Hi,
Changing tack for 30 seconds, trying to link threads when this new guidance is prepared, it may be prudent to include "student accommodation" as these are now classed as "flats" and have been subject to various intrepretation until the court ruling and considering the inference of the governments literature / understanding of "paying guests" for the summer periods, when there are short term lets and a common understanding that the Fire Safety Order then applies.
Put all this in a timber framed building, which has not been built that well or maintained, makes this in practice a recipe for potential diaster. (Although timber framed building issues when during construction phase has hit the head lines, there being not much for on going maintenace and protection of the structure). A fire in part of a building controlled by one trype of legislation, can spread to a different part being controlled by another piece of legislation, in a building type which timber frame characterises the over risk. (I would add if maintained well etc it is acceptable form of construction). The danger is when it is not, and in the current period of recession and lack of funding are all factors that impact on this sceranio.
Dare I say it and using common sense (although this has no bearing in law), as much as certain groups want it and others don't; an "audit of the standard of fire safety" in a building whether parts fall under certain legislation is something that should be undertaken and whether it has a name tag of FRA or some other name / check. Surely its making sure (a check) that the protection from fire for the normal users is the objective. From a a parent's perspective and considering youg people in most types of student accommodation, or any other flat and keeping users safe is not the objective?
Just a few thoughts.