Waking Watch vs Simultaneous Evacuation in HMOs

Fire and rescue services will shut an HMO down over the wrong escape strategy, not just a missing alarm. In one case in Hove, East Sussex Fire and Rescue served a prohibition notice on a house in multiple occupation because there was no protected route of escape from the upper floors, using the powers under Article 31 of the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005). The order followed failures under Article 14, which covers emergency routes and exits, and Article 13, which covers fire detection and warning. Get the evacuation strategy wrong and that is the kind of letter that lands on your doormat.

Landlords who have read about tower block cladding scandals sometimes ask whether their HMO needs a "waking watch". Almost none do. Waking watches and the related idea of simultaneous evacuation come from very different parts of fire safety, and mixing them up leads landlords either to pay for something they do not need or to miss the strategy their property actually requires.

What simultaneous evacuation actually means

Simultaneous evacuation is the strategy where, the moment a fire is detected anywhere in the building, every occupant leaves straight away. It is the default strategy in almost every HMO, and for converted houses it is usually the only sensible option.

The reason is compartmentation. A stay-put strategy, where only the flat on fire evacuates while everyone else remains behind a fire-resisting door, only works where each unit is genuinely sealed off from its neighbours. That level of fire resistance is what you get in a well-built, purpose-built block of flats. It is rarely what you get in a converted Victorian terrace with later partition walls, as we covered in our piece on fire compartmentation and the difference between 30 and 60 minute fire resistance.

Because most HMOs cannot guarantee that compartmentation, the fire risk assessment should specify simultaneous evacuation as the strategy, backed up by a common fire alarm system that every tenant can hear from their room, however they got there, a licensing condition in most areas, and clear escape routes, including usable escape windows where a protected stairway is not available.

What a waking watch is, and why it rarely applies to an HMO

A waking watch is a temporary, staffed patrol used in buildings, almost always tall blocks of flats, where a fire risk assessment has found a serious, specific defect, most commonly unsafe external cladding, and where the usual stay-put strategy can no longer be relied on until that defect is fixed. The National Fire Chiefs Council's Simultaneous Evacuation Guidance, now in its fourth edition, sets out when a building should temporarily switch from stay-put to simultaneous evacuation and how a waking watch or a common alarm system should support that switch.

Waking watches are expensive. Reported costs for blocks awaiting cladding remediation have run from several thousand pounds a week for a single building up to tens of thousands a week for larger developments, which is why the guidance pushes hard against leaving a waking watch in place any longer than necessary.

None of this describes a typical HMO. A waking watch solves a specific problem: a tall building designed around stay-put that no longer has the fire resistance to support it. A converted house or small block of HMO bedsits was never designed around stay-put in the first place, so there is no stay-put strategy to temporarily suspend. If your fire risk assessor recommends a waking watch for a standard HMO, ask them to explain exactly which defect it is meant to cover and for how long, because it is very likely the wrong tool for the job.

How to tell which strategy your property actually needs

Start with construction, not age. A purpose-built block of self-contained flats, built to current Building Regulations standards with fire-resisting floors and walls between units, can sometimes support stay-put. A converted house, whatever its age, usually cannot, because the walls and floors between rooms were never built or upgraded to the fire resistance a stay-put strategy needs.

Next, look at what actually separates one let room or flat from another. Original lath-and-plaster ceilings, hollow stud partitions, and gaps around pipework and cabling are common in conversions and all defeat compartmentation, whatever the fire door on the landing looks like. A single upgraded fire door does not create a fire-resisting compartment on its own.

Finally, check what the alarm system can actually do. Simultaneous evacuation only works if everyone in the building is warned at the same time, which means an interlinked system covering every room, not a handful of standalone smoke alarms. If your system cannot wake every tenant at once, your evacuation strategy is a plan on paper that will not work in practice.

Where it gets genuinely complicated

There is a smaller category of HMOs where this is less clear-cut: large, converted blocks of several storeys, sometimes with later extensions, sometimes with mixed construction types, that behave more like a purpose-built block than a terraced conversion. If your HMO falls into this category, do not try to work out the strategy yourself. Get a fire risk assessment from someone competent to assess compartmentation, not just alarms and escape routes, and be guided by their written reasoning rather than a generic template.

What should never happen is a landlord assuming stay-put is safe because "the fire brigade will handle it" or because a similar-looking building down the road uses it. The standard of fire safety expected in HMO communal areas exists precisely because landlords cannot assume their way to a safe evacuation strategy.

Common mistakes landlords make

The first is assuming the strategy is fixed for the life of the building. If you extend an HMO, add a loft conversion, or change a single room into two, the compartmentation and escape routes change with it, and the evacuation strategy needs reassessing, not carrying over unchanged from the last fire risk assessment.

The second is treating a waking watch as a cheap short-term fix for a different problem, such as a broken alarm panel or a blocked escape route. A warden patrolling the corridors does not fix a defective fire door or a locked fire exit, and relying on one as a substitute for proper repairs is the kind of shortcut that enforcement officers notice immediately.

The third is confusing "simultaneous evacuation" with "no plan needed". The strategy still has to be written down, tenants still need to know where to go, and the alarm still has to work. Simultaneous evacuation is a decision about how the building responds to fire, not an excuse to skip the planning.

What this means for your fire risk assessment

Your written fire risk assessment, which every responsible person has had to produce since the Building Safety Act 2022 removed the old small-premises exemption, should state the evacuation strategy explicitly. For the overwhelming majority of HMOs that will be simultaneous evacuation, supported by an adequate alarm system and clear, unobstructed escape routes.

It should not reference a waking watch unless your assessor has identified a specific defect that genuinely mirrors the cladding scenario the NFCC guidance addresses, has given you a cost and a clear removal date tied to fixing that defect, and has recorded all of this in writing. Anything less than that and you are likely paying for cover you do not need, or worse, using it as a substitute for fixing the underlying problem.

Next steps

Check your current fire risk assessment states an evacuation strategy in plain words, not just a list of equipment. If it says stay-put, or says nothing at all, that needs fixing before your next licence renewal or inspection, not after. FRASafe guides you through a BS 9792:2025-aligned fire risk assessment, free to complete, with a council-ready PDF for £45. Start your HMO fire risk assessment today and get the evacuation strategy on paper, properly.