CFOA issued some guidance last year, will see if I can find it tomorrow.
The guidance defines ?Unstaffed Hotels? as a premises providing sleeping accommodation for members of the general public, such as would normally be described as a ?Hotel?, but where employees of the hotel are not present within the premises. This absence of staff can either be total, i.e. the hotel is designed to operate without staff being present or staff are absent during certain time periods e.g. during the hours of darkness.
The current CFOA advice on the subject, is contained in-
Collected Perceived Insights Into and Application of the Regulatory Reform (Fire Safety) Order 2005 For the Benefit of Enforcing Authorities (2012)
In particular
Q. 15(1)(a) How does the responsible person ensure that procedures to be followed in the event of fire are appropriate and effective for circumstances in which premises have no staff to implement those procedures, e.g. a hotel without the presence of overnight staff?
A. The requirements of 15(1) (b) suggest that such premises do not comply with the requirements and prohibitions imposed under the Order. The responsible person would have to demonstrate that zero persons are sufficient to implement the procedures. Alternatively, it may be adequate for the responsible person to demonstrate that staff members are ?on call? and located sufficiently close that in the event of fire, they will be able to implement the procedures required under article 15(1)(a). (It is likely that this approach will rarely be appropriate).
Whilst this appears to suggest that it would be very difficult for the responsible person to demonstrate that zero persons are sufficient to implement the procedures, it is interesting to note that there is reference in appendix 1 of the document to unstaffed hotels, which could be interpreted as meaning that zero persons may be sufficient in certain circumstances.
Appendix 1 Un-staffed Hotels
Premises may include those which consist of letting rooms above another business and for which registration and access to keys is through that second business. For all or part of the time, the hotel accommodation may be un-staffed. The whole premises are subject to the Order.
The Norfolk FRS position statement appears to offer a more ?open? approach providing greater risk based guidance which may be worthy of further consideration; particular considering the fact the ?Unstaffed Hotels? appear to be a fact of life. To apply the current guidance in a nationally consistent basis may result in the need for a number of formal actions which may or may not be sufficiently robust to withstand appeal or determination.
Evacuation procedures for non staffed hotels ? Position Statement
It is becoming more common for hotels to utilise business models that do not include on site staff. These premises can meet their statutory duties but they must be able to demonstrate that they have effective procedures in place.
The responsible person has a duty under article 15 of The Regulatory Reform (Fire Safety) Order 2005 to establish and put into effect procedures to be followed in the event of serious and imminent danger to relevant persons.
When auditing a hotel without on site staff, fire risk auditors must ensure the responsible person has a well developed and achievable emergency plan.
Fire risk auditors must be satisfied that the emergency plan is achievable without the use of on site staff with particular attention to;
? How people will be warned if there is a fire (including relevant persons with a disability such as a hearing impairment)
? How the fire and rescue service will be called and who is responsible for this
? What guests should do if there is a fire
? Arrangements for the safe evacuation of people identified as being especially at risk such as those with disabilities and children.
? Procedures for meeting the fire and rescue service on their arrival and notifying them of any specific risks
Further guidance on emergency plans can be found on page 110 of the DCLG Sleeping Accommodation guide
Fire risk auditors must be assured that there is sufficient control over premises that have no on site staff, to ensure the maintenance of fire safety measures such as maintaining escape routes clear of combustible material and preventing fire doors from being wedged open.
So more wool than a field full of sheep. Hope this helps.
