Agenda item

The report supported the presentation to Performance Committee and provided an overview of Lancashire Fire and Rescue Service’s (LFRS) risk-based approach to managing the risk in Houses in Multiple Occupation (HMOs), including the scale of the risk, recent fire and enforcement data, emerging pressures, and the collaborative arrangements in place with Local Housing Authorities.

Area Manager, Matt Hamer informed Members that HMOs represented a complex area of risk due to high occupancy levels, shared facilities, and often, the vulnerability of residents. While Local Housing Authorities (LHAs) were the lead regulator for most HMOs, LFRS retained responsibility under the Regulatory Reform (Fire Safety) Order 2005 for higher-risk and more complex premises, including taller buildings and mixed-use accommodation.

Lancashire had over 68,000 regulated premises, with HMOs forming a significant and growing component of residential risk. The current three-year Risk Based Inspection Programme (RBIP) identified 5,085 high and very high-risk premises. A fully established Protection establishment (Level 4 competent staff) provided capacity for up to 3,000 audits per year. To maintain a three-year intervention cycle, the Service aimed to complete 1,500 high-risk audits per annum, prioritising premises that presented the greatest life risk.

A HMO was defined as a property occupied by three or more tenants forming more than one household, sharing basic facilities. Larger HMOs were those with five or more tenants. Local Housing Authorities were the lead regulator for most HMOs, including licensed and unlicensed properties. LFRS acted as the enforcing authority for higher-risk premises, such as:

-        HMOs within mixed-use buildings,

-        Taller and more complex residential layouts,

-        Hostels, hotels, and accommodation managed by local authorities.

The dual-regulatory framework required strong coordination to ensure that risk was effectively managed without duplication.

Local authority data indicated several hundred known HMOs across Lancashire, with the majority being below three storeys, but a smaller number of 3-6 storey HMOs that presented elevated risk. Between 2021 and 2025, LFRS attended 125 primary fires in HMOs:

-        63% occurred in licensed HMOs,

-        33% where licensing status was unknown,

-        4% in known unlicensed HMOs.

Since 2021, LFRS had undertaken significant regulatory activity within HMOs, including audits, enforcement notices, alterations, and prohibitions. Enforcement action had been used proportionately to address serious deficiencies and manage risk where compliance could not be achieved through advice or informal measures.

Emerging risk pressures were:

-        Rapid growth in small (3-4 person) HMOs that fell outside licensing schemes, reducing visibility and oversight.

-        Increased investor ownership, often by individuals based outside the area, making engagement and compliance more challenging.

-        Growing use of HMOs as supported accommodation, housing residents with increased vulnerability, which elevated life risk and complexity.

LFRS worked closely with all Lancashire Local Housing Authorities through:

-        A formal Memorandum of Understanding (MoU),

-        Selective licensing and joint initiatives targeting higher-risk HMOs and rogue landlords.

-        Information sharing and coordinated enforcement activity,

-        Attendance at pan-Lancashire housing leads forum,

-        Continual safeguarding and signposting through prevention pathways (e.g. Home Fire Safety Check (HFSC) / Business Fire Safety Checks (BFSC),

-        National Leadership on Improving premises risk data, including development of improved local data systems.

County Councillor A Riggott commented that only 6 Councils in Lancashire had issued an Article 4 Directive to remove permitted development rights for HMOs and some Councils were not exercising their regulatory powers.

The Chair asked if the severity of injuries of those involved in HMO fires was recorded as she believed it would be useful campaign material and encourage Councils to issue Article 4 Directives. Area Manager, Matt Hamer confirmed that the severity was recorded as slight, serious, or fatal.

Councillor S Sidat queried whether Councils could identify some unlicenced HMOs through the Housing benefits system based on addresses with multiple claimants. Area Manager, Matt Hamer advised that the matter was left to professional judgement. Due to personal circumstances, many tenants of unlicenced premises could be claimants of multiple benefits and some opportunistic landlords use an individual’s vulnerabilities to increase rent charges.

In response to a question from Councillor Sidat regarding Homes of Multiple Occupation, Area Manager, Matt Hamer explained that if the residents were from the same family (immediate or extended), it would be classed as a single private dwelling. The perspective from the Fire Service would be prevention in the home. He advised that he would check the legislation with regards to classification and the number of family members in one household as there were grey areas in housing and planning legislation, and fire safety.

In response to a question from the Chair in relation to Air BnBs, Area Manager, Matt Hamer explained that the property was classified as a single private dwelling, however, when hosting paying guests, it should be treated as a small property for paying guests in accordance with guidance. The Air BnB website advised guests to provide their own smoke detection. Nationally, Fire Services had collaborated with the National Fire Chiefs Council (NFCC) and Air BnB to raise awareness of fire safety issues. It was acknowledged that once a paying guest was present, the property should fall under paying guest regulations, however, it would need to be enforced. Following a fire in a glamping pod, the Service worked with the NFCC to shape guidance around those types of dwellings.

County Councillor highlighted a tax break that the government had introduced for renting additional rooms in homes, which could result in a growing number of HMOs. Area Manager, Matt Hamer advised that he would investigate it outside of the meeting.

The Chair queried the number of unlicenced properties in relation to slavery. Area Manager, Matt Hamer explained that he would liaise with the Fire Safety Manager in Blackpool as there was an organised crime response which identified victims of modern slavery.

County Councillor J Tetlow moved to note the report and presentation; seconded by Councillor S Sidat.

Resolved: - That the Performance Committee noted the report and presentation.