Over the past few years, I’ve noticed a significant increase in demand for expert fire safety advice for both holiday and residential caravan parks, and in my experience, this demand is due to increased enforcement activity from the Local Authority. Back in October 2017, one local authority quoted:
‘Whilst the situation of park homes is very different to Grenfell as they are not high rise buildings, the issue of cladding and fire safety is still relevant in terms of the quality of material that should be allowed and the separation distance between homes that needs to be maintained.’
At first glance, the Model Standards are quite straightforward; however, I have seen so many different interpretations. For park operators, this can leave a postcode lottery as to how flexible the Local Authority EHO is prepared to be.
In this article, I’ll cover some of the more common interpretations of the model standards, and along the way, I’ll add some links to some influential documents that provide further guidance.
Who do we work with?
Based in the UK, we specialise in health and safety and fire safety for the hospitality and leisure industry with particular focus on caravan parks both holiday and residential. We have carried out fire risk assessments all across the UK and provided expert fire safety advice to our clients across the UK and Europe.
Why do we have spacing issues?
It is not easy to determine precisely why we have spacing issues, but static caravan units have definitely grown in size over the years and so has customer demand for larger units. Even if we were to discount the huge financial implications, to completely reshuffle a park to accommodate a larger caravan simply isn’t an option on most parks. This has led to concrete bases being extended with paving slabs, which has ultimately reduced the separation distance. There is also a trend to install larger decking areas to provide more useable outside space. Finally, there was a definite period in time where some enforcement visits by the Local Authority were almost non-existent, attributable to budget cuts to local government services, and so even if a park operator wanted some further clarification, it wasn’t always easy to obtain.
The Model Standards
S.5 of the Caravan Sites and Control of Development Act 1960 grants a Local Authority the power to attach conditions to site licences and the Model Standards provide some indication of “good practice standards”. It is a common misconception that the Model Standards themselves are legislation, rather they identify the standards “normally expected as a matter of good practice on sites.” Having worked on parks across the UK, I can say with some certainty that no two parks are the same which makes legislating the Model Standards difficult and so the final say is left to the EHO.
There are two sets of model standards:
Model Standards 1989 covering holiday caravan parks
Model Standards 2008 covering residential caravan parks
For parks which have a mixture of residential and holiday caravans, the 2008 standards apply.
“When it was time to renew our Fire Risk Assessments I used Pete Thomas. Their reports are very user-friendly, clearly stating the issues and what should be done to resolve them; clear, concise and easy to follow. I value the pragmatic and balanced approach and the peace of mind that all is well. I would not hesitate to recommend Pete Thomas.” Dr Claire Zabell Owner of Ludgate House, Owls and The Elms Residential Parks
The ‘89 Standards states that “It is recommended that a 3-metre wide area should be kept clear within the inside of all boundaries” and the ‘08 Standards state: “No caravan or combustible structure shall be positioned within 3 metres of the boundary of the site.”
Some further guidance is provided in Revising the Model Standards for Park Homes – December 2005: “Where the potential threat from fire is minimised, such as when the park is adjacent to fields or water then this requirement can be relaxed.”
It also provides some further guidance:
“If a new licence is to be issued to an existing park it is probable that the boundaries of the park are well established and that to alter the existing licence condition in respect of boundaries would cause unnecessary hardship.”
I have seen a mixed response in response to boundaries. A positive example was where two parks with the same owner share a boundary, the decision was reached that provided the units either side of the boundary were separated sufficiently then there were no fire safety concerns. A less positive response was a minor breach where a holiday caravan shared a boundary with an unused car park. Despite the unit being 2m away at the nearest corner, the decision was that it must be moved.
Density and spacing between caravans
The ’89 Standards state that the minimum separation distance between two units should be 5m and 3.5m at the corners provided the units are “made of aluminium or other materials with similar fire performance properties”.
I am not aware of any guidance on what is considered “similar fire performance properties” and this ambiguity is open to interpretation. One site licence I reviewed stated:
“the cladding must meet Class 1 standard as tested under BS 475-7 (for surface spread of fire). As an example, timber cladding, even where painted/impregnated with a fire retardant finish, will not be acceptable”.
In contrast, December 2005 paper referred to earlier states that:
“A distance of less than 6 metres between park homes could be acceptable where the facing walls of two homes are specifically constructed (or treated) for fire resistance.”
Admittedly, the latter is in relation to residential parks, but it should be considered, and I have seen this reflected in holiday park site licences.
The ‘89 Standards also state:
“where there is a mixture of holiday caravans of aluminium and plywood, the separation distance should be 6 metres.”
More ambiguity; does this mean mixed construction in two adjacent units or that a park has one plywood unit then ALL separation distances must be 6m? I have seen the latter on one park where a timber staff lodge increased the separation distance for ALL aluminium units on the park.
The ‘08 Standards require a 6m separation distance between units with the following caveat:
“Where a caravan has been retrospectively fitted with cladding from Class 1 fire rated materials to its facing walls, then the separation distance between it and any adjacent caravan may be reduced to a minimum of 5.25m.”
Note the word retrospective; again, I have seen a park site a new unit constructed of modern fire-resistant material, only to be told to increase the separation distance to 6m as the cladding wasn’t fitted retrospectively.
I’ve also seen a residential park with historic spacing issues which was signed off, however, when one resident sought to improve fire safety by installing fire-resistant cladding they were stopped as the park home was in breach of the 5.25m, despite the argument that these works would surely improve fire safety.
The Mobile Homes Act 2013 – A Best Practice Guide for Local Authority Enforcement on the New Site Licencing Regime recognises that ‘Historical spacing issues cannot usually be resolved quickly or easily’, and later explains that:
“A sensible approach is to draw a line in the sand; accepting existing contraventions and then put site licence conditions in place that, going forward, are clear and can be enforced.”
The ’89 Standards explain that where “Ramps for the disabled, verandahs and stairs” extend from the unit, there should be a clear 3.5m from the adjacent unit.
Whereas the ’08 Standards state that “Any structure including steps, ramps, etc. (except a garage or car port), which extends more than 1 metre into the separation distance shall be of non-combustible construction”.
This is perhaps the only time I prefer the ’89 Standards as it simply makes a clear requirement for the amount of remaining separation distance. Consider a disabled ramp constructed from modern fire-resistant decking which is just over 1m wide to allow for ease of wheelchair egress. I have also seen two units with a separation distance well over 7m where the decking extended 20cm over the recommendation. The requirement made was for the 20cms of decking to be removed and constructed out of concrete. There is no clear definition of non-combustible, and some areas won’t accept fire-resistant as non-combustible.
The ’89 Standards state that “Exposed gas bottles or cylinders should not be within the separation boundary of an adjoining unit.”
Whereas the ’08 Standards have removed this requirement, which seems sensible given that LPG regulators are always located in some sort of separation distance. Again, I have seen a site licence refused as the LPG cylinders are located in the separation distance.
How does this relate to a fire risk assessment?
A fire risk assessment or FRA is an assessment of the risk to life from fire. As with most areas of safety, this process follows a logical structure; first, we evaluate the risk of a fire starting, ignition sources, and then the consequences of said fire.
Of course, the Model Standards must be considered as part of an FRA, but this is only one piece of the puzzle as the Standards predominantly concern themselves with the consequences of a fire and not the risk of ignition. Reduce the risk from the ignition, and then the overall risk is reduced accordingly.
The Standards focus on the risk of a fire spreading to an adjacent unit and causing harm to someone within that adjacent unit. Yes, again this must be considered, but the Revising the Model Standards for Park Homes – December 2005 refers to the fire retardant-qualities of park homes being last tested in 1989 report and that “new homes are built to BS3662 which requires higher levels of insulation and protection than its 1989 predecessor”. Yes, the ‘08 Standards refer to park homes, however, the improvement in technology around fire-resistant materials must still be considered as part of fire risk assessment and, although the ’08 Standards would not be considered by the Local Authority for the site licence, as a risk assessor I would still consider them to be influential. Finally, it is hard to categorise a park as high risk for a “breach” of the site licence conditions while it is widely accepted elsewhere in the country.