Fire Risk Assessment — Practitioner Reference

This reference provides practitioner-level depth on UK fire risk assessment — the RRO 2005 framework, the Fire Safety Act 2021 scope clarification, PAS 79 methodology, the post-Grenfell residential framework, the BSA 2022 HRB regime, third-party certification, and the records regime. The layman version is at /fire-risk-assessment.

1. Legal framework

The fire risk assessment duty rests on a layered regulatory framework that has expanded materially since Grenfell.

1.1 The Regulatory Reform (Fire Safety) Order 2005

The principal regulation in England and Wales. Key provisions:

• Article 3 — defines the Responsible Person. Multiple Responsible Persons can exist in a building; cooperation is required under Article 22.
• Article 9 — duty to make a "suitable and sufficient" fire risk assessment.
• Article 9(3) — duty to review where the assessment is no longer valid or there has been significant change.
• Article 11 — duty to make and maintain fire safety arrangements.
• Article 13 — duty to provide fire-fighting equipment, fire detection, and fire warning.
• Article 14 — duty to provide emergency routes and exits including emergency lighting where necessary.
• Article 17 — duty to maintain the premises and the fire safety equipment.
• Article 18 — duty to use competent persons for fire safety assistance.
• Article 21 — duty to provide adequate fire safety training to employees.
• Article 22 — duty to cooperate where there are multiple Responsible Persons.

The RRO is enforced by the Fire and Rescue Authority for each area, with HSE retaining enforcement powers in specific workplace contexts.

1.2 The Fire Safety Act 2021

The Fire Safety Act 2021 amended the RRO to clarify scope for buildings with two or more sets of domestic premises. Key provisions:

• The FRA scope must include the building's structure and external walls (including cladding, balconies, windows, anything attached to the building envelope) and the entrance doors to individual flats
• The clarification removed the ambiguity that had allowed some pre-Grenfell FRAs to omit external wall examination
• Applies to all buildings in scope of the RRO regardless of height — though depth of examination varies by height and construction

The Act's scope clarification has had operational impact:

• FRAs prior to 2021 typically did not include external wall examination
• Post-2021 FRAs must include structure and external wall scope
• Existing buildings have required FRA refresh to bring scope into compliance

1.3 The Fire Safety (England) Regulations 2022

The Fire Safety (England) Regulations 2022 impose additional duties on Responsible Persons of multi-occupied residential buildings:

For all multi-occupied residential premises with two or more sets of domestic premises:

• Provide fire safety instructions to residents
• Provide information about fire doors
• Provide information about fire alarms

For buildings 11m+ in height:

• Quarterly checks of communal area fire doors
• Annual checks of flat entrance fire doors (with reasonable access)
• Reporting on fire safety performance

For buildings 18m+ in height (HRBs under BSA 2022):

• Provide information about external wall construction
• Maintain a secure information box on the premises
• Provide a building plan and external wall information to the local FRS
• Wayfinding signage in the building

These regulations operate alongside the RRO and the BSA 2022.

1.4 The Building Safety Act 2022

The Building Safety Act 2022 created the regulatory framework for Higher-Risk Buildings:

HRB definition: Residential building of at least 18m height or 7+ storeys, with 2+ residential units.

Accountable Person duties:

• Assess building safety risks
• Take all reasonable steps to control them
• Produce a safety case report
• Engage with the Building Safety Regulator (BSR)
• Maintain a golden thread of information
• Report mandatory occurrences

The Principal Accountable Person (PAP):

Where multiple APs exist (e.g., freeholder for structure, leaseholder for areas under their control), a PAP is designated as the primary coordinator. The PAP holds responsibility for the safety case and BSR engagement.

The safety case:

A documented assessment of building safety risks including fire and structural risks. The fire risk assessment forms part of the safety case. The safety case is reviewed by the BSR at registration and at trigger events.

1.5 Equivalent provisions

• Scotland — Fire (Scotland) Act 2005 and Fire Safety (Scotland) Regulations 2006
• Northern Ireland — Fire and Rescue Services (Northern Ireland) Order 2006 and Fire Safety Regulations (Northern Ireland) 2010

Substantive duties are broadly similar across jurisdictions; specific procedural and enforcement details vary.

2. PAS 79 methodology

PAS 79 is the recognised methodology for fire risk assessment in the UK. The current publications:

• PAS 79-1:2020 — Fire risk assessment. Part 1: Premises other than housing. Code of practice.
• PAS 79-2:2020 — Fire risk assessment. Part 2: Housing. Code of practice.

The two-part structure replaced the single PAS 79:2012 in 2020, reflecting the post-Grenfell need for distinct methodologies for non-residential and residential applications.

2.1 PAS 79 nine-step framework

PAS 79 sets out a nine-element framework:

1. Information about the premises and the people

   • Building plans, occupancy data, use, fire history, vulnerable users

2. Examination of the premises and work activities

   • Physical walk-through, examination of construction, examination of fire safety systems

3. Identification of fire hazards

   • Sources of ignition, sources of fuel, structural conditions

4. Assessment of likelihood of fire

   • Based on hazards and existing controls

5. Determination of fire protection measures

   • Passive (compartmentation, fire resistance, fire-stopping) and active (detection, alarm, suppression)

6. Information on relevant persons

   • Employees, public, vulnerable users, all those affected

7. Assessment of likely consequences

   • Harm that could result from fire

8. Assessment of fire risk

   • Combining likelihood and consequence into a defensible rating

9. Action plan

   • Prioritised actions with target dates and ownership

The methodology supports proportionality — a small simple workplace requires less depth than a complex HRB, but the same elements apply. PAS 79 is the most defensible methodology and is treated as best practice by fire and rescue authorities, courts, and insurers.

2.2 Risk rating

PAS 79 does not mandate a specific risk matrix but expects the assessor to use a structured method to rate residual risk after controls are considered. Common approaches:

Qualitative rating — Low / Tolerable / Substantial / Intolerable, based on likelihood and consequence assessment.

Semi-quantitative rating — numerical scoring on defined scales for likelihood and consequence, with a combined risk score.

The rating itself is less important than:

• Whether the methodology is clearly stated
• Whether the rating reflects the actual residual risk
• Whether actions are prioritised by rating

A common deficiency is rating language that is inconsistent or that does not match the actions specified — for example, items rated "Intolerable" but with action target dates of 12 months.

3. Residential FRA inspection types

For residential premises, four inspection types are recognised (the typology pre-dates PAS 79-2 but is retained in supporting guidance):

3.1 Type 1 — Common parts only, non-destructive

Visual inspection of common parts including corridors, stairs, lobbies. No destructive examination. Doors to flats inspected from the outside. Most common residential FRA type pre-Grenfell.

Application: typical residential blocks where compartmentation is known to be sound and external wall construction is established.

3.2 Type 2 — Common parts including destructive inspection

As Type 1 plus selective destructive inspection of compartmentation in common parts — typically targeted at:

• Penetrations through compartment walls and floors
• Stair shaft compartmentation
• Roof void compartmentation
• Service riser sealing

Application: where Type 1 reveals concerns about compartmentation, or where construction documentation is unreliable.

3.3 Type 3 — Common parts plus flats, non-destructive

As Type 1, plus inspection within flats (with the owner's permission). Inspection of flat entrance doors from the inside, flat compartmentation, escape provision within flats.

Application: where flat-level provision warrants verification, particularly for HMOs and assisted living premises.

3.4 Type 4 — Common parts plus flats, with destructive inspection

The most comprehensive residential FRA. Combines Type 2 destructive inspection in common parts with Type 3 access to flats and destructive inspection within them where warranted.

Application: high-risk residential premises, post-incident assessment, HRBs where the safety case warrants comprehensive evidence.

3.5 Inspection type selection

Post-Grenfell, the proportion of Type 2 and above inspections in residential blocks has increased. Drivers:

• Fire Safety Act 2021 explicit scope inclusion of external walls and structure
• BSA 2022 HRB safety case requirements
• Insurer PI market hardening, making comprehensive inspection a commercial necessity
• Public concern leading to enhanced scrutiny of fire safety provision

The FRA scope should be agreed with the duty holder before commissioning, with the inspection type and any destructive elements specified in the brief.

4. Competence framework

RRO Article 18 requires competent persons. The competence framework for fire risk assessors:

4.1 Third-party certification schemes

BAFE SP205 — Life Safety Fire Risk Assessment. The principal third-party certification scheme. Assesses both individual assessors and organisations.

IFE Register of Fire Risk Assessors — recognised register, with grades from associate to senior membership.

FRACS (Fire Risk Assessment Competency Council) — competency framework with multiple assessor grades.

IFSM Register — recognised alternative.

4.2 Individual qualifications

• NEBOSH National General Certificate (baseline awareness)
• NEBOSH National Certificate in Fire Safety
• NEBOSH National Diploma (senior practitioner)
• IFE membership (TIFireE, GIFireE, MIFireE)
• IOSH membership for the broader safety dimension

4.3 Sector-specific competence

For specific premises types, sector experience is increasingly the differentiator:

• Healthcare — HTM 05-03 awareness, NHS estates experience
• Custodial — high-security and prison estates experience
• HRBs — BSA 2022 framework competence, BS 8670 awareness
• Heritage buildings — listed building consent processes, historic construction
• Care and assisted living — specific occupant profile considerations

4.4 PI insurance

PI insurance markets for fire risk assessment hardened significantly post-Grenfell. Implications:

• Assessors without third-party certification face higher premiums or exclusions
• Insurance availability is itself a competence signal
• Reasonable cover should be verified at commissioning
• For HRBs, PI cover specifically for HRB work is increasingly required

A practical commissioning question: "What is your PI cover for this type of building, and does the policy specifically extend to BSA 2022 work?" Unsatisfactory answers indicate a competence mismatch.

5. Scope determination

The FRA scope should be agreed with the duty holder before work begins. Scope elements:

Physical scope:

• Building or buildings included
• Areas accessed
• Areas excluded and why (e.g., individual flats in a Type 1)
• Inspection type for residential

Element scope:

• Structural inspection depth
• External wall examination depth
• Compartmentation examination
• Active fire safety system review (alarm, suppression, emergency lighting)
• Passive fire safety review (compartmentation, fire doors, fire-stopping)
• Means of escape evaluation
• Fire safety management review

Declared limitations:

• Areas not accessed and the implications
• Documentation reviewed and what was not available
• Presumptions made and their basis
• Areas where the assessment could not reach definitive conclusions

The declared scope and limitations protect both the assessor and the duty holder. An FRA with vague scope and undeclared limitations is harder to defend and harder to act on.

6. The action plan

PAS 79 expects a prioritised action plan as the operational output of the assessment. Elements:

Action statement — specific, actionable language. "Replace fire door FD30 to flat 12" rather than "Improve fire door provision."

Priority — typically Immediate / High / Medium / Low (mapped to the risk rating).

Target date — specific date for completion, not "as soon as possible."

Responsible person — named individual or role responsible for delivery.

Verification — how the action will be verified as complete (typically by re-inspection or certificate).

The action plan should be tracked through completion. A common deficiency is action plans produced at assessment but not subsequently tracked, with no documented closure of items between assessments.

7. Review intervals

The RRO does not specify an FRA review interval. Article 9(3) requires review where the assessment is no longer valid or there has been significant change. Industry consensus:

Annual review — practical baseline for most premises. Documents continued validity even where no significant changes have occurred.

More frequent review — quarterly or six-monthly for:

• HRBs under the BSA 2022 safety case regime
• Complex commercial premises with substantial change
• Healthcare premises
• Custodial settings
• Care premises

Full reassessment — every 3-5 years even where annual reviews have identified no change. Captures cumulative drift.

Trigger events:

• Building changes (extensions, refurbishment, change of use)
• Change of occupancy
• Fire safety system changes
• Fire incident
• Near miss
• Regulatory change

Even where review identifies no changes, the review itself should be documented. An FRA with annual reviews recorded over five years is in a stronger documentary position than one with the original assessment alone.

8. Multiple Responsible Persons and the duty to cooperate

RRO Article 22 imposes a duty to cooperate where multiple Responsible Persons exist. In multi-occupied buildings:

• Each tenant is typically RP for their demised area
• The landlord or freeholder is RP for the structure and common parts
• Managing agents typically have devolved RP duties

Article 22 cooperation in practice means:

• Coordinated FRAs covering complementary scope
• Shared access to relevant information
• Joint or coordinated action planning where issues span multiple RPs
• Designated lead RP for coordination (commonly the landlord/freeholder or managing agent)

A common deficiency is poor cooperation between RPs, with separate uncoordinated FRAs covering overlapping scope, gaps where neither RP has assumed responsibility, and contradictory findings.

For HRBs, the BSA 2022 Principal Accountable Person structure addresses the cooperation challenge with a designated coordinator.

9. Specific premises types

9.1 Healthcare premises

Healthcare premises require sector-specific competence. Key references:

• HTM 05-03 — Operational provisions (multi-part)
• HTM 05-01 — Managing healthcare fire safety
• HBN (Health Building Notes) — design guidance for specific care environments

Critical considerations:

• Patient evacuation strategies (progressive horizontal evacuation typical)
• Sleeping risk with vulnerable users
• Continuous occupancy
• Specific high-risk areas (operating theatres, oxygen storage, MRI suites)
• Bariatric and reduced-mobility provision

9.2 Custodial premises

Custodial premises (prisons, immigration detention, secure mental health) require sector-specific competence. Key features:

• Locked occupants — evacuation requires staff intervention
• High occupant density
• Specific risks (cell fires, deliberate ignition)
• Integration with security regime
• Specific HMPPS guidance

9.3 Heritage and listed buildings

Heritage buildings require consideration of:

• Listed building consent for any alterations
• Historic construction methods (timber frames, plaster, lath construction)
• Restricted scope for active intervention
• Conservation officer engagement
• Specific guidance from Historic England, Historic Environment Scotland, Cadw

The fire safety strategy often relies more heavily on management, training, and surveillance where physical intervention is constrained.

9.4 HMOs

Houses in Multiple Occupation require specific consideration:

• Local authority licensing conditions (varying by authority)
• BS 5839-6 alarm provision (typically Grade D Category LD1 or LD2)
• Mixed responsibility between landlord and tenants
• Frequent occupant change

9.5 Holiday and short-let premises

Short-let premises occupy a regulatory grey area. The premises are non-domestic in use (occupied by paying guests, not domestic residents) and the RRO applies. Considerations:

• Fire safety provision equivalent to small hotels
• Guest information provision
• Local authority licensing in some areas
• Insurance implications

10. Documentation and records

The FRA records that matter:

• The current FRA, in editable form
• All previous editions retained (the version history)
• Action plan with progress against each item
• Annual and trigger-event review records
• Supporting evidence — photographs, plans, certificates referenced
• Communications with enforcing authorities
• For HRBs, the safety case and golden thread
• Coordination records with other Responsible Persons

Retention should be for the life of the building plus a substantial period — five years minimum, longer for HRBs as part of the safety case.

11. The interface with the wider fire safety regime

The FRA references — and is referenced by — the wider fire safety records:

• Fire alarm system records (BS 5839-1) — design, commissioning, service, logbook
• Emergency lighting records (BS 5266-1) — testing logbook, certificates
• Fire extinguisher records (BS 5306) — service certificates, monthly check logs
• Compartmentation surveys and remediation records
• Fire door inspection records (Fire Safety (England) Regulations 2022 for residential 11m+)
• Smoke control system records where applicable
• Sprinkler/suppression system records
• Training records (RRO Article 21)
• Evacuation drill records

A common deficiency is the FRA referencing these systems generically without checking they exist or are current. The FRA should integrate the regime — recording what is in place, what is missing, and what is required.

12. Enforcement

Fire safety enforcement post-Grenfell has intensified materially. Themes:

Inadequate FRA scope. Buildings with FRAs that did not address external walls or compartmentation in line with the Fire Safety Act 2021 — particularly residential blocks where scope omission is now untenable.

FRA action plans not delivered. Premises where the FRA identified actions but they were not subsequently delivered, with the original FRA becoming evidence against the duty holder.

Competence challenges. FRAs produced by assessors without third-party certification or appropriate sector experience, particularly for residential blocks and HRBs.

Cooperation failures. Multi-occupied buildings where Article 22 cooperation broke down, leaving fire safety gaps that no Responsible Person addressed.

HRB safety case inadequacies. Buildings within BSA 2022 scope where the safety case is incomplete, the golden thread is fragmented, or the AP/PAP arrangements are not in place.

Sentencing under the RRO 2005 framework has produced significant penalties post-Grenfell. The Health and Safety (Offences) Act 2008 framework applies — unlimited fines on indictment, up to two years imprisonment for individuals. Recent prosecutions have produced six and seven-figure corporate fines and custodial sentences for individuals where the breach was reckless.

This pillar should be read alongside the layman version at /fire-risk-assessment and the related professional pillars on fire alarms, emergency lighting, and fire extinguishers.