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If anyone has a moment, please could I have your expert steer on a FRA due to be carried out?

The basics:

  • Converted building (originally built circa 1900 but conversion in recent years so not purpose built block of flats)
  • The property as a whole is rented by the same party
  • Communal stair and main entrance – each flat has own independent entrance door opening on to stair
  • Each of the 4 flats has four bedrooms and a shared lounge, diner, kitchen and bathroom.   
  • The premises are not registered for HMO purposes (being the 4 bedroom rule).

The plan is to use the building to house refugees before being housed permanently… so the tenants / occupants may have no connections at all, or they could be a family – so it is very open as to who will be there, and for how long…

The FRA is a Type 3 inspection with communal areas and each flat being looked at.

For the purpose of the FRA, would you consider this as a non-purpose built block of 4 flats, or would you treat each flat as a separate HMO?

The managing agent we have been appointed by is asking for this to be treated as a block of flats (so jurisdiction applying to communal areas and including front doors to flats) and for me to purely comment on fire safety in each of the 4 flats.  But I am worried that each flat should be treated as HMO (albeit not licenced) as 4 people, possibly unknown to each other, could be staying there – therefore, fire doors with self closers, etc. would be needed.

Guidance I would typically use would be LACORS and HM Guidance for Sleeping risks… but LACORS obviously has various case studies depending on the use.

As always, any steer whatsoever is greatly appreciated!

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I've done a few like this for a Local Authority.

Depending on how they are let each flat is either an individual HMO or a shared house (the latter usually only applies with students unless the same family happens to let one). LACORS applies.

The common parts, if converted in accordance with Building Regulations, could in theory fall under the LGA Guide although these blocks are usually full evacuate rather than stay put so arguably you could use the Sleeping Risk guide.

In this scenario it's not one big HMO/flat/shared house, more 4 distinct units with a common access.

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