PEEPs in Blocks of Flats: Why Evacuating Disabled Residents Remains an Unresolved Challenge

Personal Emergency Evacuation Plans (PEEPs) are well-established in workplaces, commercial buildings, and other non-domestic premises. When it comes to offices, hospitals, schools, and public buildings, the principle is clear: employers and responsible persons must identify disabled occupants who would need assistance in an evacuation and put a documented plan in place to ensure their safe egress. This is done, dusted, and universally accepted.

But for residential blocks of flats, PEEPs remain one of the most contentious and unresolved issues in UK fire safety. Despite a recommendation from the Grenfell Tower Inquiry that responsible persons should be legally required to prepare PEEPs for disabled residents in high-rise blocks, the government has — for now — declined to implement that recommendation. Understanding why, and what the current obligations are, is essential for every responsible person, managing agent, and fire safety professional.

The Workplace Model: Why It Works There

In a workplace, PEEPs are relatively straightforward. The employer knows who their employees are. The building has trained fire wardens. Evacuation routes are rehearsed. Refuge areas are provided at stairways. The number of disabled occupants is manageable and their needs can be assessed individually.

A typical workplace PEEP might specify that a wheelchair user will proceed to a designated refuge area on their floor and wait for trained colleagues to assist them down the stairway using an evacuation chair, or that the fire service will be alerted to their presence. This works because trained staff are present during working hours, the building is managed, and the occupancy is known.

The Residential Block: A Fundamentally Different Problem

Translating the workplace PEEP model to a residential block of flats encounters several practical obstacles that the government's consultation process laid bare:

No on-site staff in most blocks. The vast majority of residential blocks do not have 24-hour staffing. Even those with daytime concierge services rarely have staff present overnight — precisely when many fires occur. A PEEP that relies on staff presence is meaningless if no staff are there when the emergency happens.

Unknown and changing occupancy. Unlike a workplace, the responsible person for a residential block often does not know the exact composition of their resident population, particularly in blocks with a mix of social housing, leaseholders, and private tenants. Residents come and go. Health conditions change. Maintaining accurate, current PEEPs for a transient population is operationally challenging.

The volunteer problem. Some consultation respondents suggested that PEEPs could rely on neighbours and friends who would assist disabled residents during an evacuation. The government noted in its consultation response that this idea attracted significant concern from respondents. Volunteer arrangements are inherently unreliable — neighbours may be absent, asleep, unwilling, or physically unable to assist. No responsible person could safely base an evacuation plan on the assumption that volunteers would be available at the critical moment.

Proportionality and cost. Providing dedicated staff in every residential block with a disabled resident would impose enormous costs, particularly in the social housing sector. The government's position was that this would be disproportionate to the statistical risk, given that the overall probability of a fire requiring evacuation in any given block is very low.

The Government's Position: Three Tests Not Met

Following its consultation on PEEPs for residential blocks of flats, the government concluded that the evidence base was not sufficient to mandate their implementation. The consultation response articulated three concerns:

1. Practicability — No respondent was able to demonstrate a workable PEEP model for residential blocks that did not rely on either dedicated staff or fire and rescue service intervention. The government found no evidence that anyone had successfully implemented a PEEP in a residential setting without permanent staffing.

2. Proportionality — The requirement must be proportionate to the risk. Mandating 24-hour staffing in every residential block with a disabled resident was not considered proportionate.

3. Safety — Perhaps most significantly, the government concluded that mandating PEEPs at this stage "could in fact have a detrimental effect on those with certain protected characteristics" and "could prove counterproductive because it could increase the risks posed to vulnerable people." In other words, poorly conceived or unworkable PEEPs could create a false sense of security or lead to dangerous evacuation attempts by untrained people.

The government has not permanently closed the door on PEEPs. Ministers have stated that if someone can demonstrate a PEEP model that meets all three tests — practicable, proportionate, and safe — the government would be willing to reconsider.

Emergency Evacuation Information Sharing (EEIS): The Alternative Approach

In place of mandatory PEEPs, the government has consulted on an alternative: Emergency Evacuation Information Sharing (EEIS). This approach is narrower in scope, primarily targeting buildings where the stay-put strategy has been compromised — most notably, buildings with hazardous cladding that has not yet been remediated.

The EEIS proposal would require information about disabled residents to be placed in the building's secure information box, making it available to the fire and rescue service upon arrival. This is not a PEEP in the traditional sense — it does not prescribe how the individual will be evacuated, but it ensures that firefighters are aware of residents who may need assistance.

This consultation has closed, and the government's analysis and response is awaited.

The Judicial Review: Legal Challenge to Government's Position

The government's decision not to mandate PEEPs has been challenged through a judicial review brought by disabled residents, alleging that the government failed to implement the recommendation of the Grenfell Tower Inquiry Phase One report. The outcome of this case could reshape the legal landscape, potentially forcing the government to reconsider its position.

Building professionals should monitor the outcome closely.

What Responsible Persons Should Do Now

While there is no legal requirement for PEEPs in residential blocks, responsible persons should not interpret this as permission to ignore the needs of disabled residents entirely. Good practice includes:

1. Understand Your Residents' Needs

Where possible and appropriate, identify residents who may need assistance in an emergency. This should be handled sensitively, respecting residents' privacy and data protection obligations, and should be voluntary on the resident's part.

2. Ensure the Evacuation Strategy is Appropriate

For the majority of blocks of flats, the stay-put strategy means that residents who are not in the flat of fire origin do not need to evacuate at all. This actually protects many disabled residents — the strategy itself is their plan. However, if the stay-put strategy has been compromised (e.g. by defective cladding), a simultaneous evacuation strategy may be in place, and the needs of disabled residents become far more acute.

3. Consider Interim Measures for High-Risk Buildings

For buildings where the stay-put strategy has been suspended, responsible persons should take active steps to understand and mitigate the evacuation challenges for disabled residents. This might include:

- Maintaining a register of residents who self-identify as needing assistance
- Ensuring the fire and rescue service has this information
- Considering interim measures such as waking watch services that can assist with evacuation
- Installing evacuation alert systems that give advance warning

4. Provide Clear Communication

Ensure all residents, including disabled residents, understand:

- The building's evacuation strategy
- What to do in the event of a fire
- Who to contact with concerns about their personal fire safety
- How to report changes to their mobility or circumstances that might affect their evacuation

5. Document Your Approach

Even in the absence of a legal requirement for PEEPs, responsible persons should document what they have done to consider the needs of disabled residents. In any enforcement action or legal proceedings, being able to demonstrate that you gave thought to vulnerable residents and took reasonable steps will be far more defensible than silence on the subject.

6. Maintain a Watching Brief

The legal and regulatory position on PEEPs and EEIS is actively evolving. The judicial review outcome, the government's response to the EEIS consultation, and potential future statutory instruments under the Building Safety Act could all change the requirements. Stay informed through industry bodies, professional networks, and regulatory updates.

The Broader Principle: Risk Assessment Must Consider All Occupants

Regardless of the specific PEEP debate, the fundamental principle of fire risk assessment remains: the assessment must consider the risks to all occupants, including those with disabilities that may affect their ability to escape in an emergency.

A fire risk assessment that fails to consider the presence and needs of disabled residents is incomplete. Even without a mandatory PEEP requirement, the fire risk assessor should:

- Note where the stay-put strategy is the primary protection for residents who cannot self-evacuate
- Identify where that strategy might be compromised
- Recommend that the responsible person take steps to understand the needs of their resident population
- Flag any buildings where the combination of compromised stay-put strategy and known disabled residents creates an elevated risk

The absence of a legal mandate for PEEPs does not extinguish the duty of care. It simply means the profession must exercise judgement, apply good practice, and act responsibly while the legislative position continues to evolve.

Conclusion

The PEEPs debate encapsulates the tension between aspiration and practicality that runs through much of post-Grenfell fire safety reform. Everyone agrees that disabled residents deserve protection. The challenge is delivering that protection in a way that is workable, affordable, and — crucially — genuinely safe rather than merely bureaucratic.

For responsible persons, the message is clear: you are not currently required to prepare PEEPs for residential blocks, but you are expected to think carefully about how disabled residents would be protected in an emergency, document your approach, and keep pace with what is a rapidly developing area of law and practice.