Why Building Height Shouldn’t Define Safety Policies - The flawed logic of PEEPs

Why Limit PEEPs to High-Rise Residential Buildings Over 11m?

Today, the Home Office published its response to the Emergency Evacuation Information Sharing Plus (EEIS+) consultation, making an important clarification: Personal Emergency Evacuation Plans (PEEPs) will now apply not only to higher-risk residential buildings (HRBs) but also to residential buildings between 11m and 18m with simultaneous evacuation strategies. This expanded scope reflects growing recognition of the unique evacuation challenges posed by taller buildings. However, the decision to restrict PEEPs to these specific building types, based on building height, raises critical questions about inclusivity and the industry's commitment to risk-based approaches.

The Intrinsic Challenge of High-Rise Buildings

The consultation response emphasises that higher-risk buildings inherently limit evacuation opportunities. Factors such as complex layouts, vertical evacuation paths and the potential for overcrowding in emergency situations mean that residents and in particular, those with mobility impairments, face heightened risks. The Grenfell Tower Inquiry rightly spotlighted the need for tailored evacuation plans in such buildings, underscoring that safety should be proactive, not reactive.

Yet, while these findings are valid, they don't tell the whole story. High-rise buildings aren’t the only places where disabled or vulnerable individuals might face evacuation challenges. By using height to define the safety policy, essentially limiting PEEPs to buildings over 11m, the response could end up creating a patchwork of safety measures that excludes many in need.

Costs Versus Lives: Striking the balance when defining safety policies, and the flawed logic of PEEPs

The consultation's Impact Assessment reveals the crux of the issue: cost. Extending mandatory PEEPs to all 1.7 million multi-occupied residential buildings under the Fire Safety Order would come with significant financial implications. At this stage, the government has deemed the additional costs disproportionate. While financial prudence is necessary, it’s worth questioning whether an arbitrary height threshold is the right way to manage safety. (And this goes for more than just PEEPs!)

After all, a disabled resident living on the third floor of a 10 metre building faces comparable challenges to someone in a high-rise. Conversely, a ground-floor resident in a taller building might be able to self-evacuate. Evacuation planning should be about individual risk, not just building height.

A Risk-Based Approach: Tailoring safety policies to individuals

As the industry moves toward a risk-based approach to safety, this is an opportunity to embed inclusivity in policy. Building height shouldn’t define safety policies; rather than using building height as the sole determinant of PEEPs eligibility, responsible persons (RPs) should conduct case-by-case risk assessments. If a person presents with mobility issues, their evacuation needs should be evaluated, regardless of whether their building qualifies as "high-rise, higher risk, high-risk" (depending on how you take you tea).

This approach aligns with the spirit of the Fire Safety Order, which places responsibility for life safety firmly in the hands of RPs. By assessing individual needs, RPs can implement proportionate measures that reflect the reality of the risks faced by residents.

If building height shouldn’t define safety policies, then where do we go from here?

The EEIS+ response is a step in the right direction but it doesn’t go far enough. In a sector increasingly committed to risk-based solutions, limiting PEEPs to buildings >11m buildings feels like a missed opportunity. The focus must shift from building height to individual need. Only then can we ensure that every resident, regardless of their mobility or where they live, has a fair chance at a safe evacuation.

This isn't about a one-size-fits-all solution. It’s about making safety personal and that starts with expanding our scope and our thinking.