Domestic violence refuges provide essential accommodation for vulnerable individuals and families. Because these premises involve sleeping risk and may operate with limited staffing overnight, fire safety arrangements must be robust, clearly managed and legally compliant.
Refuges are classed as non-domestic premises under fire safety legislation. This means a suitable and sufficient fire risk assessment is a legal requirement.
Why is a fire risk assessment required?
The requirement to undertake a fire risk assessment for non-domestic premises is set out in the Regulatory Reform (Fire Safety) Order 2005. The Order applies to virtually all non-domestic premises in England and Wales, including sleeping accommodation such as refuges.
The key stages of a fire risk assessment include:
- Identifying fire hazards
- Identifying people at risk
- Evaluating, removing or reducing risks
- Informing, instructing and training
- Reviewing and updating the assessment regularly
Domestic violence refuges are typically treated as sleeping accommodation for fire safety purposes. This places particular importance on early warning systems, clear escape routes and effective evacuation procedures.
The role of the Responsible Person
The “Responsible Person” is the individual or organisation with legal responsibility for fire safety compliance under the Order. In domestic violence organisations, this is often the Chief Executive, a senior manager, or the Management Board. Where the building is owned or managed by a Housing Association, responsibilities may be shared.
The Order also places a duty of co-operation and co-ordination (Section 22) on those who share control of premises. This requires clear communication between parties and documented arrangements for matters such as fire alarm servicing, emergency lighting maintenance and escape route management.
Relevant guidance
Guidance for domestic violence refuges generally falls under sleeping accommodation. Organisations should consider appropriate government guidance for sleeping premises alongside:
- LACORS Housing – Fire Safety guidance
- National Fire Chiefs Council (NFCC) guidance on Fire Safety in Specialised Housing
- Approved Document B, which sets out building fire safety requirements
These documents should be used to inform, but not replace, a premises-specific fire risk assessment.
Who can carry out a fire risk assessment?
A fire risk assessment must be completed by a competent person. This may be the Responsible Person, provided they have sufficient knowledge, training and experience.
A competent person is someone with enough training, experience, knowledge and other qualities to properly implement preventative and protective fire safety measures.
Some smaller or lower-risk premises may complete assessments internally. However, organisations must recognise their limits. If suitable competence is not available in-house, an external assessor should be appointed.
Importantly, even where the assessment is outsourced, the Responsible Person remains legally accountable for ensuring that the fire risk assessment is suitable and sufficient.
Recent prosecution highlights the risks
Lancashire Fire and Rescue Service successfully prosecuted a supported living care provider following serious breaches of the Regulatory Reform (Fire Safety) Order 2005.
After attending a fire at a supported living property in July 2019, which resulted in one fatality and serious injury to another resident, inspectors identified significant fire safety deficiencies. These included issues with escape routes, the fire alarm system, management controls and the absence of a suitable and sufficient fire risk assessment.
In September 2024, the provider pleaded guilty to failing to ensure general fire safety precautions and failing to undertake a suitable fire risk assessment. In January 2025, the company was fined £135,000 and ordered to pay £18,705 in costs.
While domestic violence refuges are typically classed as independent living rather than supported living, the legal duties are clear. Effective fire safety arrangements, regular review of risk assessments and prompt action to address deficiencies are essential to protect residents and ensure compliance.
Are your fire safety arrangements compliant?
Domestic violence organisations rightly prioritise supporting victims of abuse. However, ensuring a safe environment and protecting the health, safety and welfare of residents must remain a core responsibility.
Fire safety failures can result in significant fines, reputational damage and, most importantly, serious harm. A suitable and sufficient fire risk assessment is a fundamental part of meeting your legal duties.
Our Fire Risk Management specialists can support organisations in reviewing existing fire risk assessments, clarifying Responsible Person duties and strengthening fire safety arrangements.
