Interpretation of Fire Regulations

HMO Licensing

I am applying to renew a HMO licence in Leeds. But there seems to have been a change in interpretation of the regulations in relation to a 2nd form of fire exit for residents on the second floor.

This is a 6 bed house with two bedrooms in the basement who's only form or exit is through the lounge so a secondary exit is provided via an escape window. Makes sense.

The first and second floor bedrooms exit via a central staircase at the bottom of which are two fire doors. One leading through the lounge and the other through the Kitchen. So if either of these are on fire the second form of exit is through the alternate room.Both these rooms have fire doors. So for a fire to spread from the kitchen to the lounge it would have to burn through a fire door, cross the hall and burn through another fire door.

What Leeds City Council seem to suggest is that a second form of escape has to be through a first floor bedroom window which means that bedroom must have its locks removed.

This creates an issue that did not previously exist. Its not been mentioned on previous applications

My question relates to the interpretation of the word 'either'.

If the escape route passes through 'either' of the risk rooms (lounge kitchen) then a secondary route must be provided. I agree.

But the escape route can not pass through both rooms at the same time so the secondary escape route is through the other risk room which is not on fire and protected by - in effect two fire doors.

The regulations were written to protect tenants if 'either of the risk rooms were on fire. Not for circumstances were both risk rooms were on fire separately at the same time.

So taking a lock off a first floor bedroom door in effect creates a third route and means that tenants privacy and property are more at risk.

I hope you understand the issue here and have access to the relevant regulations to read and provide your own interpretation.