Residential PEEPs: how will they work and are landlords ready?

So what do housing providers need to do? The first step is to identify “relevant residents”. This means someone who lives in a building within the scope of the regulations and “would have difficulty evacuating without assistance in the event of a fire”.

The rules require housing providers to use “reasonable endeavours” to identify such residents. This has to include when a new tenancy is granted, and periodic reminders every year – but how exactly to do it is left in the hands of the housing provider. 

The sector’s approach has been mixed. Inside Housing has heard of one large council landlord that has sent out 10,000 letters four times and received just 60 responses.

“Tenants get so many letters from their housing provider, they do eventually get filed in that useful filing system known as the bin,” one source says.

Others are taking a different approach. Inside Housing knows of one provider, which does not want to be identified, that is using automated phone calls to approach residents. If they need assistance to evacuate in the case of a fire, they can press a button on their keypad to sign up. This has had a much more thorough response rate.

“We offered a £10 Amazon voucher to everyone who responded to our demographic survey,” says Chloe Gallagher, lead building safety manager at 9,000-home Magna Housing.

“I think we had a 95% response rate. That was our highest response rate, and it just came from changing the narrative and saying, ‘We’re going to give you something, if you give us this information.’ We’ve also sent texts, and hosted pizza nights. You need different ways of engaging for this legislation; I don’t think a simple letter will be the best approach.”

“My dad lived in a tower block and if someone had knocked on his door and told him he was vulnerable, they would have been given very short shrift”

At several providers, including Gentoo, a 30,000-home landlord in Sunderland, staff who enter residents’ flats are given instructions on looking out for vulnerability and can update the organisation via an app on their device. The building safety team will then follow up to discuss.

Magna has taken the same approach. “They [colleagues who enter people’s homes] are our eyes and ears. They’re inside people’s homes, probably more than any of us. So we have been upskilling them in what they need to look out for,” Ms Gallagher says.

Both Gentoo and Magna were in a strong position to prepare for this new set of regulations, having begun collecting data on resident vulnerability several years ago.

“At Magna, not to blow our own trumpet, we were doing this anyway before [the regulations] came in. We didn’t wait for this legislation,” Ms Gallagher says. “Based on some of the things I’ve heard on webinars, I am worried that there are other organisations out there that are not ready.”

Groups representing disabled residents have expressed concern about the way this part of the regulations is drafted. They point out that the language “reasonable endeavours” is a lower standard than many other matters of fire safety compliance (which are framed as “best endeavours”), which may leave some building owners free to undertake limited steps to contact potentially affected residents. 

An important part of this legislation is that it is consent-based. If a resident refuses the offer of an assessment, the landlord must respect that.

“It’s quite clear in the legislation that it is still down to the customers to make that decision on whether they want to do this or not,” says Gemma Darville, director of safety, risk and assurance at Gentoo. This makes messaging a challenge. 

“I think that messaging is really important to customers, to say, you know, we’re here to help,” Ms Darville says.

Another expert adds that some customers may be put off by language like ‘vulnerable’. Inside Housing has used the term ‘vulnerable’ in this story, as it is used in the Grenfell Inquiry and the PEEPs regulations.

“My dad lived in a tower block and if someone had knocked on his door and told him he was vulnerable, they would have been given very short shrift,” says the expert, who works at a senior level for an enforcing authority and did not want to be named.

This is far from the only criticism of the word vulnerable: housing association Eastlight Community Homes removed it from all policy documents in 2024.

Once relevant residents have been identified, the regulations require the landlord to offer a ‘person-centred fire risk assessment’ (PCFRA). This is not evacuation support, but instead targeted interventions in the home that reduce fire risk or provide early or adapted warnings.

“We’ve spent quite a significant amount on upgrading fire alarm systems to be able to have vibrating pillow pads and flashing strobes [for residents with hearing impairments],” Ms Darville says.

Ms Gallagher says that Magna has put in place misting systems (heat-activated water systems, which are plugged into a flat’s water supply), fire-retardant bedding, outside charging for mobility scooters and other interventions to reduce risks. It has also opened conversations about moving – although this is constrained by the availability of ground-level housing, and not always something the resident wants.

In this area, though, the regulations get thorny. Because they are regulations passed by a minister, under the authority given to do so in the Fire Safety Order they apply – like their parent law – to the common parts of the building only (although the government does say it intends to extend them). This is a problem because PCFRAs inevitably require adaptations inside the flat.

“I have no idea how you’re supposed to do a person-centred fire risk assessment on a resident in the common areas,” says Elspeth Grant, chief executive of Triple A Solutions, a company that specialises in PEEPs and PCFRAs. “The legislation simply doesn’t make sense.”

The implication of the regulations appears to be that housing providers are expected to act in the spirit of the law (carrying out person-centred assessments inside flats), even though this is not what the letter of it says. But this could become tricky to enforce and maintain if there are legal challenges. 

Then there is the question of how the measures identified via a PCFRA will be paid for. The rules say “reasonable and proportionate” measures must be implemented, but the housing provider can ask the resident to pay after applying a further “reasonable and proportionate” test considering whether it is fair to do so. 

This may result in an odd situation where housing providers identify hazards through a PCFRA and then don’t address them, because the resident says they won’t pay.

“There are some people for whom you cannot facilitate an evacuation statement. Someone with dementia, for example – you can go through the plan today, but they will not remember it tomorrow”

“If a disabled person says, ‘You must be joking, I’m on benefits, I can’t pay for that’, then the regulations actually state that the housing provider can walk away,” Ms Grant says.

She says this could cause serious difficulties in the event of a coroner’s inquest, and under the new Awaab’s Law provisions, which require specific hazards to be addressed within a set time period.

Both Ms Gallagher and Ms Darville say they have not passed on to residents any costs of the PCFRA measures they have carried out.

“I’m lucky enough that I’ve had a senior leadership team that has absolutely supported me wholeheartedly,” says Ms Gallagher. “We at Magna have not asked the customers to pay for anything. We will do it because we think it is the right thing to do.”

Social housing providers have received grants from central government to implement the regulations, based on central assessments of how much it would cost. These grants are geared towards capital works rather than revenue spend (so it would be hard to hire staff, for example), but those in the sector say they have welcomed cash injections, which have helped to cover the costs without billing residents in many cases.

Information about the resident and their vulnerability must then be stored in a secure information box outside the building, which firefighters can access in an emergency, to then deploy crews to effect a rescue. Some fire authorities are accepting this information digitally, but many are not, in part due to concerns about data sensitivity and the need to remove the information as soon as residents withdraw consent.

Housing providers must also provide an ‘emergency evacuation statement’ explaining how the resident would leave the building in an emergency. Here, again, the regulations are controversial.

For many vulnerabilities, there are ways to make it easier to get out of the building. Not everyone who is considered ‘vulnerable’ has a mobility issue. Earlier alerts, low-pressure door handles, emergency lighting and double bannisters may help many who would otherwise be trapped. But there are inevitably some residents who would be entirely unable to use the stairs.

“There are some people for whom you cannot facilitate an evacuation statement,” says Ms Gallagher. “Someone with dementia, for example – you can go through the plan today, but they will not remember it tomorrow. For others who have mobility issues, I can get them out of their front door, so behind a fire door, sometimes into a protected stairwell or protected lobby, and then they do have to await rescue.”

Ms Darville says: “We will work with customers to understand what they need and the best way to do this, which could include moving house. And is that something that we can look at doing? But given the availability of social homes, it’s not a blanket thing that we can offer everyone. But we absolutely work with each customer to look at how they could get out of the flat, at least to that relative place of safety.”

For some, this means the regulations do not go far enough, because they are not providing actual means of escape. Instead, they focus on adaptations under PCFRAs and then rescue by firefighters. 

“This appears to be a significantly watered-down version of the original PEEP recommendation made by the Grenfell Tower Inquiry,” says Adam Gabsi, co-chair of disability charity Inclusion London.

“For many disabled people, particularly those living in high-rise buildings, this does not feel like a meaningful implementation of the inquiry’s recommendation. Instead, it feels like a policy compromise that weakens the core principle that everyone should be able to escape safely from their home.”

Ms Grant says more should be done to explore ‘buddy’ arrangements, which are used for workplace PEEPs. Here, a buddy is identified who can assist with evacuation, whether through a guiding arm or shoulder, or use of an evacuation chair.

“Triple A have done thousands of PEEPs, and it is much more feasible than people think to identify buddies,” she says. “It is only a tiny fraction of residents who are so completely isolated that they have no one. We know from the inquiry that, tragically, many family members died because they wouldn’t leave their disabled relatives. But there is a huge resistance to even exploring this from too many landlords.”

“For many disabled people, particularly those living in high-rise buildings, this does not feel like a meaningful implementation of the inquiry’s recommendation”

Housing providers, however, worry about the pressure they would be placing on volunteers if they made use of buddies – particularly outside the immediate household.

“With the best will in the world, I don’t feel that we can rely on that,” says Ms Darville. “It’s a reliance on goodwill, and it could be very challenging in an actual emergency.”

While the Grenfell Tower Inquiry did recommend PEEPs in its first phase, its second-phase report struck a note of caution on this point. It held back from criticising KCTMO from not having PEEPs in place, saying it was “difficult to see what additional measures the TMO could have taken to assist the evacuation of disabled residents once they had entered the common parts of Grenfell Tower”.

However, it did push for information to be shared with emergency services. It added that the failure to collect this information represented “a basic neglect of its obligations in relation to fire safety”.

One area that may help with this is lifts. If lifts were upgraded to evacuation standard, then even those who use wheelchairs may be able to exit a building independently.

“This conversation should be much more about what we can do about lifts,” says Dr Michael Kinsey, an associate director at consultancy Ashton Fire.

“PEEPs should not rely on fire service rescue, and most general needs buildings are not staffed – and that means we need to think about lifts. We need to talk about how we can convert lifts to an evacuation standard, and what is good enough in certain circumstances. Can you get lifts into a position where they could be used in the early stages, if the fire was nowhere near them?”

Changes like this would require careful thought, as well as new British Standards – although the relevant one is currently under review. 

Enforcement of these standards will sit with fire services, which currently enforce other elements of the Fire Safety Order.

This means enforcement styles will differ across the country. It is understood that the London Fire Brigade will take a tougher line in enforcement on buildings with simultaneous evacuation strategies in place, because this implies a known fire risk, and a greater threat to the resident. 

Get to know who is behind the front door

There is also the question as to whether these regulations should be wider. Risks are heightened in blocks of flats, because of the delay to the start of firefighting operations, and the much more limited options for escape. But the vast majority of fire deaths (nearly 200 a year) happen in houses and bungalows, because this is where more of the population live.

Data on these deaths shows they are much more prevalent in men over 80 (14 deaths per million people, compared to three for younger age groups). Particular risks such as smoking, mobility problems and medical conditions requiring regular use of emollient cream heighten the risk further. While no housing provider could intervene in every single house, awareness of demographic data like this could mean targeted intervention outside of high rises. 

“At Magna we will offer a person-centred fire risk assessment to anyone, regardless of height of building, evacuation strategy, tenure,” Ms Gallagher says. “Compliance isn’t just a tick box. It’s about doing the right thing.” 

These new regulations create challenges, and much rests on how individual providers interpret terms like “reasonable endeavours” and “proportionate costs”. But the legislation, like consumer standards in regulation and Awaab’s Law in disrepair, is subtly changing the sector. It needs to become much better at knowing who its customers are and the risks that exist behind their front doors. There may be benefits from this that go beyond fire safety. 

“It’s no longer good enough to not know who’s behind the front door and what support they need,” says Gentoo’s Ms Darville. “A fire is an unlikely but extreme event – but actually, there are loads of day-to-day things that we need to be aware of to make sure that we are providing safe, decent homes for customers based on their needs. This can help with that.”