendas in broad terms, usually support the intention of reducing burdens and ‘red tape’ for businesses, underpinned by the notion of personal responsibility. The intent of The FSO by the Government, was to reduce the impact of fire safety regulation. The regulatory principles arise from Health and Safety law, that those who own the risk, should be responsible for managing their own risks.
The role of the FRS therefore shifted away from being prescriptive and issuing fire certificates, towards a risk based inspection approach. FRSs now sample a range of premises each year, and target these efforts towards buildings that are likely to pose higher risks. Correspondingly, models of resourcing in FRSs shifted to reflect the changes in roles and responsibilities under the law. Teams of fire safety inspecting officers are now primarily comprised of specialist personnel with specific training who form a proportion of FRS staff.
On average, around 3%-4% of known regulated premises are now inspected each year across English FRS to ensure that enforcement of the law is proportionate.
FRSs can inspect premises to make sure people are following the rules, and to check that levels of fire safety precautions building owners have in place are sufficient. Where there aren’t enough fire safety precautions in a building, FRSs are under a legal duty to enforce The FSO and can take enforcement actions.
However individual decisions about managing the safety of buildings remains the legal duty of the RP. This is why it is the RP’s role to decide when a change of evacuation strategy is necessary, supported by advice from a suitably competent person.
More information and data about FRS fire safety activities is available from the Home Office:
FRSs must have regard to the Regulators’ Code when exercising their duties as enforcing authorities under the FSO. The Regulators’ Code can be found here:
Q. Why was there a need for the guidance in the first place?
A. Following the tragic Grenfell Tower Fire, many more buildings with similar cladding were identified. The level of risk to life, as a result of a fire involving these external wall systems, could not be ignored.
An Independent Review of a case involving the Evacuation of the Chalcots Estate was undertaken in June 2018. The review found that the impacts of prohibition on residents and leaseholders can include:
- People having to leave their homes at short notice.
- People having to continue paying their mortgage or rent and other bills at the same time as paying for alternative accommodation.
- Shortages of alternative accommodation generally.
- Social disruption: alternative accommodation may place people in locations where they cannot get to work or school, or away from family support and childcare.
- Mental health impacts of removing people from their homes including trauma, disruption and loss of dignity.
To enable people to continue to live in relative safety in their own homes, interim solutions were needed to mitigate the risk.
Q. But surely the building work complied with relevant regulations at the time it was built/refurbished? Why are there now problems?
A. Following the tragic Grenfell Tower Fire, many more buildings with similar cladding were identified. The Government then commissioned an Independent Review of Building Regulations and Fire Safety, led by Dame Judith Hackitt.
This review identified a number of problems with the system for how buildings are built, and how building work gets signed off. That is why the Government has taken through the Building Safety Act 2022, to change the rules for how buildings will be built in the future.
Unfortunately, there remains a legacy issue of existing buildings where defects have been identified.
More information about actions the Government’s Building safety Programme is available on its website:
If you’d like to know more about the views of NFCC on building rules and regulations, you can find out more about these here:
Q. What is ‘Stay Put’?
A. Stay Put is an evacuation strategy and approach chosen as part of the design process, typically by designers, architects and others responsible for designing and constructing buildings. Such designs ought to ensure that aspects such as the walls, floors, and doors in a building adequately resist the spread of fire long enough that people are safe to stay in other parts of the building while the fire service put the fire out (unless they are affected by heat or smoke). Because the building ought to resist the spread of fire in this way, this protection is often used to justify other aspects of these designs such as having a single staircase.
The SEG is primarily designed to apply to buildings:
- that pose a significant and immediate risk to the safety of residents;
- that cannot support a stay put strategy; and
- where making an immediate change to the evacuation strategy, by implementing short term interim measures, is the only alternative to immediate prohibition of the building by the appropriate enforcing authority.
FRS do not have a role in designing buildings, or in signing-off on how buildings are built; the FRS can be consulted, unfortunately those receiving the comments are not required by law to comply or even respond to these comments. It is anticipated that once the new building safety regime commences, that the Government’s proposed Gateways system will operate in such a way as to address some of these issues for new and refurbished buildings in scope. How this will work is still the subject of further public consultation and development of secondary legislation under the Building Safety Act 2022, which is ongoing.
Once a building is built, FRS then have to respond to any fire incident according to the strategies which are set by those responsible for the building. The FRS has limited powers to get changes made to buildings after they are built.
NFCC supports the principles of a high level of compartmentation. However, we do not believe that the principles of a high level of compartmentation (which by default support stay put strategies) should be read as mutually exclusive, to measures which also support a Plan B, to support people to safely get out should they wish to.
NFCC has made recommendations to Government about how to strengthen both the regulatory environment for building and construction, as well as the underpinning design guidance (known as Approved Document B). Measures that would bring English building safety standards closer to other countries to support safe evacuation would include:
- multiple staircases, with new buildings having a minimum of two staircases;
- evacuation lifts;
- refuge areas with communications; and
- NFCC has urged Government to make it a requirement to retrofit sprinklers in all high-rise residential buildings over 18m, or 6 storeys, that are served by a single staircase.
If you’d like to know more about the views of the NFCC on building rules and regulations, you can find out more about these here:
Q. Why waking watches?
A. Waking watches are one of several interim measures that can be implemented to allow a building to remain occupied; however, it is often likely to be the only one that can be implemented immediately, and this then allows the time needed to install other measures, such as common fire alarms.
The SEG sets out a clear expectation for Responsible Persons to move quickly to install a common fire alarm and to remove or reduce dependence on waking watches as quickly as possible.
Although waking watch had been used in buildings before Grenfell Tower, it became clear following the Grenfell Tower fire that no central guidance existed on how to consistently implement these arrangements. This needed to be rectified urgently given the emerging scale of the problem and the need to support Responsible Persons (RPs) to implement measures effectively and consistently.
In response to this need, NFCC convened a group of industry professionals to produce a technical guide on arrangements to support a temporary change to the evacuation strategy. In the absence of a common fire alarm, the premise was to ensure that all residents can be alerted by the waking watch. In producing the guide, the group sought to ensure the safety of residents, and prevent removing people from their homes, whilst highlighting that the principal way to reduce risk was to urgently remediate the non-compliant external wall systems.
The SEG was intended to make technical and professional advice freely available, providing a tool for use to scrutinise local decision making, and benchmark implementation. Bringing together sector industry experts from a range of key organisations, aimed to minimise the risk that the public would receive contradictory or confusing advice from different bodies.
Q. Who are the ‘experts’ and ‘industry professionals’ involved in writing this guidance?
A. NFCC formed a steering group working with the following industry partners to produce edition four of the guidance:
- Fire Protection Association
- Fire Industry Association
- Institution of Fire Engineers
- National Social Housing Fire Strategy Group
- The Property Institute (TPI) – incorporating the Association of Residential Managing Agents (ARMA) and the Institute of Residential Property Management
- Metropolitan Thames Valley Housing
- Fire Sector Federation
Other groups who have provided significant comments or contributions on the successive editions of the SEG, are also thanked within the foreword. Comments and submissions from different groups in response to the most recent consultation draft have been published, along with responses from the steering group noting how each comment has been addressed.
Q. Why are we now on the fourth edition of this guidance?
A. Guidance needs to be continually reviewed to ensure it is fit for purpose. The new edition of the Guidance is the product of a review commissioned by the Government following the written statement by Rt Hon Robert Jenrick MP, then Secretary of State for Housing, Communities and Local Government, on proportionality in building safety. The review follows the withdrawal of the Government’s Consolidated Advice Note, and the publication of Publicly Available Specification 9980:2022 Assessing the external wall fire risk in multi-occupied residential buildings (PAS 9980).
This edition also provided the opportunity to address the feedback, concerns, and questions raised by stakeholders, including leaseholders, since the last edition was published. Such changes can be seen in both the layout and content of this edition.
Having liaised with leaseholders we recognise that temporary measures – that were only ever expected to be in place for a short period of time – have remained in place and have been very expensive for leaseholders. Therefore, remediation was clearly required.
NFCC and our partners are deeply conscious of the impact on residents and leaseholders that the delays in remediating buildings and the consequent extended use of interim measures have. The same residents and leaseholders who are being protected from the risk of rapid-fire spread, are instead experiencing other significant consequences through no fault of their own. These include the ongoing high costs of waking watches and insurance products, an inability to sell or re-mortgage their properties, financial stress and unacceptable impacts on mental health and wellbeing.
Q. What are the key changes to this edition?
A. The updated guidance:
- Addresses concerns raised about RPs and Fire Risk Assessors failing to act proportionately and take the right steps before they change their evacuation strategy, by clearly signposting readers to the newly published PAS 9980.
- Reinforces the clear expectation that RPs will seek to reduce or remove the dependence on waking watches as soon as possible, by providing more detail within the timeline on what actions enforcing authorities expect RPs to take, and by when.
- Discourages the risk adverse behaviour of having onsite staff where they may not be needed.
- Clearly signposts readers to a wider range of supporting information, including Article 50 guidance they may need to consider in respect of persons who might find themselves in vulnerable positions.
- Includes a published Equalities Impact Assessment.
- Responds to the learnings from the New Providence Wharf Fire by incorporating a previously separate addendum into the main guide.
- Includes updates to relevant sections following the commencement of the Fire Safety Act 2021 and introduction of the Fire Safety (England) Regulations 2022.
- Includes significant revisions to evacuation management content to:
- improve distinction between where evacuation management is used to describe a job/role, and where it is used to describe a general set of duties or activities.
- highlight that (like the decision to change evacuation strategy) a decision to have onsite staff to manage an evacuation should be informed by advice from a competent person in conjunction with a holistic review of the Fire Risk Assessment.
- clarify that (like members of a waking watch team) any persons with appropriate training can perform evacuation management duties where they are recommended by the Fire Risk Assessment/Competent Person.
Q. What does this Guidance mean for me?
A. The purpose of this non-statutory guidance is to support building owners, Responsible Persons, associated fire safety specialists, Fire and Rescue Services, and other appropriate enforcing authorities to assist with a consistent, standardised approach. The SEG does not constitute legal advice. All parties’ legal duties remain those specified by law, in particular the Regulatory Reform (Fire Safety) Order 2005, the Housing Act 2004, and the Building Regulations 2010.
Responsible Persons for affected buildings should review their fire risk assessment to ensure the fire safety arrangements including the interim measures in place are appropriate, informed by the advice of a competent person.
Q. What about buildings where remediation can’t happen in the short term – how are the leaseholders meant to afford the ongoing costs of interim solutions such as waking watches?
A. We have ensured the new edition reinforces the clear expectation that RPs will seek to reduce or remove the dependence on waking watches as soon as possible, by providing more detail within the timeline on what actions enforcing authorities expect RPs to take, and by when.
We have emphasised the firm and long held expectation of NFCC and our partners that building owners should move to install common fire alarms as quickly as possible to reduce or remove the dependence on waking watches. This is the clear expectation for buildings where remediation cannot be undertaken in the ‘short term’. This approach should, in almost all circumstances, reduce the financial burden on residents where they are funding the waking watches.
In January 2022, the Secretary of State for Levelling Up, Housing and Communities announced a new approach to protect leaseholders from paying for the expensive remediation of unsafe cladding on buildings above 11 metres, and that developers and cladding companies would instead be required to fund the work. The Government also made a commitment of £27 million to fund fire alarm installation in buildings with a waking watch in place.
Q. If a waking watch is implemented for my building, how do I ensure they are fully competent to carry out this important role?
A. It is the duty of the RP for the building to ensure that the waking watch are competent to carry out the role. The Guidance includes appendices to advise Responsible Persons of the management considerations to take into account when deciding to introduce a waking watch. It also outlines the person specifications to be considered for roles as part of the waking watch and evacuation management.
The role of the waking watch is specific to the individual building, and therefore the training needs to be building specific.
Companies providing waking watch services have their own duties as employers for the safety of their staff working in these buildings and to ensure they are competent and fully trained to carry out the role.