Written evidence submitted by West Midlands Fire Service [EXA 106]
1 West Midlands Fire Service is England’s second largest Fire and Rescue Service, providing emergency response, protection, and prevention services to the 2.9 million residents of Birmingham, Coventry, Dudley, Sandwell, Solihull, Walsall and Wolverhampton.
2 WMFS understands that exempt accommodation is predominantly made up of small residential units and houses of multiple occupation (HMO). Residents are typically at greater risk and have higher support and welfare needs. Quality support and accommodation with appropriate regulation and oversight is often out of reach. This type of accommodation is often the only option for individuals who are seeking accommodation for example after being released from prison or as a first step to housing following homelessness.
3 There are likely to be thousands of premises of this type in the WMFS service area which are typically occupied by a broad range of individuals who often have multiple and complex needs requiring care and support. We know there to be 22,000 exempt accommodation claimants in Birmingham alone[1].
4 As a Fire and Rescue Service, WMFS has statutory functions to Prevent and Protect the communities and businesses from Fires and other emergencies as well as responding to these emergencies when they occur.
5 WMFS has the resources to meet its duties for Prevention and Protection through the provision of support and guidance to foster good practice with the objectives of:-
6 However, exempt accommodation provides a series of challenges for WMFS in meeting its Prevention, Protection and Response statutory duties and its ability to effectively target its resources and support providers and residents. These are:-
6.1 The multiple and complex needs of the individuals residing in such accommodation increase the individual’s risk and vulnerability to accidental dwelling fires and in being seriously or fatally injured if a fire occurs.
6.2 The first point at which WMFS will identify an exempt premise and the risks and vulnerabilities of its residents is often through attendance at an emergency incident or in response to the receipt of a complaint regarding compliance with the Fire Safety Order. This provides little or no opportunity to proactively engage in Prevention and Protection activities before an issue arises.
6.3 The Fire Safety Order is enforced to achieve minimum fire safety standards and most premises meet these but go no further in support of good practice to better protect their residents and their businesses. There are instances where providers have sought guidance from WMFS Protection teams to improve Fire Safety standards beyond minimum compliance, however these are extremely rare.
6.4 WMFS does not have access to full information on exempt accommodation and is therefore unable to provide a complete picture to support or otherwise the prevalence or nature of incidents at such properties. This limits our ability to monitor trends and impact of emergency incidents or the demand on WMFS resources for response at exempt accommodation premises.
6.5 WMFS Emergency incident data and learning from serious incident reviews identify that an individual is more likely to have a fire and be seriously or fatally injured as a result if they reside in rented accommodation. The risk of serious or fatal injury increases where there are multiple and complex support needs. For example, those with mental health issues/illness, smokers, those taking prescribed medication, those with alcohol or drug dependency or those with care and support needs.
6.6 WMFS offers education, support, and the opportunity to refer and signpost individuals to support from agencies through a Safe & Well Visit. The aim and purpose of this visit is mitigating the risk of fire, injury and death for the individual and therefore, in this type of accommodation, for all of the residents at the premises.
6.7 Typically, those who have multiple and complex needs, increasing their risk and vulnerability to fire, are referred to WMFS for a Safe & Well by workers in organisations already supporting them. The transient nature of the residents and the number of premises, with many tenants accessing the accommodation directly due to little or no support from other agencies means there is little or no opportunity to receive such referrals. This results in extremely limited opportunity for WMFS to engage with the individuals who reside in such accommodation to support with Safe & Well as these circumstances make the opportunity for referrals is extremely limited.
6.8 It is not clear to WMFS what if any needs assessment is completed within in the tenancy agreement processes and what the timescales are for completing these. A timely assessment at tenancy sign up would enable providers to support residents to seek help and support to meet their needs, referring those who are at risk and vulnerable to WMFS for a Safe & Well visit.
7.1 Creating an expectation on local authorities and providers to routinely share this information with WMFS would enable and provide opportunity for the service as a Fire and Rescue Service establish robust partnership and information sharing arrangements with our local authorities.
7.2 This information would enable the service to evidence the extent to which its resources are deployed to emergency incidents at such accommodation and the nature of them to support a proactive and proportionate approach to targeting our Prevention and Protection activities where the risk and need is greatest.
February 2022
[1] https://www.insidehousing.co.uk/insight/insight/the-story-explained-what-is-exempt-accommodation-73541