Means of Escape for Disabled People
Every fire risk assessment must account for everyone in the building — and for responsible persons managing commercial premises, that means thinking carefully about how disabled employees, visitors, and contractors will get out safely if the alarm goes off.
The Regulatory Reform (Fire Safety) Order 2005 is clear on this point: the responsible person must ensure that all people likely to be in the premises, including disabled people, are covered by the emergency evacuation plan. This is not a supplementary consideration to be addressed once the main evacuation strategy is in place — it is a core part of any fire risk assessment. Failure to make adequate provision may constitute both a breach of fire safety legislation and unlawful discrimination under the Equality Act 2010.
For offices and commercial premises, this obligation is often more complex in practice than it first appears. Buildings are occupied by a wide range of people across different floors, with varying mobility, sensory, and cognitive needs, and those needs are not always visible or declared. A responsible person who has thought carefully only about physical wheelchair access, while overlooking hearing impairment, visual impairment, or conditions that affect how a person responds under stress, has not completed the picture.
What the law requires
The duty falls squarely on the responsible person — the employer, building owner, or whoever has control of the premises — to produce a suitable and sufficient fire risk assessment that addresses the evacuation of disabled people, and to implement an emergency plan that puts those arrangements into practice. A fire evacuation plan that does not specifically address the needs of disabled occupants is not adequate under the FSO. The fire and rescue service's role, as the enforcing authority, is to ensure that adequate and reasonable provision is in place; it is not there to compensate for gaps in the responsible person's planning.
The Equality Act 2010 reinforces this by requiring employers and service providers to make reasonable adjustments for disabled people, which extends to ensuring they can leave the building safely. Where a responsible person has made no provision for disabled evacuation, this can be treated as discrimination, in addition to any enforcement action under the FSO. These obligations should also be reflected in a fire safety policy that sets out who is responsible for what, and how arrangements will be reviewed and maintained.
Key pointThe responsible person's evacuation plan must not rely on the fire and rescue service to make it work. Arrangements need to be fully functional on their own, tested regularly, and documented as part of the fire risk assessment record.
Personal Emergency Evacuation Plans (PEEPs)
For employees and regular visitors who require specific assistance to evacuate, the appropriate tool is a Personal Emergency Evacuation Plan, or PEEP. A PEEP is an individually tailored document that sets out how a named person will leave the building in an emergency, taking account of their particular needs, their usual location within the premises, and the physical characteristics of the building. It is not a generic document — it must reflect the actual circumstances of the individual and the building.
Producing a PEEP should involve the individual themselves. Not every disabled person requires assistance, and among those who do, the nature and extent of that assistance varies considerably. A person with a mobility impairment may be able to manage stairs in an emergency even if they use a lift for everyday movement; a person with a hearing impairment may simply need an alerting system that reaches them reliably. The starting point is always a conversation, not an assumption.
PEEPs should be reviewed whenever the individual's circumstances change, when they move to a different area of the building, or when the building's layout or fire safety systems are altered. They should also be tested in fire drills, though it is worth noting that what a disabled person is willing and able to do during a real emergency may differ from what they can reasonably manage in a practice scenario — the PEEP should be written with the real event in mind, and drill procedures should reflect that.
Standard plans for occasional visitors
Employees and regular visitors can be accommodated through individual PEEPs, but commercial premises also receive one-off visitors, contractors, and members of the public whose needs may not be known in advance. For these cases, responsible persons should have standard evacuation options ready at reception, covering the most common scenarios, and should make the availability of these plans clear as part of the sign-in or visitor management process.
A standard plan is not a substitute for a PEEP where one is needed — it is a practical framework for buildings that cannot anticipate every visitor's requirements. Reception staff should be trained to offer options, gather relevant information from the visitor, and ensure that whoever is hosting that person understands their responsibility for assisting with evacuation if necessary.
Mobility impairment and the staircase problem
The most common practical challenge in multi-storey commercial buildings is evacuation from upper floors for people who cannot use the stairs. Standard evacuation lifts are not available in most office buildings — ordinary passenger lifts should not be used in a fire, as they may fail or bring occupants to the fire floor — and so the usual solution involves a combination of horizontal evacuation, areas of refuge, and evacuation chairs.
An area of refuge is a fire-protected space, typically within a protected staircase enclosure, where a person who cannot descend the stairs can wait safely while other occupants evacuate and until trained assistance arrives to help them. The responsible person must ensure that these areas are clearly identified, that staff know where they are and how to use them, and that any person who may need to use one has this reflected in their PEEP. The integrity of the compartmentation protecting these spaces — including the condition of fire doors leading into them — is critical; a fire door inspection will identify any deficiencies in the doors on which these areas depend.
Evacuation chair training is a specific requirement where chairs are part of the evacuation strategy — it is not sufficient to purchase a chair and store it on a landing. Staff who may be called upon to use evacuation equipment need hands-on training, and that training should be recorded and refreshed regularly. Our evacuation chair training service is delivered on-site and covers both the safe operation of the chair and the communication and coordination required to use it effectively during an evacuation.
ImportantDisabled people should not use or be assigned to areas of a building where escape would be difficult or impossible without the intervention of the fire and rescue service. Where a disabled employee's usual working area presents this risk, relocation to a more suitable part of the building should be considered.
Hearing and visual impairment
Mobility is only one dimension of disability, and responsible persons sometimes overlook the evacuation implications of sensory impairments. A person with significant hearing loss may not receive an audible fire alarm reliably, particularly in noisy industrial environments or where they are working with headphones or hearing aids removed. Provision in these cases might include visual alarm devices such as strobes, vibrating pagers, or a designated buddy system where a trained colleague checks on the individual when the alarm activates.
For employees or visitors with visual impairments, the challenge is often orientation — knowing where the escape routes are, being familiar enough with the layout to navigate quickly under stress, and having access to escape route information in an appropriate format. Escape route markings with high colour contrast, tactile floor coverings, and step edge markings all assist; so does ensuring that a visually impaired person is introduced to the escape routes as a matter of routine, rather than waiting for an emergency to discover they are unfamiliar with them.
Cognitive and neurological conditions
This is an area where fire safety guidance has historically been thinner, and where responsible persons need to exercise particular care. People with conditions such as autism, dementia, acquired brain injury, or significant anxiety disorders may respond to a fire alarm differently from the majority of occupants — they may freeze, become disoriented, or be unable to process rapidly changing instructions. The noise and disruption of an evacuation can itself be distressing in ways that impede safe escape.
Where a responsible person is aware of an employee or regular visitor with such a condition, the PEEP process should explore what adjustments will help — whether that is a designated staff member who is always responsible for that individual during an evacuation, a quieter or pre-agreed route, or specific communication strategies. These considerations apply with particular force in care homes and healthcare premises, where the majority of occupants may have cognitive or physical conditions affecting their ability to evacuate independently, and in schools and colleges, where the range of needs among pupils and students can be wide. Research commissioned by the government has acknowledged that the behaviour of people with neurological conditions during evacuation is not yet well understood, and that current guidance does not go far enough in addressing it — which makes it all the more important that responsible persons think carefully about the specific people in their buildings rather than relying on generic protocols.
Multi-occupancy buildings
Commercial office buildings are frequently occupied by more than one organisation, which complicates the picture. Where multiple employers or tenants share a building, each is responsible for the evacuation of their own staff, but overall coordination — including the management of shared escape routes, areas of refuge, and common areas — falls to the building owner or managing agent. In these circumstances, individual organisations must ensure their PEEPs are compatible with the building's overall evacuation strategy, and the responsible persons for each occupier need to cooperate and share information.
Managing agents with responsibilities across office or commercial portfolios can find more specific guidance for their role here. The responsible person for the building as a whole bears the duty of ensuring that all of the individual plans work together, and that no occupier is left to manage their disabled evacuation in isolation from the building's overall procedures.
What to review in your fire risk assessment
A fire risk assessment for a commercial premises should address disabled evacuation across several areas: whether the building's physical design allows for safe horizontal evacuation and the provision of areas of refuge; whether alarm systems will reliably alert all occupants including those with sensory impairments; whether PEEPs are in place for all employees and regular visitors who require them; whether standard plans exist for occasional visitors; whether evacuation chairs are available, maintained, and used by trained staff; and whether all of these arrangements have been tested and documented as part of a current fire evacuation plan. Where the assessment identifies gaps, the responsible person must act to address them within a reasonable timeframe.
Buildings where these questions have not been properly considered are not compliant with the FSO — and in the event of an incident, the consequences of that gap in planning can be severe. For offices and commercial premises of all sizes, this is an area that warrants careful and regular attention.
Need help with your evacuation planning?
Fletcher Risk Management carries out fire risk assessments across offices and commercial premises throughout Chester, Cheshire, the Wirral, and the wider North West. If you have questions about disabled evacuation provision, PEEPs, evacuation chair training, or any aspect of your fire safety arrangements, please get in touch.