Fire risk assessments (FRA)

ultimate guide

Ensuring robust fire safety in residential blocks is paramount for property managers, not only to comply with stringent regulations but to safeguard lives. Navigating these requirements can be complex, yet neglecting them carries significant risks, from severe legal repercussions to loss of life. 

That’s why it’s important to demystify Fire Risk Assessments (FRA) for multi-occupied buildings. Learn the fire safety measures every block manager must implement, identify common hazards to mitigate, and outline the most up-to-date legal obligations. 

Fire risk assessments (FRA) explainer guide

Underpinning these efforts are The Fire Safety (England) Regulations 2022, which mandate that a thorough FRA be conducted by the designated Responsible Person(s) for all blocks of flats. This responsibility typically falls to the landlord or any party with control over the premises, such as building managers or managing agents. This assessment is also a mandatory requirement for all rental properties, including Houses in Multiple Occupation (HMOs). 

What is a Fire Risk Assessment?

A Fire Risk Assessment involves a thorough examination of your premises and its occupants to identify potential fire hazards. The primary goal is to enhance fire safety measures, thereby safeguarding individuals from harm. 

Why fire safety is important

Multi-occupied residential buildings present distinct fire safety challenges. This is due to shared common areas, the diverse activities of different tenants, and typically high occupancy levels. Without adequate fire safety measures, you face several critical dangers:

  • Rapid fire spread due to insufficient containment. 
  • Increased likelihood of blocked escape routes, trapping residents. 
  • Potential legal action and severe penalties for non-compliance. 

A legal obligation

A FRA isn't just good practice, it's a legal requirement. If you're the Responsible Person for a building—such as a freeholder, head lessor, RMC or RTM directors of any premises that isn't a single private dwelling—you must ensure a suitably competent person completes an FRA. It's your duty to identify fire risks and hazards within your premises and take appropriate action to mitigate them. 

While legal compliance is a driving factor, effective fire prevention also makes sound economic sense. A thorough understanding of fire risks, gained through a properly conducted FRA, is the crucial first step in preventing such devastating incidents.

Types of Fire Risk Assessment

The specific fire risk assessment needed is determined by the building's type and use, as well as findings from inspections. They are as follows:

Type 1 Fire Risk Assessments

Type 1 is the most common type and is non-destructive. Its primary purpose is to ensure that the common parts of a building, such as a shared lobby in a block of flats, have the necessary arrangements for people to escape in the event of a fire, including clear signage for entry and exit points. 

While a Type 1 FRA assesses all common areas, it does not typically include individual dwellings. In some instances, it may inspect construction points between individual dwellings, such as shared supportive walls, but this is usually not required. 

The findings of a Type 1 FRA may indicate the need for additional FRAs. If this is the case, the Type 1 FRA will specify the reasons for such a requirement.

 

Type 2 Fire Risk Assessments

Type 2 is uncommon. They are usually advised only when a Type 1 FRA indicates potential serious structural defects within a building that could heighten the risk of fire propagation. 

This type of assessment involves destructive sampling, which necessitates the engagement of a contractor, thereby increasing the overall cost.

 

Type 3 Fire Risk Assessments

Type 3 is a comprehensive evaluation that extends beyond legal requirements. It encompasses all common areas of a building as well as individual dwellings. 

This assessment considers all escape routes, including those within individual residences, the building's structure, compartmentation between flats, and all fire detection systems. Type 3 FRAs are non-destructive and are typically only deemed necessary when fire risks are identified within individual dwellings. 

Arranging Type 3 FRAs can be challenging for landlords and building owners due to the necessity of gaining access to individual dwellings. These assessments are often more easily conducted when living spaces are unoccupied.

 

Type 4 Fire Risk Assessments

Type 4 are the most extensive and complex, involving destructive sampling in both the common areas and individual dwellings of a building, such as apartments. This comprehensive nature necessitates access to private residences and may result in the need for subsequent repairs due to the destructive sampling process. 

Consequently, they are only conducted in specific, limited situations, typically when there are concerns about serious defects in both the shared parts of the building and private living spaces. 

 

How to determine which Fire Risk Assessment is needed

A Type 1 Fire Risk Assessment is typically sufficient for most buildings, especially if the building is not new and has likely undergone such an assessment previously. 

More comprehensive assessments, such as Type 2 or Type 4 FRAs, are usually only recommended if a Type 1 assessment identifies specific risks or warrants further investigation. For instance, if a Type 1 FRA reveals inaccessible areas, like under floorboards, that raise concerns, a Type 2 or Type 4 FRA, which includes destructive sampling, may be advised. 

How to perform a Fire Risk Assessment

The FRA should be completed by a Responsible Person, who is legally obligated to do so. They can either conduct the assessment themselves if they are deemed competent or appoint a competent fire risk assessor to do it for them. Performing a comprehensive FRA is a systematic process, typically broken down into five steps: 

The first step involves a thorough inspection of the premises to pinpoint anything that could potentially start a fire (ignition sources) or contribute to its spread (fuel). This includes identifying faulty electrical equipment, combustible materials, heating systems, cooking areas, and potential sources of arson. 

Next, consider who might be affected by a fire and how. This involves assessing the number of occupants, their activities, and any specific vulnerabilities, such as people with disabilities, young children, or those unfamiliar with the building layout (e.g., visitors or new staff). This is where Personal Evacuation Plans (PEPs) come in, which are tailored plans to help individuals with disabilities or other limitations evacuate a building safely during an emergency, such as a fire. It's a document outlining specific procedures and assistance required for an individual's safe evacuation, recognising that not everyone can evacuate unaided or within the same timeframe. 

Once hazards and at-risk individuals are identified, evaluate the existing fire safety measures and determine if they are sufficient. The primary goal is to eliminate hazards where possible. If not, implement measures to reduce the likelihood of a fire starting and minimise its potential impact. This could involve improving housekeeping, securing flammable materials, or installing fire detection and suppression systems. 

It's a legal requirement to document the significant findings of your assessment, especially if you employ five or more people. Based on these findings, develop a clear and actionable emergency plan outlining procedures for evacuation, alerting emergency services, and assembly points. Crucially, ensure all occupants receive appropriate fire safety training and are familiar with the emergency plan. Regular fire drills are also vital. 

FRAs are not static documents. They must be reviewed regularly – annually for higher-risk buildings or buildings over 11m, or every three years at a minimum. Furthermore, the assessment must be updated whenever there are significant changes to the building's structure, layout, occupancy, processes, or fire safety provisions. This ensures the assessment remains relevant and effective in protecting lives. 

What does the assessor examine during a Fire Risk Assessment?

During a FRA, a qualified assessor meticulously evaluates several critical aspects to determine a building's fire safety profile. Their focus is generally on: 

They assess the probability of a fire starting within the building. This involves identifying potential ignition sources, such as electrical faults, heat sources, hazardous materials, and the presence of combustible materials that could fuel a fire. 

The assessor evaluates the potential impact should a fire occur. This includes considering the risks to life (occupants, visitors, firefighters), potential property damage, and the disruption to operations. 

A key component is understanding how fire and smoke spread throughout the building. The assessor examines the effectiveness of compartmentation, fire doors, firestopping, and other passive and active fire protection systems designed to contain a fire and protect escape routes. This could include Automatic Opening Vents (AOV), which is a type of smoke or fire vent designed to automatically open and close in response to a control system, typically triggered by a fire alarm, to help vent smoke and heat from a building. 

Specific considerations for multi-occupied residential buildings

For multi-occupied residential buildings, especially those exceeding 11 meters in height, specific regulatory requirements come into play regarding fire doors. 

For communal fire door checks, regulations mandate that responsible persons undertake inspections of all fire doors located in communal areas. This ensures their integrity and functionality. For all multi-occupied residential buildings in England with storeys over 11 metres in height to undertake quarterly checks of all fire doors in the common parts and undertake – on a best endeavour basis – annual checks of all flat entrance doors that lead onto a building’s common parts. 

The assessor might suggest enhancements to the fire door during the assessment, and the Responsible Persons will decide on their implementation. If defects are identified, maintenance or replacement may be required to ensure the door remains fit for purpose. However, a fire door in full working order from a fire safety perspective does not need to be replaced merely because it doesn't meet current Building Regulations standards. 

Additionally, annual checks are required for all flat entrance doors that open onto the building's common parts. 

These checks are crucial for verifying that essential features, such as the self-closing devices on these doors, are fully operational. Should any issues or defects be identified during these assessments, more detailed investigations may be necessary. This could involve consulting with a fire safety specialist or a qualified contractor to ensure all deficiencies are promptly and effectively addressed.

 

Relevant legislation

Building Safety Act 2022

Following the Grenfell Tower tragedy, the Building Safety Act 2022 was enacted to enhance fire safety, particularly in higher-risk structures. The Act establishes new obligations for building owners and managers, mandates updated fire risk assessments, and defines fire safety responsibilities across a building's entire lifecycle. It also provides financial safeguards for leaseholders concerning the costs of rectifying fire safety defects. 

Want to know more about the act? Our Building Safety Ultimate Guide is the perfect tool.

 

Health and Safety at Work etc. Act 1974

The Health and Safety at Work etc. Act 1974 provides the framework for managing workplace health and safety in the UK. It outlines the general duties for maintaining health and safety across most workplaces. These duties apply to everyone, from employers and employees to owners, managers, and maintainers of work premises which include communal areas of apartment blocks. 

Further specific legislation exists for business sectors operating in higher-risk environments, such as the construction industry or chemical manufacturing. 

Complementing the HASAWA 1974 are statutory instruments. These are secondary or delegated pieces of legislation that allow for minor changes, updates, or additions to existing legislation without requiring an entirely new Bill. 

 

The Regulatory Reform (Fire Safety) Order 2005

This is the main piece of legislation governing fire safety in buildings in England and Wales. 

It applies to all workplaces and the shared areas of buildings with two or more domestic residences. Under the FSO, the Responsible Person (typically the owner or landlord) is legally obligated to conduct and document fire risk assessments, as well as implement and maintain general fire safety measures. 

The Fire Safety Act 2021 clarified that fire risk assessments must include external walls, flat entrance doors, and the building's structure, as these are covered by the FSO. Further duties for Responsible Persons under the Fire Safety Order were introduced by the Fire Safety (England) Regulations 2022 and section 156 of the Building Safety Act 2022.

 

PAS 9980:2022

PAS 9980:2022 is a British Standard code of practice. It offers competent professionals a methodology to conduct Fire Risk Appraisals of External Wall (FRAEW) construction. The scope of PAS 9980 primarily covers existing blocks of flats, but also includes student accommodation and specialised housing. It outlines a five-step process for assessing external wall fire risk, including identifying potential hazards, gathering information, and determining risk factors. 

Intended users of PAS 9980 include fire engineers, building professionals, and others involved in fire safety assessments, such as block managers, building control bodies, insurers, and contractors. It's important to note that PAS 9980 is not a substitute for the EWS1 form but, instead, is a more comprehensive assessment method that informs the fire risk assessment of a building.

Discover the difference from EWS1 forms with our guide.

 

BS 9999

First published in 2008, BS 9999 partially superseded BS 5588 (Fire precautions in the design, construction and use of buildings), some parts of which are still relevant for residential properties. The latest edition was released in 2017. 

BS 9999 provides recommendations and guidance for the design, management, and use of buildings to ensure acceptable levels of fire safety for occupants and those in the vicinity. It emphasizes specifying the dissociation temperature of materials. 

It accommodates complex or larger buildings where standard guidelines may not apply. It allows for compensatory measures, such as adjusting travel distances or escape door widths, to maintain overall safety. 

The standard is relevant for new constructions, extensions, existing buildings, and those in the design phase. It also outlines methods for assessing aspects like easy access to exits and the safety of people. Furthermore, it covers maintaining fire detection systems, providing guidance on employee fire safety training, organising efficient evacuation plans, and assigning leadership responsibilities, ensuring robust and effective fire safety strategies.

 

BS 9991

This standard’s primary purpose is to ensure an adequate degree of life safety in residential buildings in the event of a fire, while also offering protection for nearby properties and businesses. 

Professionals involved in building fire protection are the main users of this standard. BS 9991:2024 provides recommendations and guidance on the design, management, and use of various residential building types to achieve reasonable fire safety standards for all occupants and those in the vicinity. 

 

Fire safety measures for residential blocks

Effective fire safety in multi-occupied residential buildings hinges on a multi-faceted approach. Here are the key measures block managers must implement and continuously uphold: 

Fire Risk Assessments (FRAs)

Under UK law, block managers are obliged to conduct comprehensive FRAs. This process involves:

  • Identifying potential fire hazards throughout the building. 
  • Evaluating the safety and accessibility of fire escape routes. 
  • Verifying the functionality of fire alarms and emergency lighting systems. 
  • Ensuring fire doors and fire extinguishers are operational and well-maintained.

It is imperative that these assessments are reviewed annually or whenever any significant changes occur within the building's structure, occupancy, or fire safety provisions. 

Fire doors and means of escape

Fire doors are a cornerstone of passive fire protection, crucial for compartmentalising fires and facilitating safe evacuation. Block managers must routinely check that: 

  • Self-closing devices on all fire doors operate correctly, ensuring doors fully close. 
  • Doors are free from damage, gaps, or missing intumescent strips, which are vital for sealing in the event of a fire. 
  • Escape routes remain clear and unobstructed at all times, providing unimpeded access for residents and emergency services.

In accordance with The Fire Safety (England) Regulations 2022, quarterly checks of communal fire doors are mandatory, alongside annual checks for flat entrance doors leading onto common parts. 

Smoke and fire detection systems

Robust detection systems are vital for early warning. UK law mandates a minimum for fire alarms in purpose-built blocks of flats. This requirement primarily applies to individual flats, not communal alarm systems, unless specific risk factors necessitate the latter. 

Since 1992, new-build individual flats must be fitted with smoke alarms as part of their early fire warning systems. These systems typically include interconnected and mains-powered (with standby battery) alarms: one smoke alarm in the hallway, another in the living room, and a heat alarm in the kitchen. These installations are mandated under Approved Document B and BS 5839-6. 

To ensure ongoing compliance with legal requirements and full operational readiness, regular testing and maintenance of these systems are essential. 

In purpose-built blocks designed for a "stay put" strategy with adequate compartmentation, a communal fire alarm system is typically not necessary. BS 5839-6:2019 advises against the use of domestic detectors in communal areas and explicitly states that communal systems are "normally undesirable". If a communal system is installed, it must comply with BS 5839-1 standards for non-domestic applications. 

A communal system should only be installed by the responsible person if compartmentation or escape routes are substandard, or if a simultaneous evacuation strategy is required. 

For buildings exceeding 18 meters in height, an evacuation alert system is mandated by Building Regulations. This system is activated manually by the Fire & Rescue Service, rather than through automatic detection. In converted blocks or those with inadequate compartmentation, a comprehensive Grade A fire alarm system (as per BS 5839-1) may be necessary to facilitate simultaneous evacuation. 

Emergency lighting and signage

In the event of a power failure or smoke-filled corridors, emergency lighting provides vital illumination for safe egress. Clear and unambiguous fire safety signage must be prominently displayed to indicate:

  • Fire exit routes. 
  • Designated assembly points. 
  • Locations of fire extinguishers and other firefighting equipment. 

Tenant fire safety awareness

Even the most advanced fire safety systems can be compromised by unsafe tenant behaviour. Therefore, block managers should proactively: 

  • Educate residents on crucial fire safety policies and procedures. For example, systems like Fixflo can evidence property managers have communicated to all owners and tenants their obligations under the terms of the lease with regards to fire safety and breaches around stored items in communal areas. 
  • Strictly prohibit the storage of flammable materials in hallways and other common areas. 
  • Ensure proper waste disposal practices are followed to prevent the accumulation of combustible materials that could pose fire hazards. 

What if a managing agent doesn’t carry out the Fire Risk Assessment?

Failure to conduct an FRA constitutes a breach of legal duty regarding resident safety. This can lead to severe penalties, including an unlimited fine, up to two years imprisonment, or both.

 

Prioritising fire safety works

Discovering non-compliant fire doors and a lack of proper record-keeping can quickly escalate rectification costs for property managers. This daunting prospect often leads to an initial instinct to delay, particularly when immediate funds are insufficient for all necessary work. 

Property managers must lean on their specialist suppliers. These experts can help alleviate panic by collaborating with clients and leaseholders to prioritise tasks and address required work in phases. This stage is ideal for developing a planned preventative maintenance strategy, differentiating between immediate necessities and work that can be scheduled and budgeted for later. This is crucial for meeting regulations and passing inspections. 

Financially, preventative maintenance is almost always more cost-effective than rectifying problems after they occur. Property managers overseeing multiple properties can achieve significant time and cost savings by coordinating planned preventative maintenance across their portfolios, as most buildings require similar lifecycle works over comparable periods.

Fixflo can help by auto scheduling the next FRA and tracking all Remedial Actions. Get in touch for more information on how Fixflo’s AI Remedial Assist can support your team.

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