That is the point does the Regulatory Reform (Fire Safety) Order 2005 apply to the land?
Most residential caravan (mobile homes, park homes) sites I have seen consist of an area divided usually into fenced off plots with their own sewerage and water connection and you lease the plot, therefore where is the common areas, other than the road to the caravan plot. I do accept if there is an owners office then that would be subject to the RR(FS)O but that does not have any implications to the fire safety of the caravans so how do you claim the site is subject to the RR(FS)O.
However holiday caravan sites is a different matter I can see how you could claim they have common areas between caravans and the RR(FS)O could apply.
Ian Butter FRICS MRTPI of the Rural and Urban Planning Consultancy says,
Following the introduction of the Fire Safety Order in 2005 a duty was placed on the responsible person to carry out suitable and sufficient assessments of the fire risks on the premises. The Order applies to holiday caravan parks (excluding privately owned units unless they are sub-let) and the common areas of park homes (residential caravans). The latter criterion evidently excludes from consideration the residential caravan itself and its surroundings in private occupation. This has given rise to issues of interpretation which have yet to be adequately resolved. Some Fire Authorities are certain that caravan spacing is not within the scope of the FSO, whereas others consider it is. It is a moot point.
A point to consider, does it matter which legislation applies because a FR assessor conducting a FRA under the RR(FS)O would most probably use the model standards as a guide consequently the fire safety standard would be similar which ever legislation is used, the only difference would be one would be fire risk assessed and the other prescriptive.
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