AnthonyB

As it's considered commercial sleeping risk rather than a flat on a AST the expectation would be for Grade D1 (mains with tamperproof battery) system that are interconnected. It's a long time since you needed to link via bell wire and now almost universally radio link units are used. You can find D1 Radio link alarms here https://www.safelincs.co.uk/smoke-alarms/

This is the link to the appropriate Government fire safety guidance for your usage of the flat: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/11085/payingguests.pdf The rest of the building (common parts) is the responsibility of the freeholder or lease holder's 'right to manage' company with regard to risk assessment and fire safety provisions.

Looks electro-mechanical and not usually allowed on exits, absolutely not if not failsafe. Depending on the type of override if it was fail safe there are maintenance/testing obligations

Risk assessment guidance suggests in the smallest premises (which being a couple of ground floor rooms this would fall into) that sometimes torches are sufficient. Power failure is not exclusive to fire and you have to consider also the impact of a sudden loss of power on any procedures in progress. Even if it is determined that 'proper' emergency lighting is required you may find that a simple LED bulkhead (e.g. https://www.safelincs.co.uk/eden-led-emergency-bulkhead-light/) in each room and the entrance foyer (3 of in total based on your layout) may suffice, wired off the normal lighting circuit if installed as non maintained (lit only on power loss or, if it has to be on it's own circuit (usually due to a lack of a readily available permanent live in the ceiling cables to each light from the switch) installed as maintained (always lit)

I think if you are concerned you should contact the Fire Safety department of your local Fire and Rescue service. A strict interpretation of the law is that significant findings of the FRA should be shared with other Responsible Persons in the premises, not all relevant persons. If the freehold is owned by the flat owners through right to manage then an owner who is on the Tenant Management Company board is a Responsible Person so can access the FRA, but if the freehold is privately owned then it's not a given.

No, you aren't competent by your own admission. You may be able to test them, but unless an electrician conversant with commercial premises (not just Part P) and the regulations regarding EL and how they should be cabled and wired then you should not be repairing/replacing/adding.

Read where?

Seems a bit over zealous as it isn't actually the house, just a lobby with a shower off, an area infrequently occupied and not sleeping risk. Ask them to reference the relevant paragraph of Approved Document B they are using to determine this requirement.

Of course. Stairwells have heads and foots and the lobby/foyer at the foot of the stair leading to the final exit would be considered part of the protected route. If the travel distances from the furthest point of the storage area to the front door are long enough to require the stair to be protected then the lobby would need to be clear (assuming there isn't a second stair from the storage area)

Building Regulations (England & Wales). Relates to compiling and handing over fire safety information relating to the build, being given more teeth in the Building Safety Bill.

That is a matter of personal interpretation, you will hear different opinions of both A & D, plus if the premises are a conversion that comes under selective licensing the council will have their view as well. I've seen Grade A more often than not in this situation. Another factor that could influence matters is the separation between the shop & flats - if inadequate thus requiring linked systems you are looking definitely more like a Grade A system.

Any current type of simple fastening not requiring a key would suit, BS EN 1125 panic fastenings would only be needed if over 60 persons would be using the route or would be unfamiliar with it - BS EN 179 exit devices may suffice.

The normal expectation is an assembly point to keep staff safely together, allow further checking that people are out, etc. Depending on the geography of the site and number of persons involved there may be multiple assembly points for different floors, etc but it's expected there should be defined locations not just people randomly wandering off in all directions.

What floor the flat is on? Sounds like an individual flat assessment template than a building wide FRA.

If you mean not testing the smoke control yourself it's because you are unlikely to have the equipment and competency to ensure it is subject to a suitable system of maintenance and be maintained in an efficient state, in efficient working order and in good repair based on the required maintenance regime in British Standards (which the Enforcers’ Guidance published by the National Fire Chiefs Council advises enforcement officers to use as a benchmark). With the Emergency Lighting you will be able to follow the BS and demonstrate competency as well as having the right equipment for the job.

If the occupiers of other flats have to pass your front door to get to the escape stair it has to be a fire door, always has been a requirement. If you are the last flat on the row, not as big an issue.

If it still complies with current regulations you are not making it detrimental, merely different. Shouldn't be an issue.

Are these in windows on an external wall? It's more of an issue with internal smoke shafts, where incorrect C&E on the system has led to rapid spread of smoke through all floors.

They do exist as a legacy measure in older buildings though, the usual guidance is a maximum of 5 staff only to resort to such. You can't use them in anything new of course.

If only, for the majority of buildings the Reg 38 info is long gone or the building pre dated the requirement. If the building's Golden Thread is intact and the info is available it is, of course an easy way to verify the items.

And you should have a Fire Risk Assessment in any case and a significant change, such as altering the standard of fire protection, requires a review. Building Regulations and Fire Regulations are totally separate entities.

You should avoid letting tenant's reset the system, however unless there is a rapid key holder response to reset it there is a risk they could damage the system trying to silence it. You can't stop them ignoring an alarm - they do retain responsibility for their actions (Or lack of) They should evacuate (& contact a keyholder who can reset). If the system has been correctly designed and installed for a HMO then false alarms other than malicious call point use should be rare - there are purpose made systems for HMO's designed to reduce the disruption from alarms raised within units as oppose to common parts.

Using this would be simpler https://envirograf.com/product/electrical-consumer-unit-and-distribution-board-fire-protection-system/

You could treat it on the inside with intumescent paint or use the purpose made metal electrical distribution board enclosures. both from https://envirograf.com/ These solutions will be far cheaper.

The smoke ventilation system needs to be tested annually by a competent person as per Article 17 of the fire safety order so it is maintained in an efficient state, in efficient working order and in good repair. There is a lot more to this than just testing it operates and requires a specialist contractor (many electricians and fire alarm companies don't maintain them properly either, a smoke vent specialist is recommended) The same Article applies to the emergency lighting however as the annual duration test only differs in duration to the monthly you could argue that you are competent to do the basic test with other competent persons brought in for repairs.