The Emergency Evacuation Information Sharing consultation closes on 21 August 2022*. It’s important that disabled, Deaf and older residents have their voices heard. You can respond to the consultation via the Home Office survey or just email your views to FireSafetyUnitconsultations@homeoffice.gov.uk.
We understand the documents are long, complicated and potentially upsetting to read, so we’ve produced this summary of the consultation and our views on it.
Background
In 2019, the Grenfell Inquiry recommended that that there should be a legal requirement on owners and managers of high-rise residential buildings to prepare personal emergency evacuation plans (“PEEPs”) for all residents who would struggle to self-evacuate in an emergency and to keep relevant and up-to-date information about such residents and their PEEPs in a premises information box.
In the 5 years since the Grenfell Tower fire, the Government has not implemented this recommendation, despite promising to do so. Over 40% of those who died in Grenfell Tower were disabled and none of them had evacuation plans.
In 2021, the Home Office consulted on plans for PEEPs and the majority of respondents agreed with the proposals.
After the consultation closed, the Home Office acknowledges that it had private meetings with housing associations and local authorities.
In May 2022, the Government announced plans to scrap the proposal for PEEPs on grounds of “proportionality, practicality and safety”. It launched this latest consultation proposing ‘Emergency Evacuation Information Sharing’ instead of PEEPs. On 5 August 2022, the Government published an easyread version, 2 weeks before the consultation closing date and 2 months after it was requested. The Home Office has since moved the deadline back by 2 working days.
The Home Office has held four workshops for the public and professionals as part of the consultation process. They have all been on Microsoft Teams and the Home Office claimed it was unable to provide a BSL interpreter.
Instead of a right to PEEPs, the Home Office proposes that:
- The onus is on disabled people to tell the ‘responsible person’ if they might not be able to self-evacuate
- The Responsible Person would then perform a ‘person-centred fire risk assessment’ with them
- The RP would share this information with the Fire & Rescue Service
Our concerns
The Government’s proposal does not give disabled people the right to a plan which actively gets them away from a fire and to a place of safety.
The proposals only apply to ‘high risk’ buildings with simultaneous evacuation strategies in place. Mid and high rise buildings which are subject to a ‘stay put’ strategies might need to switch to an emergency evacuation in the event of a fire at any time. Everyone needs a Plan B. A rescue by the fire service should be Plan C.
The Home Office accepts that it takes the fire service some time to reach a fire in high rise building and/or start rescuing people after they get on site. Disabled and older people should be able to start evacuating as soon as possible, without wasting any time, and not wait unnecessarily to be ‘rescued’.
The consultation focuses on mobility-impaired people. It ignores that 1 in 5 of the UK are disabled. A much wider group of people may experience barriers to evacuation, including Deaf people, those with visual impairments, cognitive impairments and learning disabilities.
The Home Office relies on dangerous assumptions without providing evidence to support them, including the following claims:
- Disabled people slow down the evacuation of other residents; and
- Disabled people cannot safely be evacuated.
The proposal claims that there are liability issues for disabled residents to rely on “untrained or non-professional people” to help them evacuate (such as family, PAs or neighbours). However, there are nearly 14 million unpaid carers in the UK who the Government relies upon to provide care for disabled children, adults and older people and deems them to be fully competent and safe.
Placing the burden on disabled people to ‘self identify’ for an assessment is wrong. A disabled resident may not know the barriers they would experience in an evacuation, particularly if it has not happened before.
The only information which the Government proposes is shared with the Fire Service is the floor/flat number of the disabled person. How will a Deaf or non-verbal person communicate with the Fire Service?
The proposal says that the costs of evacuation aids should fall on the individual disabled, Deaf or older person. This is not fair (when adaptation to common parts benefit everyone, including visitors) and individuals will not be able to afford it.
The Home Office’s equality impact assessment is poor. There is very little data in it to show the true impact of the proposals. The Home Office is wrong to conclude that race and gender are not relevant factors to the potential disproportionate negative impacts of their proposed policy.
Our asks
We believe that everyone should have a right to evacuate a block of flats in an emergency. This must include disabled, Deaf and older people, as well as pregnant women and children.
Every resident unable to self-evacuate should have the right to a Personal Emergency Evacuation Plan (PEEP) which enables them to reach an ultimate place of safety, and this should not depend on an arbitrary categorisation of buildings.
Disabled people must have an equal right to evacuate in good time and as safely as possible. Forcing us to wait, waste time and then be subject to an unplanned rescue is wrong and will inevitably result in life-changing injuries.
The Government must provide non-means tested funding for any costs associated with putting PEEPs in place.
We do not believe that there is a need for an on-site individual to facilitate evacuation of disabled people. PEEPs should include putting reasonable and workable measures in place. The starting point must be a positive one, rather than using extreme scenarios to justify the denial of a right for all. Guidance should confirm that PEEPs may involve buddies (including willing family and neighbours).
As a matter of urgency, reliable digital systems should be put in place for responsible persons to share complete and accurate information with the fire service, in a secure manner, which is available in an emergency situation.
Deaf and disabled persons organisations should be commissioned to co-produce any toolkits and guidance documents, like the Disability Access Review and Advisory Committee in the USA.
Responsible Persons (“RPs”) must be expressly obliged to remind, support and advise residents about the right to have a PEEP. All communication must be accessible, reassuring and be provided via multiple channels. They must be obliged to perform mandatory training and the standard of person-centred fire risk assessments need to be monitored. There needs to be a complaints process for individuals to challenge poor assessments.
The Home Office should review and publish the evidence (if it exists) on which it bases its assumptions in this consultation. It should also urgently re-perform the Equality Impact Assessment.
The Emergency Evacuation Information Sharing consultation closes on 17 August 2022. It’s important that disabled, Deaf and older residents have their voices heard. You can respond to the consultation via the Home Office survey or just email your views to FireSafetyUnitconsultations@homeoffice.gov.uk.
- * On 12 August 2022, the closing date for the consultation changed from 17 August to 21 August 2022.
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