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Travel Distance above 18 meters - single escape route.


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In 2019 I had a professional fire risk assessment carried out for my Guest House by an ex fire officer. At the time he said we should decommission the fire escape (as its unsafe) provided we upgraded the ceilings in the basement to 2 hours compartmentation, updated the basement doors to half hour fire doors and carried out additional staff training as this would reduce the risk and extend the travel distance from 18 meters. 2 weeks later the local authority fire officer visited us and said we should carry out the work noted in the fire risk assessment which we did.

About 2 weeks ago we had a visit from a different fire officer to carry out an audit of the fire risk assessment. The fire officer disagreed with his colleague and the risk assessor. He measured the travel distance to be 21 to 22 meters from the furthest point on the top floor of the building. He doesn’t think there is any flexibility in the 18 meter rule and is talking about issuing a prohibition notice so we can’t use the top floor of the building.

The property comprises of a basement, ground, first and second floor. The Guest House accommodates 21 guests and has L2 Fire alarm system in place with sounders in every room. Half hour fire doors are in place to all rooms apart from the boiler room that has a 1 hour door and the en-suite bathrooms that are standard doors.

We have a 5 year periodic electrical assessment certificate for the hard wiring, a fire alarm and emergency lighting certificate, the firefighting equipment (extinguishers and fire blanket) is tested every 12 months and a gas certificate every 12 months. There is an emergency escape plan in place and a Personal Emergency Evacuation Plan. We do a fire drill every 6 months.

I have read through the sleeping accommodation guide book at great length and it does say where the risk can be reduced the travel distances can be extended but there is nothing definitive in there that I could go back to the fire officer with. The book does say were a fire alarm is in place the travel distance can be extended but he disagrees as he said guest houses need to have a fire alarm.

I have also read Part B of the building regulations for ‘buildings other than dwellings’ and can see anything about extended travel distances in that. I have read articles about about BS 9999 which seems to be a little more helpful, in that it talks about increasing the travel distance by 15% where a fire alarm is in place but I am not sure if it applies to me as I can’t read the document in full.

I have spoken to the professional who produced the fire risk assessment since the last fire officer visit but he has advised asking to speak to a superior or getting a solicitor involved (which will probably be expensive).

I would like to know is the fire officer being reasonable in asking us to reinstate the external fire escape? If you think he is can anyone point me in the direction of a good source of supporting information so I can maybe change his mind or his superior. Are there any other steps we can take to reduce the risk (I know its probably difficult to say just by reading a few paragraphs).

Reinstating the fire escape is going to cost a lot of money and after the last few years of trading during covid its not the best timing.

Thank you


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In theory he is within his rights as you should have had a system of maintenance in place over the years so that it did not become unsafe, just because it has been neglected doesn't mean it's OK to do away with it.

BS9999 is an alternative to Approved Document B for designing a building and isn't meant for existing building assessment unless it meets all sections of the document and couldn't help you anyway as the additional % allowed for various matters only apply where fire precautions are above the minimum and an L2 system is determined as the minimum for your type of premises and the other option to extend TD (sprinklers) is no easier than replacing the escape.

I can't see where upgrading the basement alone justified the TD of the floors above - even where the normal TD are used you would expect the doors to be 30 minute and the ceiling 60 (I have no idea where the 120 he advised came from).

The accepted methodology for fire risk assessment (PAS 79-1) determines that TD are not set in stone and minor variations should be acceptable - it's whether 3 metres would be minor or not.

Your options are:
If you think there is no deficiency and no risk and that the Notice is inappropriate: See if the fire authority will agree to an informal review of the decision to issue an notice, failing that you can appeal to your local magistrates’ court within 21 days of receiving a notice.
If you agree there is a need to improve fire precautions but disagree on the technical solution to be used (as in this case): See if the fire authority will agree to refer the issue to the Secretary of State for independent determination under article 36 of the Fire Safety Order (this should be done as soon as possible and ideally before a formal notice is issued). Of the four determinations so far the fire service's solution have won 2, the responsible person's the other 2.

or, if you feel you are unlikely to win, carry out the work.

Possible solutions to TD include - upgrading fire alarm to L1, or fitting sprinklers.


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I trust you will get the situation resolved but at the end of the day the key thing is that your premises are fire-safe. I don’t know the layout but the removal or redundancy of the external stairs would normally warrant a building control application. Relying solely on a fire risk assessor to give a green light on an issue that needs approval through the BC process was not, in my opinion, prudent. 
If I ruled the world, there would be few establishments with sleeping accommodation that didn’t offer an alternative means of escape! 

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