By Daniel Morgan-Williams, Founding Director, Visualise Training and Consultancy Ltd.
Ask most employers whether they have a fire evacuation plan and the answer is yes. Ask whether it works for the colleague who cannot read the exit signs from across the room, or who has never walked the back stairwell because nobody ever needed it, and the answer is often a pause. The plan exists. It was simply written for an imagined employee who sees the building the way the floor plan does.
This article is for occupational health, HR, health and safety leads, line managers and case managers, and for employees with sight loss who want to know what a sensible plan looks like. It covers what the guidance asks employers to do, how a personal emergency evacuation plan (PEEP) is built, and why a specialist visual impairment workplace assessment can make the difference between a plan that exists on paper and one that people trust. It is general information, not legal advice.
Sight loss does not make a building unsafe to leave. Unfamiliarity does.
Nothing about sight loss means a person cannot leave a building in an emergency. Many people with sight loss move around familiar buildings confidently and quickly. What changes is the information they rely on. A person with central vision loss may not pick out a small exit sign. Someone with reduced peripheral vision may be slower to spot a hazard at the edge of their view in a crowded stairwell. A person who is totally blind relies on memory, touch and sound, and a route they have never practised is, to them, an unknown route.
The alarm itself is usually audible, so the warning is rarely the barrier. The barrier is what follows: knowing which way to go, which door is the nearest safe exit, whether the usual route is blocked, and what to do when the plan changes on the day. Those are information and familiarity problems, and both can be solved before anything happens.
What the guidance expects of employers
In England and Wales, the Regulatory Reform (Fire Safety) Order 2005 puts the duty on the “responsible person”, usually the employer or whoever controls the premises. Article 14 requires emergency routes and exits to be kept clear and, where necessary, to lead as directly as possible to a place of safety so that people can evacuate quickly and safely. The Order does not single out disabled people by name. It refers to relevant persons generally, which is why the supporting guidance matters.
That guidance is the Home Office publication Fire safety risk assessment: means of escape for disabled people. It was first published in 2007, updated in September 2023 to summarise its legislative status, and is marked as applying to England. Its core points are consistent and practical. A plan should not rely on the Fire and Rescue Service to make it work. The disabled person should be consulted, with their opinions and experience sought and respected. Nobody should assume that a disabled person cannot leave the building independently. Staff and regular visitors can have an individual plan, while occasional visitors are covered by standard options. A PEEP should be offered at induction and not only to people who appear to need one, and plans should be practised at least every six months.
For sight loss specifically, the guide points to good colour definition and accessible signage, contrast on stair nosings, avoiding open risers on escape routes, and instructions available in Braille, large print or audio. It suggests a tactile map of escape routes can help and recommends orientation training for visually impaired staff. Where someone uses a guide dog, the dog may guide them out, or they may prefer a human buddy, in which case someone may also be needed to look after the dog.
Building a personal emergency evacuation plan with the employee
A good PEEP is a conversation, not a form. The person who understands the barriers best is the employee, so the starting point is to ask them what they find easy, what they find difficult, and what has worked in other buildings. The sections below set out the elements that most plans need to cover.
Familiarisation with the routes
The Sight Advice FAQ, produced by a group of UK sight loss charities including RNIB and Guide Dogs, notes that evacuation routes, procedures and assembly points are usually covered at induction, and that some blind and partially sighted people want to learn the main routes and practise leaving through emergency exits soon afterwards. Offering that practice walk, with a colleague who knows the building, is one of the simplest and most effective steps an employer can take. It should include the route the person would actually use from their own desk, the alternative route if that one is blocked, and the assembly point.
Information in a format the person can use
Evacuation procedures need to reach the person in a form they can read independently. The Sight Advice FAQ suggests an ordinary Word document will work for many access technology users. Others will want large print, audio or Braille. Ask rather than assume, and keep the plan somewhere the employee can find it themselves.
A buddy, where one is wanted
A buddy system can help someone who is still learning the routes, or who prefers human assistance. It works best when the buddy has been told what to do, the employee has agreed to the arrangement, and there is more than one buddy so that cover exists when someone is on leave or in a meeting. The last two points are practical suggestions rather than something the guidance prescribes in detail. The buddy’s role is to offer to help, and to ask how the person would like to be guided, not to take hold of them.
The physical environment
Contrast on stair edges, clear signage at a sensible height and in large, high-contrast lettering, uncluttered corridors and good lighting on escape routes all reduce the need for help. The Northern Ireland guidance on evacuating disabled people adds a point that is easy to forget: when the internal layout changes, whether a temporary diversion, a moved partition or stored boxes in a corridor, the people who rely on a learned route need to be told.
Drills, reviews and change
A plan that has never been tested is a hope. Include the employee in fire drills, ask afterwards what worked, and update the PEEP if the route, the team, the floor or the person’s sight changes. Reviewing the plan after any move to a new desk or building is just as important as the six-monthly practice.
Where the Equality Act fits in
Fire safety law and the Equality Act 2010 are separate, though they point the same way. Under section 20 of the Equality Act, an employer must take reasonable steps where a provision, criterion or practice, a physical feature or the absence of an auxiliary aid puts a disabled person at a substantial disadvantage. Providing information in an accessible format can be one of those steps, and the employer cannot generally require the disabled person to pay for the adjustment. Schedule 8 also provides that the duty does not apply where the employer does not know, and could not reasonably be expected to know, that the person is disabled and likely to be affected. Whether a particular adjustment is reasonable depends on the circumstances, and nothing in this article is a conclusion about any individual case.
In practice, this is a good reason to ask about emergency arrangements early. An employer who never asks may not be in a position to say it did not know.
Scotland, Northern Ireland and Ireland
Fire safety law is devolved. In Northern Ireland, Part III of the Fire and Rescue Services (Northern Ireland) Order 2006 and the Fire Safety Regulations (Northern Ireland) 2010 apply, and the 2011 guidance produced for the Department of Health, Social Services and Public Safety makes the same core points: the responsibility cannot be delegated to the Fire and Rescue Service, individual plans are written with employees, and plans are practised at least every six months. Scotland has its own legislation under the Fire (Scotland) Act 2005 and separate Scottish Government guidance on evacuating disabled people, which was not reviewed in detail for this article, so employers there should check the current Scottish guidance directly.
In Ireland, the Health and Safety Authority’s June 2021 guide to employees with disabilities says employers should consult staff individually and document PEEPs for those who need them, updating them after issues arise in routine drills. It points to Regulation 25 of the Safety, Health and Welfare at Work (General Application) Regulations 2007, which requires workplaces to be organised, where necessary, to take account of workers with disabilities, and to the Employment Equality Acts on reasonable accommodation, unless the cost would be disproportionate.
What this means for occupational health, HR and case managers
Emergency planning is one of the quieter reasons a return to work or a new start stalls. Nobody refuses to provide a plan. It just sits on the list behind the equipment, the screen reader and the desk move, until the first fire drill. A few questions help to bring it forward.
Has the employee been offered a PEEP, and was it offered before their first day or return date? Was the person consulted, or was a plan written for them? Have they walked the real route from their own workstation, including the alternative route? Are procedures available in the format they use? Does anyone know who the buddies are, and what happens when they are away? If the workstation, the floor or the team changes, who is responsible for updating the plan?
For case managers and insurers, a documented evacuation plan is also a practical sign that adjustments have been thought through properly, rather than limited to the obvious equipment. None of this involves a judgement on the person’s fitness for work. It is about the building, the information and the process.
Why a specialist assessment helps
A general fire risk assessment looks at the premises. It will not usually ask a person with Retinitis Pigmentosa, glaucoma or macular disease how they find stairwells in low light, whether they can read the signs from where they stand, or how they would cope with a diverted route. A visual impairment workplace assessment looks at the way the individual works and moves through their own environment, including emergency arrangements where they are relevant, and produces practical recommendations that the employer, occupational health and the fire safety lead can act on together.
Summary
Sight loss does not stop anyone leaving a building in an emergency, but an unfamiliar route, an inaccessible procedure or an unannounced change can. The official guidance, in England, Northern Ireland and Ireland alike, asks employers to consult the person, write an individual plan, offer it at induction, practise it at least every six months where guidance says so, and keep it up to date. Signage, contrast, information formats, familiarisation and a buddy where wanted do most of the work. The aim is a plan the employee has helped shape and trusts.
Next step
If you or someone in your team is visually impaired and would like expert, tailored support to stay productive and comfortable at work, visit https://visualisetrainingandconsultancy.com/workplace-assessments/visual-impairment-workplace-assessments/ to arrange a visual impairment workplace assessment.
Frequently asked questions
Does an employer have to produce a personal emergency evacuation plan for an employee with sight loss?
Employers in England and Wales have duties under the Regulatory Reform (Fire Safety) Order 2005 to make sure people can leave safely. The Home Office guidance recommends individual plans for staff who need them and says a PEEP should be offered at induction. Whether a plan is needed or adequate for a particular person depends on the circumstances.
What should be in a PEEP for someone who is blind or partially sighted?
It usually covers the route from the person’s own workstation, an alternative route, the assembly point, how information is provided, whether a buddy is wanted, how a guide dog is handled, and how and when the plan is reviewed. The employee should help to write it.
Can a guide dog user evacuate with their dog?
The Home Office guide says a guide dog user may prefer the dog to guide them, or may ask for a human buddy. In the second case, someone may also be needed to look after the dog. Ask the person what they would like to happen.
How often should evacuation plans be practised?
The Home Office guide and the Northern Ireland guidance both say plans should be practised at least every six months. Review the plan too whenever the route, the workstation or the person’s sight changes.
Who is responsible for telling an employee about changes to the escape route?
The employer, or whoever has responsibility for the premises. The Northern Ireland guidance says internal layout changes should be communicated to partially sighted people, and the same sensible approach applies elsewhere.
Is an alarm enough to keep an employee with sight loss safe?
The alarm is the warning, not the plan. Most fire alarms are audible, but the person still needs to know which way to go, what to do if the usual route is blocked and where to meet. Dual sensory loss needs a separate approach.
Sources
Home Office, Fire safety risk assessment: means of escape for disabled people (first published 2007, updated 12 September 2023): https://www.gov.uk/government/publications/fire-safety-risk-assessment-means-of-escape-for-disabled-people
Home Office, Fire safety risk assessment: means of escape for disabled people (accessible version): https://www.gov.uk/government/publications/fire-safety-risk-assessment-means-of-escape-for-disabled-people/fire-safety-risk-assessment-means-of-escape-for-disabled-people-accessible-version
The Regulatory Reform (Fire Safety) Order 2005, article 14: https://www.legislation.gov.uk/uksi/2005/1541/article/14
Equality Act 2010, section 20: https://www.legislation.gov.uk/ukpga/2010/15/section/20
Equality Act 2010, Schedule 8, paragraph 20: https://www.legislation.gov.uk/ukpga/2010/15/schedule/8/paragraph/20
Sight Advice FAQ, How can I help a colleague with sight loss in an emergency evacuation?: https://www.sightadvicefaq.org.uk/employment-work/staying-in-work/Evacuation
Department of Health, Social Services and Public Safety (Northern Ireland), Fire Safety Law: The Evacuation of Disabled People from Buildings (2011): https://www.nifrs.org/wp-content/uploads/2021/02/Fire-Safety-Law-The-Evacuation-of-Disabled-People-from-Buildings.pdf
Health and Safety Authority (Ireland), Employees with Disabilities: an employer’s guide (June 2021): https://www.hsa.ie/eng/publications_and_forms/publications/safety_and_health_management/hsa_disability_guidelines_2021.pdf
Safety, Health and Welfare at Work (General Application) Regulations 2007, regulation 25: https://revisedacts.lawreform.ie/eli/2007/si/299/section/25/revised/en/html
Note on sources: the Home Office guide dates from 2007 and applies to England. The Northern Ireland and Irish documents are the official guidance for those jurisdictions. The Scottish Government guidance was not reviewed in detail, and the position in Wales rests on the 2005 Order and should be checked with the relevant fire and rescue authority. This article is general information and is not legal advice.