PEEPs in Residential Buildings: Consideration of Vulnerable Residents

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April 1, 2026

PEEPs in Residential Buildings

Are You evidencing considerations of Vulnerable residents?

Regulators are increasingly scrutinising how housing providers identify and support residents who may not be able to self-evacuate in the event of a fire. 

Even in buildings operating a “Stay Put” strategy, the expectation is clear: vulnerability must be considered, documented, and defensible.

While full Personal Emergency Evacuation Plans (PEEPs) are not always mandatory in general needs residential blocks, housing providers must still demonstrate that vulnerable residents have been identified and their needs assessed.

Failure to evidence this consideration may be viewed as a breach under: 

The key issue is no longer simply “Do you have PEEPs?” — but rather:
Can you demonstrate informed, recorded decision-making?

Why this matters now

Post-Grenfall reforms and strengthened regulatory oversight have shifted expectations.

Housing providers are increasingly being asked: 

  • How do you identify residents who may struggle to evacuate?

  • How does your evacuation strategy account for vulnerability?

  • What is your process if circumstances change?

  • How would the Fire & Rescue Service access relevant information in an emergency?

The absence of documented consideration is often viewed more critically than the absence of formal PEEP itself. 

Key focus areas for housing providers

1. Vulnerability Identification

 

You should be able to evidence a process for identifying residents who:

  • Have mobility impairments

  • Use mobility aids or oxygen equipment

  • Have sensory impairments

  • Have cognitive or mental health conditions affecting response

  • May be temporarily vulnerable (injury, illness, pregnancy)

This does not require intrusive data gathering, but does require a reasonable, proportionate system.

Examples include:

2. Evacuation Strategy Suitability (Including Stay Put)

 

Many purpose-built blocks operate a Stay Put strategy. This relies on effective compartmentation and fire resistance to contain fire within the flat of origin. 

However, regulators are increasingly asking:

  • Has the Stay Put policy been assessed against your resident profile?
  • What happens if compartmentation is compromised?
  • What is your contingency plan?

An evacuation strategy should not simply exist, it should be reviewed in the context of who lives in the building.

3. Recorded Decision-Making

 

This is often the missing piece. 

If you decide that full PEEPs are not appropriate for a general needs block, that decision should be:

  • Risk assessed
  • Recorded
  • Reviewed periodically
  • Supported by clear reasoning

A written record demonstrating why a particular approach was taken can significantly reduce regulatory risk.

If it isn’t documented, it will be difficult to defend. 

4. Information Sharing with Emergency Services

 

Housing providers should consider: 

  • How vulnerability information is securely recorded
  • Whether there is a method to provide relevant data to the Fire & Rescue Service
  • Whether building risk information is accessible when required

This does not mean handing over sensitive data, but it does mean having a structured approach. 

What Regulators are looking for

Increasingly, enforcement bodies are looking beyond physical fire precautions and into governance and decision-making.

They want to see:

A blanket “We operate Stay Put so PEEPs are not required” is unlikely to satisfy scrutiny without supporting evidence. 

Practical steps you can take now

Review

Review whether your Fire Risk Assessments reference vulnerable residents.

Resident

Check whether resident profile data has been considered in evacuation planning.

Record

Ensure your decision-making process is recorded.

Responsible Persons

Clarify who is responsible internally for vulnerability oversight.

Revisit

Review how often this information is revisited and document any changes.

Final Thought

PEEPs in residential housing remain a complex and evolving area. The expectation is not necessarily that every resident has a bespoke evacuation plan — but that housing providers can demonstrate thoughtful, proportionate considerations of those who may be at greater risk.

In today’s regulatory climate, documentation and governance are as important as physical fire safety measures.

If you cannot evidence consideration, you may struggle to evidence compliance.

Contact Us Today Ensure Your residents are safety considered

Contact us today to duscuss a tailored review of your PEEPs and FRA compliance.

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