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HIQA Regulation 28 Fire Safety: What Nursing Homes Must Evidence

Author

Paddy McDonnell

Date Published

Nursing home corridor with care nurse and medication trolley showing fire safety compliance features - Phoenix STS Ireland

Regulation 28 is the fire precautions regulation that HIQA uses when assessing nursing homes and other designated centres for older people. It is short on the page, but it is demanding in practice. It is not satisfied by having a fire alarm, a few extinguishers and a folder of certificates. The registered provider must be able to show that the centre is protected from fire risk, that residents can be moved to safety, and that staff know what to do when the alarm sounds or a fire is discovered.

The standard is especially important in nursing homes because the people most at risk may not be able to escape without help. Some residents may be sleeping, frail, confused, bedbound, receiving end of life care or dependent on evacuation equipment. A procedure that works in an office may fail in a care setting. HIQA therefore looks at the building, the fire systems, staffing, training, resident dependency, evacuation arrangements and the management records together.

This guide explains what Regulation 28 requires, what changed in the 2025 regulations, the common weak points seen in nursing home fire safety management, and how providers can keep the centre inspection-ready without turning compliance into a paper exercise.

The Current Legal Position

Regulation 28 sits within the Health Act 2007 (Care and Welfare of Residents in Designated Centres for Older People) Regulations 2013. Those regulations have been amended several times. The current set is commonly referred to as the Health Act 2007 (Care and Welfare of Residents in Designated Centres for Older People) Regulations 2013 to 2025.

A point worth correcting is the status of S.I. 1/2025. It is no longer the current amendment. It was revoked by S.I. 98/2025, which came into operation on 31 March 2025. Regulation 28 itself remains the fire precautions regulation, but the wider 2025 amendments matter because they strengthen governance, management, risk management, notifications and related operational duties in designated centres.

Regulation 28 should also be read alongside the Fire Services Acts, the Safety, Health and Welfare at Work Act 2005, Building Control requirements, relevant Irish Standards and HIQA guidance. A building may have had a Fire Safety Certificate, but that does not prove the centre is compliant today. HIQA's Fire Safety Handbook makes this distinction clearly. The building must be managed for the residents who actually live there now.

What Regulation 28 Requires

The registered provider must ensure that adequate precautions are taken against the risk of fire. That includes the premises, the equipment, access for emergency services, bedding and furnishings, and the way the service is delivered. In practical terms, the centre must be able to prevent fire where possible, detect it quickly, contain it, raise the alarm, call the fire service and move residents to a place of safety.

The regulation also requires adequate means of escape, emergency lighting, fire detection and alarm systems, fire-fighting equipment, fire doors, compartmentation and the maintenance of fire safety systems. It requires arrangements for reviewing fire precautions. That review is important because a nursing home changes constantly. Residents' needs change, rooms change use, staff teams change, equipment moves, contractors carry out works, and a safe arrangement can become unsafe if nobody is checking it.

Staff training is specifically required. Regulation 28 refers to fire prevention, emergency procedures, the building layout and escape routes, the location of fire alarm call points, first aid fire-fighting equipment, fire control techniques and arrangements to be followed should a resident's clothing catch fire. These are not abstract topics. Staff should be able to explain the local procedure in their own words and show how they would carry it out.

Adequate Means Resident-Specific

The word adequate is doing a lot of work in Regulation 28. It cannot be judged by looking at the building alone. A centre with mostly independent residents may have a different risk profile from a centre where most residents require two staff and equipment to move safely. The same corridor, bedroom layout or compartment size can be acceptable in one setting and weak in another if staffing and dependency are different.

This is where fire safety management and care planning meet. Providers need to know who can self-evacuate, who needs prompting, who needs physical assistance, who needs a ski sheet or evacuation mattress, and who may resist movement because of dementia or distress. These details should feed into personal emergency evacuation planning, fire drills, night-time planning and staffing decisions.

Progressive horizontal evacuation remains central in many nursing homes. The usual idea is to move residents from the affected compartment into an adjoining protected compartment on the same level, rather than immediately trying to remove everyone from the building. That only works if the compartmentation is intact, fire doors close properly, smoke spread is controlled, staff understand the sequence, and there is enough space and equipment to place residents safely.

Fire Risk Assessment

A current fire risk assessment is the foundation of Regulation 28 compliance. It should be carried out by a competent person who understands residential care, not just commercial buildings. The assessment should look at ignition sources, fuel, oxygen, resident vulnerability, alarm arrangements, compartmentation, escape routes, evacuation equipment, fire doors, emergency lighting, staff training, drills, maintenance and the management of remedial actions.

The assessment should be reviewed after building works, changes in resident profile, significant staff changes, fire incidents, false alarm patterns, HIQA findings or changes to the evacuation strategy. Annual review is sensible for most nursing homes, but the trigger is not just the calendar. If the risk has changed, the assessment should be revisited.

Action plans need ownership and dates. HIQA inspectors will not be reassured by a good report if the same high priority items remain open months later. Fire door defects, gaps in compartmentation, missing fire stopping, poor storage, blocked escape routes and overdue servicing are practical problems. They should be tracked to completion and verified when closed.

Fire Safety Training and Drills

A useful drill programme should also record the safe evacuation time for the compartment being tested and the actual time taken. Where the actual time exceeds the safe evacuation time, the provider should carry out root-cause analysis rather than simply repeat the drill. The cause may be staffing, resident dependency, equipment location, alarm information, poor compartmentation or unclear role allocation.

The fire safety register should make this visible. It should include current compartment plans, alarm zone plans, the resident dependency profile by compartment, PEEPs, safe evacuation times, drill reports and evidence that corrective actions were closed. That is stronger evidence than a certificate file that proves attendance but not capability.

Fire safety training in a nursing home has to be local. Staff should know the alarm zones, the panel location, call points, escape routes, fire compartments, evacuation equipment, oxygen risks, laundry and kitchen risks, and the residents who need particular assistance. Agency, night, part-time and new staff need the same level of practical understanding. A centre is only as strong as the staff on duty at the time of the fire.

The clothing fire requirement is a good example of where training needs to be realistic. Regulation 28 requires arrangements and training for dealing with a fire involving clothing. It does not prescribe one exact method. In a real event, a carer may be much smaller than the resident, the resident may panic, move or fall, and staff may never have practised putting a blanket over a live person with flames coming from clothing. Providers should not write procedures that assume heroic actions which staff have never trained to perform.

A more defensible approach is to set out practical techniques, including raising the alarm, getting help, using the nearest suitable first aid fire-fighting equipment where safe, protecting the resident from further harm, and calling emergency services. Portable extinguishers may be more realistic than trying to smother a moving person with a fire blanket, depending on the circumstances, equipment and staff capability. The procedure should be agreed through the fire risk assessment and reflected in training.

Fire drills should test the actual evacuation strategy. A drill that only asks staff to gather at the alarm panel proves very little. Useful drills test decision-making, compartment movement, communication, resident dependency, night staffing assumptions, access to evacuation equipment and the handover to the fire service. Records should capture what happened, what worked, what failed and what action was taken afterwards.

Night-Time Fire Safety

Night-time is usually the most demanding scenario in a nursing home. Residents are asleep, staffing levels are lower, response time is slower, and the first few minutes depend heavily on the judgement of the staff on duty. A centre should not assume that a plan tested on a weekday afternoon will work at 3am with a smaller team and higher resident dependency.

The night procedure should deal with who checks the alarm panel, who investigates if safe to do so, who calls the fire service, who starts evacuation, who brings evacuation equipment, and how staff communicate if they are split across compartments. It should also deal with practical matters such as keys, magnetic door releases, oxygen, bariatric residents, residents who may resist movement, and access for the fire service.

Some providers refer to evacuation benchmarks when assessing whether staff can move residents quickly enough. Benchmarks can be useful, but they should not become a tick-box answer. The more important question is whether the centre has proved that its own staff, with its own residents, equipment, compartments and night staffing levels, can carry out the strategy in time.

Systems, Maintenance and Standards

The fire alarm, emergency lighting, fire doors, extinguishers, smoke control measures and evacuation equipment all need active management. Certificates alone are not enough if defects are not closed out. A fire alarm fault that appears repeatedly, an emergency light that fails a test, or a fire door that will not close properly should lead to a recorded action and a verified repair.

Irish Standards such as I.S. 3218 for fire detection and alarm systems and I.S. 3217 for emergency lighting are relevant when systems are designed, modified, commissioned and maintained. Nursing homes should keep clear records of servicing, weekly or periodic checks, faults, false alarm trends and remedial works. Where an older system is being relied on to support progressive horizontal evacuation, it should be reviewed carefully against the centre's current fire strategy and resident profile.

Records HIQA Will Expect to See

Good records do not replace good practice, but they prove that the system is being managed. A Regulation 28 file should include the fire risk assessment, action plans, fire alarm servicing, weekly alarm tests, emergency lighting tests, extinguisher maintenance, fire door checks, compartmentation surveys where carried out, staff training, drills, personal evacuation information, equipment checks and records of any fire incidents or false alarms.

S.I. 98/2025 also amended notification requirements. Schedule 4 now requires notification to the Chief Inspector within two days of any fire, and quarterly notification of prescribed events including any occasion where the fire alarm equipment is operated, other than for drill or test purposes. That makes accurate local recording more important. The centre should know the difference between a drill, a weekly test, a false alarm, a confirmed fire and an unplanned evacuation.

Records should be easy to retrieve during an inspection. If a person in charge cannot find the evidence, it is hard to show effective oversight. Digital systems can work well, but only if they are complete and staff know how to access them. Paper folders can also work, but they need version control and regular review.

Common Regulation 28 Weak Points

The recurring issues are familiar. Fire doors are wedged open, do not close properly, have damaged seals or excessive gaps. Escape routes are used for storage. Fire stopping above ceilings is incomplete after maintenance work. Bedrooms or stores are changed without considering the evacuation plan. Evacuation equipment is present but staff are not confident using it. Alarm records exist, but no one has acted on repeated faults or false alarms.

Another common weakness is treating training as an annual certificate exercise. HIQA inspectors may ask staff what they would do if the alarm sounded, where they would move residents, how they would use evacuation equipment, and who would call the fire service. If the answers are vague, the presence of certificates may not be enough.

A third weakness is separating the fire risk assessment from day-to-day care. If a resident's mobility deteriorates, the fire plan may need to change. If a resident moves bedroom, their evacuation route and equipment needs may change. If the centre accepts a higher dependency resident, night-time evacuation assumptions may need to be checked. Fire safety in a nursing home is not static.

How Phoenix STS Supports Providers

Phoenix STS works with nursing homes and designated centres across Ireland on Regulation 28 compliance. Services include fire risk assessments, compartmentation reviews, fire door surveys, I.S. 3218 fire alarm audits, fire safety training, evacuation planning, tabletop exercises and HIQA inspection readiness reviews.

The value of an external review is not just finding defects. It is connecting the building, staff practice, resident needs and management system into one workable plan. That means checking whether the evacuation strategy is credible, whether staff training reflects the actual centre, whether records prove oversight, and whether action plans are being closed rather than recycled after every inspection.

Providers who want a broader review of the 2025 HIQA guidance can also read our HIQA Fire Safety Handbook 2025 review. For practical emergency planning, our article on tabletop exercises for nursing home fire safety explains how to test decisions before a real incident.

Frequently Asked Questions

What is Regulation 28?

Regulation 28 is the fire precautions regulation in the care and welfare regulations for designated centres for older people. It requires registered providers to protect residents from fire risk through suitable fire precautions, fire safety management, staff training, evacuation arrangements, maintenance and review.

Did S.I. 1/2025 amend Regulation 28?

S.I. 1/2025 was revoked by S.I. 98/2025. The current citation is the 2013 to 2025 Regulations. Regulation 28 remains the key fire precautions regulation, while the 2025 amendments strengthen wider governance, risk management and notification duties that affect how fire safety is managed.

Does every nursing home need a fire risk assessment?

Yes. A competent fire risk assessment is essential evidence that the provider has considered the actual building, residents, staffing and evacuation arrangements. It should be reviewed when risk changes and at planned intervals.

How often should staff receive fire safety training?

Staff should receive training on induction and at suitable intervals afterwards. Annual refresher training is common in nursing homes, but the provider must also train sooner where staff roles, resident needs, procedures, equipment or the building change.

What should clothing fire training include?

It should cover the centre's agreed procedure for a fire involving clothing, including raising the alarm, summoning help, using suitable first aid fire-fighting equipment where safe, protecting the resident, and calling emergency services. The regulation requires techniques and arrangements. It does not prescribe one single method for every scenario.

Can Phoenix STS help before a HIQA inspection?

Yes. Phoenix STS provides Regulation 28 reviews, fire risk assessments, training and practical inspection readiness support for nursing homes. Call 043 334 9611 or use the contact page to discuss the centre.

Contact Phoenix STS

For support with Regulation 28, fire risk assessment, fire safety training or HIQA inspection preparation, contact Phoenix STS on 043 334 9611 or visit the Phoenix STS contact page.

This article is for general information only and is not legal advice. Requirements can vary depending on the building, residents, staffing arrangements and fire strategy. Providers should refer to current legislation, HIQA guidance and competent fire safety advice for their own centre.