Domestic smoke and carbon monoxide alarms

 

8th January 2021

FPRA Honorary Consultant Jonathan Gough has prepared a response to the extension of the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 Consultation. This was submitted on 8th January.

Further details of the Consultation are below:

https://www.gov.uk/government/consultations/domestic-smoke-and-carbon-monoxide-alarms

The responses are  shown in green :

Questions: Smoke alarms in rented homes

Q1: Do you support the proposal to extend the smoke alarm requirements as set out in the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 to the social rented sector?

  1. Yes
    b. No

Q2: Please give your reasons.
Early detection will save lives and protect properties from suffering damage from smoke and fire

Q3: Do you think that the guidance on where smoke alarms should be situated requires updating?

  1. Yes
    b. No

Q4: Please give your reasons.

Better examples must be provided so people can decide upon the correct location. Examples could be provided by the manufacture together with information on where additional advice can be obtained, for example via government and manufacture websites.

Q5: Do you agree with the proposal that landlords should not be required to test smoke alarms during the life of the tenancy?

  1. Yes
    b. No

Q6: Please give your reasons.
Will not be practical if the landlord is not a resident within the UK or local to the property. Fire safety is everybody’s responsibility and engaging with residents will help instil this collective responsibility. This could be reinforced through Government campaigns.

Q7: Please provide examples of how social landlords could best support residents to test their smoke alarms regularly and safely.
Provide instruction within information packs provided when the tenancy commences. Place information upon communal notice boards. Reinforce the message a key times of the year, for example, before winter propaganda can be published and made available on web portals asking residents to test their alarms and report faults. Offer a service so a competent person can test the alarm if the resident is unable.

Q8: Do you agree with our proposal that legislation is amended to create an obligation for social landlords to repair or replace smoke alarms, once informed that they are faulty?

  1. Yes
    b. No

Q9: Please give your reasons.
Demonstrates a suitable level of care and concern for the resident by the landlord, and reinforces the importance of life safety systems within communal living areas.

Q10: Do you agree with our proposal that legislation is amended to create an obligation for private landlords to replace alarms once informed that they are faulty?

  1. Yes
    b. No

Q11: Please give your reasons.
Unfortunately, without legislation, some landlords will ignore the guidance. Law will help protect residents and assist them with progressing concerns and matters of non-compliance.

Q12: Do you agree with our proposal to update our guidance document to ensure the choice of alarm meets relevant product standards?

  1. Yes
    b. No

Q13: Please give your reasons.
Consistency delivered by standards is important to ensure all devices perform correctly and help residents ensure the right device has been provided.

Q14: Do you support the proposal to commence the regulations as soon as practicable following the laying of regulations?

  1. Yes
    b. No

Q15: Please give your reasons.
Delays are likely to cause deaths, so the implementation must occur as soon as possible.

Q16 For local authorities only: What additional operational or financial burdens do you consider would be placed on you by enforcing our proposals on smoke alarms? Please provide any costings to support your answer.

Questions: Carbon monoxide alarms in rented homes

Q23: Do you support the proposal to amend the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 to require private landlords and social landlords to install a carbon monoxide alarm in any room used as living accommodation where a fixed combustion appliance of any fuel type (excluding gas cookers) is used?

  1. Yes
    b. No

Q24: Please give your reasons. It will save lives.

Q25: Do you think that the guidance on where carbon monoxide alarms should be situated requires updating?

  1. Yes
    b. No

Q26: Please give your reasons.
Better examples must be provided so people can decide upon the correct location. Examples could be provided by the manufacture together with information on where additional advice can be obtained, for example via government and manufacture websites. Perhaps appliance manufactures should include a detector within every appliance purchased and the competent person installing the appliance is responsible for correctly sighting the alarm.

Q27: Do you agree with the proposal that landlords should not be required to test carbon monoxide alarms during the life of the tenancy?

  1. Yes
    b. No

Q28: Please give your reasons.
Will not be practical if the landlord is not a resident within the UK or local to the property. Safety is everybody’s responsibility and engaging with residents will help instil this collective responsibility. This could be reinforced through Government campaigns.

Q29: Please provide examples of how landlords could best support residents to test their carbon monoxide alarms regularly and safely.
Provide instruction within information packs provided when the tenancy commences. Place information upon communal notice boards. Reinforce the message a key times of the year, for example, before winter propaganda can be published and made available on web portals asking residents to test their alarms and report faults. Offer a service so a competent person can test the alarm if the resident is unable.

Q30: We are proposing that legislation be amended to create an obligation for landlords to repair or replace carbon monoxide alarms, once informed that they are faulty. Do you agree?

  1. Yes
    b. No

Q31: Please give your reasons.
Demonstrates a suitable level of care and concern for the resident by the landlord, and reinforces the importance of life safety systems within communal living areas.

Q32: Do you support the proposal to commence the requirements as soon as possible after laying amended carbon monoxide alarm regulations?

  1. Yes
    b. No

Q33: Please give your reasons.
Delays are likely to cause deaths, so the implementation must occur as soon as possible.

Q34 For local housing authorities only: What additional operational and financial burdens do you consider would be placed on you by enforcing our proposals on carbon monoxide alarms? Please provide any costing to support your answer.