When Is a Waking Watch Required and What Are the Obligations?

Summary

Waking watch services became widespread in the wake of the Grenfell Tower fire in June 2017. When surveys of high-rise residential buildings began identifying serious fire safety deficiencies — particularly combustible cladding but also compartmentation failures and inadequate detection — building owners and fire risk assessors had to consider what interim measures were needed to protect residents until remediation could be completed.

A waking watch provides a continuous human patrol by trained staff who can detect a fire in its early stages and alert all residents immediately. In buildings with stay-put evacuation strategies (the norm for purpose-built blocks of flats), the waking watch monitors the building and, on detecting a fire or seeing smoke, initiates a simultaneous evacuation. This provides the early warning that automatic detection would otherwise give.

The costs of waking watch services have been enormous — running to thousands of pounds per day in some larger buildings. The combined pressure of these costs, which were often passed to leaseholders, and the logistical difficulty of maintaining watch 24 hours a day prompted the government to fund interim common alarm systems in many buildings, allowing waking watches to be stood down. The Waking Watch Replacement Fund (WWRF) provided grants for this purpose, now closed to new applications but relevant to understanding the policy context.

Key Facts

• Legal basis — Not mandated by any single piece of legislation; arises from fire risk assessments and enforcement action by fire and rescue authorities
• NFCC guidance — National Fire Chiefs Council guidance on simultaneous evacuation and waking watches (updated 2022); primary reference for responsible persons and fire risk assessors
• Purpose — Interim life safety measure where automatic detection is absent or inadequate, and where compartmentation or external cladding creates elevated risk
• Buildings typically affected — High-rise residential blocks (over 17.7m or 6 storeys in most guidance); lower buildings with severe deficiencies
• Staffing — Sufficient staff to patrol the entire building continuously; minimum 1 watcher per building, but typically multiple per storey depending on size
• Duties of watcher — Patrol designated areas; detect early signs of fire/smoke; alert all residents using agreed method; call fire service; assist evacuation
• Training — Watchers must be trained in building layout, patrol procedures, alerting methods, communication, and evacuation; no national mandatory qualification but NFCC guidance sets expectations
• Communication — Watchers must have working communication devices and access to all areas including plant rooms
• Log keeping — Patrol logs must be maintained; records of any incidents, false alarms, or concerns
• Waking Watch Replacement Fund (WWRF) — Government grants now closed; funded interim common alarm systems to replace waking watches
• Common alarm system — Preferred alternative: a system that gives automatic warning to all flats simultaneously; allows waking watch to be stood down
• Building Safety Act 2022 — Placed duties on accountable persons and principal accountable persons for higher-risk buildings; waking watch is within the interim safety measures framework
• Costs — Highly variable; typically £10,000–£30,000+ per month for a large block; cannot lawfully be passed to qualifying leaseholders under the BSA 2022 in most cases

Quick Reference Table

Detailed Guidance

Why Waking Watch Is Required

Purpose-built blocks of flats in England and Wales have traditionally operated on a "stay-put" evacuation strategy. The design principle is that each flat is a self-contained fire compartment — if a fire starts in one flat, residents in other flats are safer staying where they are than evacuating through potentially smoke-filled common areas. The fire brigade fights the fire in the affected flat while the rest of the building remains in place.

This strategy works only when:

1. The compartmentation between flats is intact — the fire is contained to the flat of origin
2. There is sufficient automatic fire detection in common areas to alert the fire service and any affected residents quickly
3. The structure, external cladding, and building elements do not promote rapid fire spread

Where surveys found combustible cladding, defective compartmentation, or absent detection in common areas, the stay-put strategy was undermined. A fire could spread beyond its compartment, or could spread up the exterior cladding, reaching other flats before residents were aware. In this scenario, a simultaneous evacuation strategy — where everyone leaves the building when a fire is detected anywhere — is the safer approach. A waking watch is the human mechanism for delivering that simultaneous evacuation when automatic systems cannot.

NFCC Simultaneous Evacuation Guidance

The NFCC published its guidance on simultaneous evacuation strategies in 2020, updated in 2022. This guidance sets out when responsible persons should consider a simultaneous evacuation approach and the requirements for implementing it:

When to consider simultaneous evacuation:

• The external wall system of the building has been assessed and found to have significant fire risk
• There are serious and widespread compartmentation failures that cannot be quickly remediated
• The fire detection system in common areas is absent or seriously deficient
• The fire risk assessment concludes that stay-put is not safe given the building's condition

Implementing simultaneous evacuation: The NFCC guidance identifies two routes:

1. Waking watch: Human patrols cover the whole building continuously. On detecting a fire, watchers alert all residents simultaneously and call the fire service. Immediate; no infrastructure required; expensive and not sustainable long-term.
2. Common fire alarm system: An automatic or common alarm system that can alert all flats simultaneously. Requires installation of hardware (detectors, sounders, wiring); takes time to install; permanently solves the alerting problem; much lower ongoing cost than waking watch.

The guidance establishes that the common alarm system is the preferred solution. A waking watch is explicitly described as a short-term interim measure pending the installation of a common alarm or the remediation of the underlying building deficiencies.

Waking Watch Operations

Staffing levels: There is no single mandated formula. The number of watchers required depends on the size of the building, the layout, the number of floors, and the time it takes for a single watcher to complete a patrol. The principle is that the entire building must be under continuous observation — if a watcher is at the top of a 20-storey building, the ground floor is unobserved. For large buildings, multiple watchers on different zones operating concurrently is required.

A common starting point is one watcher per 2–3 floors, plus a coordinator who is not assigned to a patrol zone and can manage communication and emergency response. Fire risk assessors and fire and rescue authorities may specify staffing requirements in enforcement notices or in the conditions for changing the evacuation strategy.

Patrol routes and frequency: Watchers must patrol designated areas including:

• All common corridors and stairwells
• Bin stores, plant rooms, and other risk areas
• External areas (particularly where cladding is the primary concern)
• The car park and ground floor areas

Patrol intervals should be frequent enough that a fire could not develop to a dangerous level between patrols in any area. For typical high-rise residential buildings, a complete circuit of all floors every 10–20 minutes is often specified.

Alerting methods: When a watcher detects a fire, the building must be simultaneously alerted. Methods used include:

• A manually operated alarm panel or additional sounders
• Air horns (where no common alarm exists)
• A phone cascade to residents (slower and less reliable)
• Knocking on all doors (impractical in large buildings)

The alerting method must be effective enough to wake sleeping residents and must be audible throughout the building. Where a watcher detects a fire, the fire service must be called immediately — watchers are not expected to fight the fire.

Log keeping: A detailed patrol log must be maintained for every patrol. Records must show:

• Time and date of each patrol
• Areas covered
• Anything of note observed (including early indicators such as the smell of smoke, propped fire doors, apparent hazards)
• Any incidents or alarms
• Changes of personnel

Logs must be retained and available to the fire and rescue authority and the responsible person.

Training Requirements

The NFCC guidance requires that waking watch personnel are appropriately trained. While there is no single mandatory national qualification, training must cover:

• The building's layout, patrol routes, and all access points
• The specific risks identified in the fire risk assessment
• The alerting procedure — how to raise the alarm and in what sequence
• Communication — how to contact colleagues and the fire service
• Basic fire safety awareness — recognising signs of fire and smoke
• Evacuation procedures — supporting vulnerable residents and the fire service
• Log keeping

Training records must be maintained. In practice, specialist waking watch companies typically provide their own training and can demonstrate competency. Where in-house staff are used, the responsible person must ensure documented training has been provided.

Transition to Common Alarm System

The NFCC guidance and the Waking Watch Replacement Fund were both explicitly aimed at replacing waking watches with common alarm systems. The steps for transition:

1. System design: A suitably qualified fire engineer or alarm designer specifies a common alarm system appropriate for the building — typically a Type 5 fire alarm system to BS 5839-6 or a bespoke solution for larger multi-occupied buildings
2. Building Regulations / planning: For new external equipment or significant wiring works, Building Regulations notification may be required
3. Installation: By a certificated fire alarm contractor (BAFE SP203 or equivalent)
4. Commissioning and testing: Full commissioning in accordance with BS 5839; confirmation that the system provides reliable detection and alarm throughout the building
5. Resident communication: Residents must be informed of the new system, how to respond to the alarm, and the change in evacuation strategy
6. Risk assessment review: The fire risk assessment must be updated to reflect the new system and any remaining deficiencies
7. Stand-down of waking watch: Once the system is operational and the risk assessment confirms adequate protection, the waking watch can be stood down

The responsible person should not stand down the waking watch without confirmation from the fire risk assessor that the common alarm system provides sufficient mitigation. Premature stand-down before the system is proven creates an unmanaged risk.

Costs and Leaseholder Protections

Waking watch costs have been a major point of contention. In many buildings, responsible persons attempted to recover costs from leaseholders through service charges. The Building Safety Act 2022 introduced protections for qualifying leaseholders that prevent them from being charged for remediation of relevant defects, including the costs of interim measures such as waking watches that are necessitated by those defects.

The legal position is complex and depends on:

• Whether the leaseholder is a "qualifying leaseholder" under the BSA 2022 definition
• Whether the building's height triggers the BSA protections (over 11m)
• The nature of the defect that triggered the waking watch
• Whether the landlord or a connected developer is primarily liable

Leaseholders facing waking watch service charges should seek specialist legal advice. Building owners and managing agents should seek legal advice before passing costs to leaseholders.

Frequently Asked Questions

Is a waking watch a legal requirement?

Not in the sense of being mandated by a specific statutory provision. The obligation arises indirectly: the RRO requires the responsible person to implement adequate fire precautions. Where the fire risk assessment concludes that the building's current condition means occupants cannot be safely evacuated without a waking watch, implementing one is what adequate fire precautions require. Fire and rescue authorities can also impose waking watches through enforcement notices.

How long must a waking watch continue?

Until the underlying risk is adequately mitigated. This means either: the deficient cladding or compartmentation is remediated to the point where the fire risk assessment confirms stay-put is appropriate again, or a common alarm system is installed and commissioned that provides equivalent early warning. There is no fixed maximum period — some buildings have been under waking watch for several years while remediation programmes have been delayed.

Can the waking watch be stood down at night?

No. A waking watch must operate continuously — 24 hours a day, 7 days a week, including bank holidays. A building is not more fire-safe at night; in fact, sleeping occupants are at greater risk because they cannot smell smoke or see the early signs of fire. Any gap in coverage negates the purpose of the waking watch.

What should residents do if they are concerned about the waking watch quality?

Residents should report concerns to the responsible person (landlord or managing agent) and, if they are not satisfied with the response, to the local fire and rescue authority. The FRA has powers to inspect the building and the waking watch arrangements and can issue enforcement notices if standards are not being met. Residents in buildings with waking watches are also encouraged to check the NFCC guidance to understand what they should expect.

Regulations & Standards

• Regulatory Reform (Fire Safety) Order 2005 — General fire precautions duty; waking watch as a precaution

• Fire Safety Act 2021 — Extended RRO scope; relevant to external wall assessments that trigger waking watches

• Building Safety Act 2022 — Accountable person duties; leaseholder protections against waking watch service charges

• Fire Safety (England) Regulations 2022 — Fire door checks, evacuation plans for higher-risk buildings; waking watch in context of overall safety management

• NFCC Simultaneous Evacuation Guidance (2022) — Primary operational guidance on waking watches and common alarm systems [verify current edition]

• BS 5839-1:2017 — Fire detection and alarm systems for buildings; design, installation, commissioning

• BS 5839-6:2019 — Fire detection and alarm systems for domestic premises; code of practice

• NFCC Simultaneous Evacuation Guidance — National Fire Chiefs Council operational guidance

• Waking Watch Replacement Fund — GOV.UK — Government scheme for interim alarm systems

• Building Safety Act 2022 — leaseholder protections — GOV.UK guidance

• DLUHC Cladding remediation guidance — GOV.UK collection

• cladding fire safety — External wall fire safety requirements and assessment

• fire risk assessment — When risk assessments trigger waking watch requirements

• emergency evacuation plans — Simultaneous vs stay-put evacuation strategies

• fire safety order — Responsible person duties under the RRO