We have submitted a response to the government's Emergency Evacuation Information Sharing Consultation. 

The wording for our response is based on a really helpful summary from CLADDAG Leaseholder Disability Action Group.

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We are responding to this consultation on behalf of a disabled people's organisation: Greater Manchester Coalition of Disabled People.

Greater Manchester Coalition of Disabled People (GMCDP) believes that every  disabled resident unable to self-evacuate should have the right to a Personal Emergency Evacuation Plan (PEEP), which enables them to reach a place of safety. This was a key recommendation of the Grenfell Enquiry Phase One. The Government’s proposal does not give disabled people this right.

We are concerned that the proposals only apply to ‘high risk’ buildings with simultaneous evacuation strategies in place. However, mid and high rise buildings which are subject to a ‘stay put’ strategy might need to switch to an emergency evacuation in the event of a fire at any time. 

The Home Office accepts that it takes the fire service some time to reach a fire in a high rise building and/or start rescuing people after they get on site. Disabled and older people should be able to start evacuating as soon as possible and not wait unnecessarily to be ‘rescued’.

The consultation focuses on mobility-impaired disabled people, rather than disabled people as a whole. People who may be unable to self-evacuate may also include Deaf people, people with sensory loss or cognitive impairments, people with learning disabilities, neurodivergent people and those with mental health issues.

The proposal claims that there are liability issues for disabled residents to rely on “untrained or non-professional people” to help them evacuate (such as family, PAs or neighbours). However, there are approximately 13.6 million unpaid carers in the UK who the Government relies upon to provide care for disabled and older people and deems them to be fully competent and safe.

We feel that placing the burden on disabled people to ‘self-identify’ for an assessment is wrong. A disabled resident may not know the barriers they would experience in an evacuation, particularly if it has not happened before or if they have recently acquired an impairment.

The proposal says that the costs of evacuation aids should fall on the individual disabled, Deaf or older person. This is not appropriate (when adaptation to common parts benefits everyone, including visitors). We are also concerned that many disabled people will be unable to afford the necessary evacuation aids. The Government must provide non-means tested funding for any costs associated with putting PEEPs in place.

As a matter of urgency, reliable digital systems should be put in place for responsible persons to share complete and accurate information with the fire service, in a secure manner, which is available in an emergency situation.

Deaf and disabled people's organisations should be commissioned to co-produce any toolkits and guidance documents.

Responsible Persons (“RPs”) must be obliged to support and advise residents about the right to have a PEEP. All communication must be accessible and available in a range of formats. Responsible Persons should undergo mandatory training.

The standard of person-centred fire risk assessments need to be monitored regularly. and there needs to be a complaints process so that individuals can challenge poor assessments.

GMCDP also has concerns about how the consultation was carried out. On the consultation website you say “It’s important that we receive as diverse and broad a range of views as possible to inform our approach, so welcome your engagement with this consultation.” However, disabled people have not been given the opportunity to fully engage because of the lack of accessible information.

GMCDP first emailed the Fire Safety Unit at the beginning of June 2022 to ask about an Easy Read Version of the Consultation. We finally received the document on the 5th August 2022. Even with the extension to the closing date it gives little time to circulate the document and for people to find the necessary support to complete it. We also have concerns about the quality of the Easy Read document.

If the Fire Safety Unit wished to engage in a genuine consultation it could have set up focus groups/workshops for disabled people  or funded Disabled People's Organisations (DPOs) to do this, with an adequate response time built in. GMCDP did ask in June 2022 if you were going to engage with DPOs, but received no response to this question

The workshops that were organised by the Fire Safety Unit were dominated by professionals with very little representation from disabled people. 

Finally, as far as we know, there is no information about the consultation available in British Sign Language.

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