2026-09-17 · HawkSwift

Care Home Fire Safety: PEEPs, Progressive Horizontal Evacuation and CQC Compliance 2026

Care homes occupy a unique and unforgiving position in UK fire safety law. Residents sleep on-site, many cannot self-evacuate, and two regulators — the Fire and Rescue Authority and the Care Quality Commission (CQC) — can examine your premises at any time. A fire risk assessment for a care home is not a tick-box exercise. It is a detailed, person-centred document that must account for mobility impairments, cognitive conditions, night-time staffing, and a defensible evacuation strategy.

This guide sets out the legal framework, the technical standards, and the practical steps care home managers and responsible persons must take to comply with fire safety law and CQC requirements in 2026.

The Regulatory Stack for Care Homes

Care homes sit at the intersection of multiple statutory regimes. Failure to comply with any one of them exposes the responsible person to enforcement action, prosecution, and — in serious cases — imprisonment.

Regulatory Reform (Fire Safety) Order 2005

The RRO 2005 is the foundation. Article 9 requires the responsible person to carry out a suitable and sufficient fire risk assessment and keep it up to date. Article 8 imposes a duty to take general fire precautions to ensure the safety of relevant persons. Articles 13 to 17 cover detection and warning, fire-fighting equipment, emergency routes, and maintenance.

In a care home, the responsible person is typically the registered manager or the provider. This is a personal legal duty. You cannot delegate it away.

Penalties under Article 32 are severe: unlimited fines on summary conviction, and on indictment, up to two years' imprisonment and an unlimited fine.

Fire Safety Act 2021

The Fire Safety Act 2021 clarified that the RRO applies to the structure, external walls, and flat entrance doors of multi-occupied residential buildings. While aimed primarily at blocks of flats, the clarification reinforced the scope of fire risk assessments for any building with common parts or mixed occupancy.

Fire Safety (England) Regulations 2022 (FSER 2022)

The 2022 Regulations impose additional duties on responsible persons in residential buildings with two or more sets of domestic premises and common parts:

Regulation 7: Monthly checks of fire detection and alarm systems, evacuation alert systems, and automatic door-release mechanisms in high-rise residential buildings (18m+ or 7+ storeys).
Regulation 8: Quarterly inspections of fire doors in common parts of buildings over 11 metres.
Regulation 9: Provision of fire safety information to residents.

For care homes, these regulations apply to common areas. The monthly and quarterly inspection duties must be documented, and records must be available for inspection.

Fire Safety (Residential Evacuation Plans) (England) Regulations 2025

Came into force on 6 April 2026. These Regulations require responsible persons in relevant residential buildings (18m+, 7+ storeys, or 11m+ with simultaneous evacuation) to identify residents who would have difficulty evacuating without assistance, offer them a person-centred fire risk assessment (PCFRA), and agree an emergency evacuation statement.

While aimed at high-rise residential blocks, the principles align with existing care home duties under the RRO. Every care home resident who cannot self-evacuate must have a PEEP — and the 2025 Regulations codify the process for identifying, assessing, and recording those plans.

For a detailed breakdown of the 2025 Regulations, see our guide to Residential PEEP Regulations 2025.

Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

CQC Regulation 15 requires premises and equipment to be safe, suitable, and properly maintained. Fire safety sits squarely within this regulation. On a CQC inspection, expect to produce:

A current fire risk assessment with evidence of action on findings
PEEPs for every resident who needs one
Evacuation drill records (minimum every 6 months)
Staff fire training records
Fire door inspection logs
Fire alarm test records (weekly and annual)
Emergency lighting maintenance records
Sprinkler and suppression system records (where installed)

Regulation 12 (safe care and treatment) also captures fire safety, particularly the duty to do all that is reasonably practicable to mitigate risks to service users.

What Makes Care Homes Different

A care home is a sleeping-risk premises. Many residents cannot self-evacuate. Some are bed-bound. Others have dementia, sensory impairments, or complex medical needs. Supplemental oxygen increases fire intensity. This combination demands a higher standard of fire safety than almost any other premises type.

The CQC reported in 2025 that 38% of inspected care homes had inadequate or non-existent evacuation strategies for residents with mobility, cognitive, or sensory impairments. Enforcement action against care homes has intensified: 192 enforcement notices were issued in 2024/25, the second-highest of any premises type in England.

Progressive horizontal evacuation (PHE) is the default strategy, not simultaneous vertical evacuation.

Progressive Horizontal Evacuation (PHE)

PHE works on the principle of moving residents from a fire-affected compartment through a fire-resisting barrier to an adjoining protected area on the same floor. Vertical evacuation down staircases is the last resort.

Requirements for Effective PHE

At least two fire compartments per floor, separated by 30-minute (minimum) fire-resisting construction. Sixty minutes is preferred.
FD30S fire doors between compartments, fitted with intumescent strips and smoke seals. Electromagnetic hold-open devices linked to the fire alarm allow doors to close on activation.
Refuge areas large enough to accommodate the number of residents being moved, with independent means of escape from each compartment.
Compartmentation integrity — fire doors, fire-stopping around service penetrations, and compartment walls must be intact. A fire door propped open with a wedge defeats the entire strategy.

PHE minimises the risks of moving frail, mobility-impaired residents down staircases. It buys time for the fire service to arrive and deal with the incident.

Fire Alarm Systems: L1 Detection Coverage

The benchmark for care homes is Category L1 coverage under BS 5839-1. This means automatic fire detectors in every area of the building — bedrooms, corridors, roof spaces, cupboards, laundries, and kitchens. A system that covers only communal areas is not adequate.

BS 5839-1:2025, published in 2025, replaced the 2017 edition. Key changes include a 5-7 month servicing window, panel clock checks at each visit, and visual alarm devices (VADs) included in routine maintenance.

For care homes, the weekly manual call point test must be recorded in a logbook. Absence of records is treated as a failure to test. Six-monthly servicing by a competent engineer is recommended for most occupied premises. Annual full inspection to Clause 45 with a written report is required.

Our detailed guide to Fire Alarm Regulations UK covers testing intervals, logbook requirements, and BS 5839 categories.

Personal Emergency Evacuation Plans (PEEPs)

Every care home resident who cannot evacuate independently must have a PEEP. This is not optional. It is a legal requirement under the RRO 2005 (Articles 8 and 15), reinforced by CQC expectations and — for high-rise residential buildings — the 2025 Residential PEEP Regulations.

What a PEEP Must Cover

The resident's specific needs: mobility level (independent, assisted, bed-bound), cognitive ability to follow instructions, sensory impairments, medical equipment in use (oxygen, suction, hoists).
Preferred evacuation route and alternative routes.
Specific staff assistance required: number of carers, equipment (evacuation chair, ski sheet, evacuation pod).
Communication method: how the resident will be alerted (visual alarm, personal alert, buddy system).
Assembly point arrangements.
Review cycle: on admission, on any change in condition, and at least every six months.

Generic Emergency Evacuation Plans (GEEPs)

For staff, visitors, and anyone who may be on the premises without a personal PEEP, a GEEP sets out the standby arrangements. It covers the building's evacuation strategy, available equipment, and staff roles during an emergency.

Evacuation Drills

Minimum every six months, plus at least one unannounced drill. Records must show:

Date and time
Scenario tested
Staff present
Issues identified
Actions agreed
Follow-up completed

A drill that identifies nothing is suspicious — fire and rescue authorities read it as a tick-box exercise. Drills should stress the plan, not just confirm it.

Fire Door Inspections

Under FSER 2022, fire doors in common parts of buildings over 11 metres must be inspected quarterly. For care homes, best practice is to inspect all fire doors — including bedroom doors — at least every six months, often quarterly.

Each inspection records: door reference, condition, self-closing operation, intumescent strips and smoke seals, glass and ironmongery, gap dimensions, and remedial action. FD30S doors are the minimum. Enhanced bedrooms use 60-minute construction.

Magnetic hold-open devices (BS EN 1155) or free-swing self-closing devices linked to the fire alarm allow doors to stand open for resident mobility but close on alarm activation.

Our guide to Fire Door Checks under FSER 2022 covers quarterly inspection duties and record-keeping.

Sprinkler Systems: Mandatory from March 2025

From 2 March 2025, all new care homes in England must have automatic sprinkler systems installed, regardless of building height. This amendment to Approved Document B (Volume 2) aligns England with Scotland, which has mandated sprinklers in new care homes since 2005.

Key requirements:

Sprinklers must comply with BS 9251:2021 (Category 3 for care homes) or BS EN 12845.
Compartment sizes limited to ten beds.
Self-closing doors required.
Transitional arrangements: projects with building control applications submitted before 2 March 2025 could continue under previous guidance if sufficiently progressed by 2 September 2025.

Existing care homes are not legally required to retrofit, but it is strongly encouraged, particularly during major refurbishment. Sprinklers dramatically reduce the spread and severity of fire incidents, provide additional evacuation time, and limit property damage.

Where sprinklers are installed, record-keeping applies: weekly pressure checks, monthly and annual services, and competent person sign-off.

BS 9991:2024 and Care Home Design

BS 9991:2024, published in November 2024, explicitly extends its scope to include residential care homes for the first time. Section 10 provides specific guidance on:

Compartmentation for progressive horizontal evacuation
Staircase widths for assisted evacuation
Refuge area specifications
Sprinkler requirements (mandatory in all residential buildings above 11m)
Smoke control systems

This is now the primary technical standard for care home fire safety design, sitting alongside Approved Document B and HTM 05-02 (for NHS-linked facilities).

Common Fire Hazards in Care Homes

A credible fire risk assessment identifies ignition sources and fuel loads specific to care settings:

Kitchen and laundry: cooking equipment, tumble dryers, lint build-up
Electrical: profiling beds, hoists, medical equipment, charging stations
Oxygen and medical gases: supplemental oxygen dramatically increases fire intensity; cylinders must be stored securely
Emollient creams: highly flammable; risk assessments must account for their use
Arson: care homes are not immune; perimeter security and waste management matter
Smoking: where residents smoke, designated areas with fire-safe receptacles are essential

CQC Inspection Readiness

On a Safe KLOE visit, CQC inspectors will ask for evidence of fire safety compliance. Have the following ready:

1. Current fire risk assessment with action plan and evidence of completion 2. PEEPs for every current resident, reviewed within the last six months 3. Evacuation drill records for the past 12 months 4. Staff fire training register with completion rates 5. Fire door inspection log (quarterly for common parts, six-monthly for all) 6. Fire extinguisher service records (annual) 7. Fire alarm test records (weekly and annual) 8. Emergency lighting records (monthly and annual) 9. Sprinkler/suppression records (where installed) 10. Incident log with learning outcomes

The CQC and fire and rescue authorities share information. A failing on a fire service inspection can become a CQC concern about a safe, well-led service.

Penalties and Enforcement

Post-Grenfell, enforcement has shifted decisively. The typical 2016 approach — improvement notices, warnings, engagement — has given way to prohibition notices, criminal prosecution, and director liability.

Recent cases include:

A Cardiff care home fined nearly £500,000 for serious fire safety failings, including inadequate fire protection, poor fire risk assessments, insufficient smoke alarms, blocked escape routes, deficient emergency lighting, and failure to conduct appropriate evacuation drills.
A care home operator pleading guilty to two breaches: failure to take general fire precautions and failure to make a suitable and sufficient fire risk assessment.

Under the RRO, the responsible person faces unlimited fines and up to two years' imprisonment on indictment. Directors and managers can be personally prosecuted where an offence results from their neglect.

How HawkSwift Can Help

HawkSwift's NEBOSH-qualified assessors specialise in care settings. Our Enhanced tier fire risk assessment covers:

Person-centred evacuation planning for every resident
Progressive horizontal evacuation strategy review
Compartmentation and fire door integrity checks
L1 alarm system assessment
PEEP documentation and review
CQC-ready report delivered within 5 working days

Book a fire risk assessment for care homes or explore our fire safety courses for care home staff.

---

Frequently Asked Questions

Is a fire risk assessment a legal requirement for care homes?

Yes. Article 9 of the Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to carry out a suitable and sufficient fire risk assessment for all non-domestic premises, including care homes. Failure to comply is a criminal offence.

How often should a care home fire risk assessment be reviewed?

PAS 79:2020 recommends reviewing fire risk assessments at least every six months for high-risk settings such as care homes, or immediately following any significant change — structural alterations, change of use, new hazards, or after a fire incident.

Does every care home resident need a PEEP?

Every resident who cannot evacuate independently must have a Personal Emergency Evacuation Plan. This includes residents with mobility impairments, cognitive conditions, sensory impairments, or those who are bed-bound. PEEPs must be reviewed on admission, on any change in condition, and at least every six months.

Are sprinklers mandatory in all care homes?

From 2 March 2025, all new care homes in England must have automatic sprinkler systems, regardless of height. Existing care homes are not legally required to retrofit, but it is strongly encouraged, particularly during major refurbishment.

What fire alarm system does a care home need?

Care homes require Category L1 coverage under BS 5839-1 — automatic fire detectors in every area, including bedrooms, corridors, roof spaces, and cupboards. Weekly manual call point tests and six-monthly professional servicing are mandatory.

How often should care home evacuation drills be held?

Minimum every six months, plus at least one unannounced drill. Records must document the scenario, staff present, issues identified, and actions agreed.

---

Get a Fire Risk Assessment Quote