Skip to main content

CROSS Safety Report

Change of use to care home

Report ID: 1078 Published: 6 June 2022 Region: CROSS-UK


A report has been received relating to the intended change of use of a large building. The reporter is concerned that there is an increase in the risk factors, while the protection levels remain unchanged.

Key Learning Outcomes

Lead designers:

  • Changing the use of a building may require a revised approach to fire safety
  • Changing from a hotel to care premises will require consideration of the mobility and other health issues that will impact the evacuation strategy

Authorities Having Jurisdiction:

  • Change of use from a hotel to a care home may be subject to planning consent requirements, however Building Regulations and in-service fire safety requirements should be considered at the earliest opportunity

Full Report

Find out more about the Full Report

The Full Report below has been submitted to CROSS and describes the reporter’s experience. The text has been edited for clarity and to ensure anonymity and confidentiality by removing any identifiable details. If you would like to know more about our secure reporting process or submit a report yourself, please visit the reporting to CROSS-UK page.


A report has been received relating to the intended change of use of a large building. The reporter is concerned that there is an increase in the risk factors, while the protection levels remain unchanged.

This building is currently used in part as a hotel, and part as private residential flats. Each is served by a single stair core. In order for the original design to be approved and built, a fire engineering solution was sought; part of that solution was a sprinkler system in the hotel occupancy.

A recent change in ownership was followed by a planning application with a council to change the existing use of the hotel to a care home. This application is supported by a report from a fire engineering firm and it is stated that the change of use to a care home is similar to the current use as a hotel. Additionally, the application also includes a section where it is argued that the sprinkler system would not be required if the change of use is to move forward.

However, the reporter is alerted to the fact that there are no alternative means of escape from the hotel, proposed to be a care home, and is also of the opinion that there is a significant difference in the proposed change of use; so, it is not similar to the previous occupancy. This stems principally from the characteristics of the occupants:

  • In a hotel, they would be short term occupants, fully mobile, and any persons with disabilities would be cared for by appropriately trained staff who would follow the hotel’s fire safety procedures and any Personal Emergency Evacuation Plans (PEEPs), among others.
  • In a care home, the occupants are normally elderly, of reduced mobility and alertness, potentially unable to escape unassisted, and can also be bed-bound due to medication or health support mechanisms. Night shifts are usually lower in staff numbers, so that would make this the time that the occupants are at a higher risk.

There is concern that the application may potentially be approved because, according to the reporter, the local authority overlooked that a fire engineering solution was required for the original build. Additionally, the reporter is of the opinion that when the occupancy risk increases, the safety precautions should increase respectively; while they could remain the same, they should not, in any event, be reduced.

The fire engineering report supporting the application may navigate the complexity of the issue in such a way as to influence the local authority to proceed with the change of use, causing a general misgiving to the reporter about the safety of the care home residents in the event of a fire.

Expert Panel Comments

Find out more about the Expert Panels

Expert Panels comment on the reports we receive. They use their experience to help you understand what can be learned from the reports. If you would like to know more, please visit the CROSS-UK Expert Panels page.

The panel agrees that, in terms of the occupancy profile and the means of escape requirements, a care home is not equivalent to a hotel. It can be quite hard to assess this situation, given the lack of details, but the reporter is correct in their uneasiness about the proposed solution with a reduction in safety measures. Sometimes, however, this difference in risk may be offset in some way by higher levels of staffing and management in conjunction with other measures. From the available information, it would appear this case relates to a planning application rather than a Building Regulations (as amended) application, which adds to the confusion. It is also unclear whether this is part of the information being provided under a Fire Statement in support of Gateway 1 of the new regulatory regime (which went live on 1 August 2021).

It is assumed that the issues highlighted in this report would be identified by the Building Control Body and by the Fire and Rescue Service during the consultation process, as the fire safety issues identified indicate the proposed measures might not be suitable, as the indicated layout would not support Progressive Horizontal Evacuation which is commonplace in most care settings.

From the available information, which is limited, it could potentially be presumed that the fire engineering team was brought into the project at a later stage, facing many constraints and unchangeable decisions. It can be challenging for a fire safety engineer to oppose or alter these decisions, especially when considering the differing levels of ‘status’ amongst the disciplines involved in the design process. There is a subtle difference between engineering a design to be safe from the start of the project, and proving that an existing, nearly finalised, design is safe. It might appear counterintuitive, but holding back in the face of uncertainty can be a sign of professionalism, which ultimately serves rather than impedes the design objective of fire safety.

holding back in the face of uncertainty can be a sign of professionalism

In a worst-case scenario, and an example of the lack of the much needed culture change, if the care home was to open and fire safety deficiencies were identified by the enforcing authority of the Regulatory Reform (Fire Safety) Order then there would be a realistic potential of formal action that may involve the prohibition of the use of part of, or all of the premises.

Submit a report

Your report will make a difference. It will help to create positive change and improve safety.

Our secure and confidential safety reporting system gives professionals the opportunity to share their experiences to help others.