Fire Safety, Emergency Planning & Regulation 25 in Children's Homes: Fire Risk Assessments, Evacuation, Drills, Fire Doors, Alarms, Individual Needs & Ofsted Expectations

Fire safety in a children's home cannot be reduced to a current fire risk assessment certificate and a regularly tested alarm. The real test is whether the fire strategy would actually work at the worst possible moment, with the children who genuinely live there and the staff who are genuinely on duty. This guide explains Regulation 25 of the Children's Homes (England) Regulations 2015, the relationship between Regulation 25 and the Regulatory Reform (Fire Safety) Order 2005, fire risk assessments, the building and its precautions, alarms and detection, escape routes and fire doors, child-specific evacuation needs, night-time arrangements, drills and training, what happens after a fire or serious event, recording and oversight, and what Ofsted looks for.

Child-centred question

If the alarm sounded at 2:17am tonight, could every child actually get out safely with the staff who are really on duty?

1. Quick answer and current position

Fire safety in a children's home is a live system, not a certificate. The official residential-care fire guidance describes the fire risk assessment as the foundation for fire precautions and says it should determine the physical measures and management arrangements necessary to keep people safe. It specifically identifies children, disabled people and people with additional needs as requiring particular consideration.

There is an important legal distinction to understand from the start. Regulation 25 contains two different routes depending on whether the Regulatory Reform (Fire Safety) Order 2005 applies to the home. This is not a technicality. It determines which legal framework the home must follow and who enforces it.

The single question this guide is built around

Every fire safety system in a children's home should be tested against one question: if the alarm went off at the worst possible moment, with the children who actually live there and the staff who are actually on duty, could every child get out safely? If the honest answer is not a clear yes, the system needs work.

2. The legal framework

Regulation 25 is the children's-home regulation. The Fire Safety Order is the broader fire-safety framework. Where the Fire Safety Order applies, Regulation 25(2) effectively directs the home into that wider framework. Understanding the relationship between these two legal sources is essential.

Regulation 25(1): where the Fire Safety Order does not apply

Where the Fire Safety Order does not apply to the home, Regulation 25(1) applies directly. After consultation with the fire and rescue authority, the registered person must take adequate precautions against the risk of fire, including the provision of suitable fire equipment, provide adequate means of escape from the home in the event of fire, make arrangements for persons working at the home to receive suitable training in fire prevention, and ensure, by means of fire drills and practices at suitable intervals, that persons working at the home and, so far as reasonably practicable, children are aware of the procedure to be followed in case of fire.

Regulation 25(2): where the Fire Safety Order applies

Where the Fire Safety Order applies to the home, Regulation 25(1) does not apply. Instead, the registered person must ensure that the requirements of the Fire Safety Order and any regulations made under it are complied with in respect of the home, except for Article 23, which contains duties placed directly on employees. This does not mean Regulation 25 is irrelevant. It means Regulation 25 itself points the home into the wider Fire Safety Order legal framework.

The Responsible Person under the Fire Safety Order

The Fire Safety Order places responsibility for fire safety on the person or persons with control of the relevant premises, known as the Responsible Person. In workplaces that will commonly include the employer, with other people such as owners or occupiers potentially also having duties according to their control of the premises. Where there is more than one Responsible Person, current fire law requires cooperation and coordination between them.

Registered Person and Responsible Person are not automatically the same

Registered Person comes from children's homes regulation. Responsible Person comes from fire safety law. Depending on the organisation and property arrangements, different individuals or organisations may hold different aspects of responsibility. For example, there could be the children's-home provider, the employer, the building owner, a landlord, or another person controlling part of the premises.

Article 23 and employee duties

Regulation 25(2) excludes Article 23 of the Fire Safety Order from the registered person's compliance duty because Article 23 places duties directly on employees. This does not mean employees have no fire-safety duties. It means those duties sit on the employees themselves rather than being the registered person's duty to ensure. Employees must take reasonable care for the safety of themselves and others, cooperate with their employer on fire safety, and not do anything that would place people at risk.

3. Fire risk assessment

The fire risk assessment is the foundation of the entire fire safety system. It identifies what could start a fire, who could be harmed, how fire or smoke would spread, and what measures are needed to protect people. The official residential-care guidance describes it as the starting point for all fire precautions.

What a fire risk assessment must cover

A suitable and sufficient fire risk assessment should identify fire hazards, identify people at risk, evaluate the risk, record the findings, and set out an action plan. For premises caring for children, it should pay particular attention to children, disabled people and people with special needs. The assessment should consider the building, the activities within it, the people who live and work there, and the specific needs of each child.

Competent fire-risk assessors

The fire risk assessment should be carried out by a competent person. Competence means having sufficient training, knowledge, experience and ability to undertake the role. For complex premises or where children have significant additional needs, the assessor should understand residential care environments and the specific evacuation challenges children may present. A generic commercial fire risk assessment that does not account for the children who actually live there is not adequate.

Review triggers

A fire risk assessment is not a one-off document. It must be reviewed regularly and updated when circumstances change. Review triggers include: a new child with different evacuation needs, a change in staffing levels or patterns, building alterations or changes of use, a fire or near miss, a failed drill, new equipment or furniture, changes to alarm or detection systems, a change of registered person, or any significant change to the premises or its use.

4. The building and fire precautions

The building itself is the first layer of fire safety. Good design, construction and maintenance reduce the likelihood of fire starting and limit how fire and smoke spread. The fire risk assessment should identify what physical measures the building needs.

Compartmentation and fire-stopping

Fire compartmentation limits the spread of fire and smoke within a building. Fire-resisting construction, fire doors and fire-stopping at service penetrations all contribute. Any alteration that breaches compartmentation, such as removing a fire door, creating an opening in a fire wall, or running cables through fire-stopping without remediation, can undermine the building's fire safety. Building work should be checked for its effect on fire separation.

Smoking and vaping

Smoking and vaping present fire risks. Smoking materials are a common cause of fire. Vaping devices and batteries have been linked to fires. The home should have a clear smoking and vaping policy that addresses where these activities may take place, safe disposal of smoking materials, charging of vaping devices, and storage. The policy should be reflected in the fire risk assessment.

Fire-setting behaviours

Some children may have fire-setting behaviours. This is a specific risk that the fire risk assessment must address. The response is not simply to remove matches and lighters, though that may be part of the plan. It should include understanding the function of the behaviour, specialist support where needed, supervision arrangements, environmental controls, and staff training. The local fire and rescue service may have a fire-setter intervention programme.

Lithium batteries, e-bikes and e-scooters

Lithium-ion batteries in e-bikes, e-scooters, phones and other devices present a specific fire risk, particularly during charging. Fires involving lithium batteries can develop rapidly and are difficult to extinguish. The fire risk assessment should address where and how such devices are charged, whether charging is permitted in bedrooms or escape routes, and what restrictions are needed. Some fire and rescue services and insurers have issued specific guidance on this issue.

Cooking, electrical equipment and candles

Cooking, electrical equipment and candles are common sources of fire in domestic settings. The fire risk assessment should consider kitchen safety, electrical testing and inspection (such as PAT testing where applicable), the use of candles and cultural or religious practices involving naked flames, and whether additional controls or supervision are needed. Cultural and religious practice should be respected, but the fire risk must still be managed.

5. Alarms, detection and fire-fighting equipment

Early warning and first-aid fire-fighting are critical layers of the fire safety system. The fire risk assessment determines what the building needs.

Fire alarm and detection systems

The fire alarm and detection system must be suitable for the premises and the people in it. For a children's home, this means considering whether children will wake to an alarm. Research and official guidance recognise that children, particularly younger children and those with certain disabilities, may not wake reliably to standard smoke alarm tones. The system should be designed to address this, which may include different alarm tones, voice alarms, or additional detection in sleeping areas. The system must be installed, commissioned, maintained and tested by competent persons.

Alarm testing and maintenance

Alarm systems require regular testing and maintenance. This typically includes weekly manual call-point tests, periodic full-system tests by a competent engineer, and maintenance of all components. Records of testing and maintenance should be kept. A fault in the alarm system is a serious matter and should be addressed immediately, with interim measures if needed.

Fire-fighting equipment

Fire-fighting equipment such as extinguishers and fire blankets should be provided as determined by the fire risk assessment. Equipment must be suitable for the types of fire likely in the area, correctly located, maintained, and inspected. Staff should know where equipment is, what type it is, and when it is safe to use it. The fire risk assessment should determine whether staff are expected to use fire-fighting equipment and what training they need.

Sprinklers and suppression systems

Sprinkler and other suppression systems may be fitted in some premises. Where they are present, they must be maintained and tested. Where a new build or major refurbishment is planned, the question of whether to install suppression should be considered. The fire risk assessment and building regulations requirements will inform this. Sprinklers are not a substitute for evacuation planning, but they can significantly reduce the rate of fire and smoke spread.

6. Escape routes, fire doors and safe evacuation

If a fire starts, people need to get out. Escape routes, fire doors and final exits are the physical infrastructure that makes that possible. They must be usable at all times.

Escape routes

Escape routes must be kept clear, unobstructed and usable. This includes corridors, stairways, fire exits and the routes to them. Furniture, storage, deliveries, pushchairs, bikes and other items should not be left in escape routes. Final exits must be operable, which means checking that locks, keypads, panic bars and other security devices work and that staff know how to use them. If an exit is locked or obstructed, it is not an exit.

Fire doors

Fire doors are a critical part of compartmentation. They resist the spread of fire and smoke for a defined period. A fire door only works if it is closed. Fire doors that are propped open, damaged, or have missing or faulty self-closing devices are not providing protection. Bedroom doors in a children's home may be fire doors, and their role in protecting sleeping children and maintaining escape routes should be understood. Fire doors should be inspected regularly and maintained by competent persons.

Emergency lighting

Emergency lighting provides illumination if the normal lighting fails. This is important for evacuation, particularly at night or in windowless areas. Emergency lighting should be tested and maintained. The fire risk assessment determines where it is needed.

Locks, keypads and access control

Security measures must not compromise escape. If doors are locked for safeguarding reasons, the locking system must allow escape from the inside without a key or code that may not be available in an emergency. Keypad codes, key safes and access control systems must be assessed for their effect on evacuation. Staff must know how to release doors in an emergency. The fire risk assessment should address this directly.

7. Child-specific evacuation needs

A fire risk assessment that does not account for the children who actually live there is not a live safety system. Each child may present different evacuation needs. The fire safety system must be built around the real children, not an idealised emergency.

Children who may not respond predictably

Some children may not respond to an alarm in the way an adult would. They may sleep through it, be frightened by it, hide, freeze, refuse to leave, try to collect belongings, or go the wrong way. Children with learning disabilities, autism, sensory needs, or trauma histories may have particular responses. The evacuation plan must account for this, not assume uniform behaviour.

Disabled children and children with mobility needs

Disabled children and children with mobility needs may require assistance to evacuate. This may include physical assistance, transfer equipment, evacuation chairs, or refuges. The plan must specify who provides that assistance, whether the staff on duty can actually provide it, and what happens if the usual staff are not present. The fire risk assessment should identify each child's needs and the measures to meet them.

Sensory and communication needs

Children with hearing or visual impairments may need alternative warning systems, such as vibrating pads, strobe lights, or personal alarms. Children with communication needs may need the evacuation explained in a way they understand. The fire risk assessment should identify these needs and the equipment or support required.

Personal Emergency Evacuation Plans (PEEPs)

A Personal Emergency Evacuation Plan (PEEP) is an individual plan for a person who needs assistance to evacuate. For a children's home, any child who cannot evacuate independently should have a PEEP. The PEEP should set out the child's needs, the assistance required, who provides it, the equipment needed, and the escape route. It should be tested through drills. The PEEP is part of the care plan and should be reviewed when the child's needs or the building change.

Child-centred question

Does this child understand what the alarm means and what staff need them to do?

Child-centred question

Are our evacuation arrangements based on the child we actually care for, or on an idealised emergency?

8. Night-time fire safety

Night-time is the highest-risk period for fire in any residential setting. People are asleep, visibility is reduced, and staffing levels may be lower. The fire safety system must work at night, not just during the day.

Minimum staffing tests

The fire risk assessment should consider whether the staff on duty at night can actually evacuate all the children. This is not just a question of numbers. It is a question of whether the staff present can wake the children, support those who need assistance, manage those who may not respond predictably, and account for everyone. If the night staffing level cannot support evacuation, the staffing level or the fire safety system needs to change.

Children who sleep through alarms

Research has shown that children, particularly younger children, may not wake reliably to standard smoke alarm tones. The fire safety system must address this. Options include different alarm tones, voice alarms, and personal waking devices. The plan must not assume that an alarm sounding will result in all children waking and responding. Staff may need to physically wake children, which requires enough staff to reach all bedrooms.

Night-time drills

Fire drills should include night-time scenarios. A drill that only tests daytime evacuation does not test the highest-risk period. A night-time drill should test whether staff can wake children, support evacuation, and account for everyone with the staffing levels that are actually present at night. This can be done sensitively, but it must be done.

9. Fire drills, training and staff readiness

Drills and training test whether the fire safety system actually works. They are not box-ticking exercises. A drill that reveals a problem and leads to it being fixed is a successful drill. A drill that reveals nothing and changes nothing may not have been testing the right things.

How often should drills happen?

Regulation 25(1)(d) requires fire drills and practices at suitable intervals. The frequency should be determined by the fire risk assessment and the needs of the home. There is no single statutory number that applies to all children's homes. The key question is whether drills happen often enough to ensure that staff and, so far as reasonably practicable, children know what to do. Drills should vary in timing, including at night, and in scenario.

What a drill should test

A drill should test the alarm system, staff response, evacuation routes, time to evacuate, accounting for everyone, and the specific needs of individual children. It should identify weaknesses. After the drill, there should be a debrief: what worked, what did not, what needs to change, who will do it, and by when. The findings should be recorded and acted on.

Staff training

Regulation 25(1)(c) requires suitable training in fire prevention for persons working at the home. Training should cover fire prevention, the alarm system, evacuation procedures, use of fire-fighting equipment where appropriate, child-specific needs, and what to do after a fire or alarm. Training should be provided on induction and refreshed regularly. Agency staff and new staff should receive relevant fire safety information before being left in charge of children.

Agency staff, visitors and contractors

Agency staff, visitors and contractors need to know what to do in a fire. Agency staff should receive fire safety information as part of their induction to the home. Visitors and contractors should be told about the alarm, evacuation routes, and assembly point. Contractors doing hot work or other fire-risk activities should be supervised and assessed. The fire risk assessment should address these groups.

10. What to do after a fire or serious fire safety event

A fire, near miss, false alarm, or equipment failure is not just an incident to be recorded and forgotten. It is a test of the system that should be learned from.

Immediate response

After a fire or alarm, the first priority is safety: account for everyone, check for injury, ensure the building is safe or evacuated, and follow the emergency plan. The fire and rescue service should be called for any fire, however small. Do not assume a small fire has been fully extinguished. Carbon monoxide and smoke damage can affect health even after the fire is out.

Notifications

A fire in a children's home may be a notifiable event under Regulation 40. The home should consider whether the event meets the threshold for notification to Ofsted and, where relevant, the placing authority. False alarms and equipment failures may also need to be considered, particularly if they reveal a systemic problem. When in doubt, seek advice. It is better to notify and be told it was not necessary than to fail to notify a serious event.

Review and learning

After any fire, near miss, or significant false alarm, the fire risk assessment and the fire safety plan should be reviewed. What happened? Why? Did the system work? What could have been different? What needs to change? The findings should be recorded, acted on, and shared with staff. A fire that reveals a weakness and leads to improvement makes the home safer. A fire that is treated as a one-off and not learned from does not.

11. Recording, monitoring and management oversight

Fire safety requires records, but records are not the point. The point is a system that works. Records are the evidence that the system is being maintained and the tool that allows management to check it.

Schedule 4 records

The Children's Homes (England) Regulations 2015 include record-keeping requirements in Schedule 4. Fire safety records, including fire risk assessments, alarm tests, drills, training, equipment maintenance and incidents, should be kept as part of the home's records system. Records should be clear, current, and available for inspection.

What records to keep

Fire safety records typically include: the fire risk assessment and its review dates, alarm test records, drill records including debrief findings and actions, training records, equipment maintenance certificates, PEEPs, incident records, and actions taken in response to findings. Records should show not just that something was done, but what was found and what changed as a result.

Management oversight

The Registered Manager and Responsible Individual should maintain oversight of fire safety. This means not just receiving records but checking them: are drills happening? Are findings being acted on? Are PEEPs current? Is the alarm being maintained? Are there recurring false alarms? Is the fire risk assessment current? Management oversight is the check that the system is alive, not just a file.

12. Ofsted, Regulation 44 and Regulation 45 scrutiny

Fire safety is subject to several layers of scrutiny: Ofsted inspection, Regulation 44 independent visits, and Regulation 45 quality of care reviews. Each provides a different perspective on whether the system is working.

What Ofsted looks for

Ofsted inspectors consider whether children are safe and protected. Fire safety is part of this. Inspectors may look at the fire risk assessment, drill records, training records, PEEPs, the physical condition of the building, and whether staff and children know what to do. They may ask children about fire drills. They may check that false alarms and incidents have been learned from. A fire safety system that is a live, well-maintained system will stand up to inspection. One that is a paper exercise will not.

Regulation 44 independent visits

Regulation 44 requires the independent person to visit the home at least once in each month, with a report following the visit. The independent visitor reports on whether children are being safeguarded and their welfare promoted. Fire safety is a relevant consideration. The Regulation 44 report may identify fire safety concerns, and the home must consider and respond to them. A pattern of fire safety findings across Regulation 44 reports should prompt management review.

Regulation 45 quality of care reviews

Regulation 45 requires the registered person to review the quality of care provided by the home at least every six months. The review should consider whether the home is meeting the needs of children, including their safety. Fire safety is part of this. The Regulation 45 review is an opportunity to step back and ask whether the fire safety system is working as a whole, not just whether individual records are in place.

13. Tools and audit

These tools are for Registered Managers and Responsible Individuals to check and improve their fire safety system. They do not replace the fire risk assessment or professional fire safety advice.